IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI
MISSOURI FARM BUREAU INSURANCE  BROKERAGE, INC.,

FARM BUREAU TOWN AND COUNTRY INSURANCE COMPANY OFMISSOURI

 AND FARM BUREAU LIFE INSURANCE COMPANY OF MISSOURI,

 Plaintiffs,
v
MITCH SHEETS,
Serve: 408 NW Essex Drive Lee's Summit, MO 64081
Defendant. 
Case No                 0716-CVQ770'S
PETITION:
COME NOW plaintiffs Missouri Farm Bureau Insurance Brokerage, Inc., Farm Bureau Town
& Country Insurance Company of Missouri and Farm Bureau Life Insurance Company of Missouri
and, for their Petition against defendant Mitch Sheets, states:
COUNT I
Claim for Preliminary and Permanent Injunction
1. Plaintiff Missouri Farm Bureau Insurance Brokerage, Inc. is a Missouri corporation
with its principal place of business in Jefferson City, Missouri.
2. Plaintiff Farm Bureau Town & Country Insurance Company of Missouri is a property
and casualty insurance company incorporated under the laws of the State of Missouri with its
principal plac.e of business in Jefferson City, Missouri.
3. Plaintiff Farm Bureau Life Insurance Company of Missouri is a life insurance 
company incorporated under the laws of the State of Missouri with its principal place of business
in Jefferson City, Missouri.
4. Defendant Mitch Sheets is an individual residing in Lee's Summit, Missouri.
5. From July 26, 1995 until June 7, 2006, defendant Mitch Sheets was an employee of
Missouri Farm Bureau Insurance Brokerage, Inc. In his capacity as an employee of Missouri Farm
Bureau Insurance Brokerage, Inc., defendant was responsible to market and service insurance
products for plaintiffs as an insurance agent of Farm Bureau Town & Country and Farm Bureau Life
and to also market and service insurance products offered through Missouri Farm Bureau Insurance
Brokerage, Inc.
6. In consideration for employment with Missouri Farm Bureau Insurance Brokerage,
Inc., defendant entered into written employment agreement (a copy of the employment agreement
is attached hereto as Exhibit "A" and incorporated herein by reference).
7. The aforementioned employment agreement provides as follows concerning the
obligations of defendant in the event his employment with Missouri Farm Bureau Insurance
Brokerage, Inc. is terminated for any reason:
9. Non-Interference. In the event that I shall cease to represent the Companies, I will not, either personally or through any other person, agency, or organization disturb the business which shall be on the books ofthe Companies at the time my employment is terminated by either of us. I will not solicit the renewals of said business, and recognize that it belongs to the Companies. I will permit the Companies to continue in full and peaceable possession of said business. I further understand and agree that in the event this agreement is violated, the Companies may obtain damages for its breach or may obtain injunctive or other equitable relief against me; without the necessity or requirement of posting a bond, cash or otherwise, from further violations of this agreement.
8. Defendant's employment with Missouri Farm Bureau Insurance Brokerage, Inc. was
terminated on June 7, 2006.
9. Subsequent to termination of his employment with Missouri Farm Bureau Insurance 
Brokerage, Inc., defendant became, and is currently, an insurance agent for insurance companies who
compete for insurance business with plaintiffs.
10. Subsequent to the termination of defendant's employment with Missouri Farm Bureau
Insurance Brokerage, Inc., defendant, in violation of the aforementioned Agreement, specifically
paragraph 9 of said Agreement, has solicited insureds of Farm Bureau Town 8: Country, Farm
Bureau Life and clients of Missouri Farm Bureau Insurance Brokerage, Inc. for purposes of inducing
them to cancel or non-renew their insurance policies with Farm Bureau Town & Country, Farm
Bureau Life and/or insurance carriers whose business was placed through Brokerage and place their
insurance with insurance companies that defendant currently represents.
11. Upon information and belief, defendant has further breached his contractual
obligations, as set forth in the aforesaid Agreement in that, upon information and belief, subsequent
to termination of his employment with Missouri Farm Bureau Insurance Brokerage, defendant,
without plaintiffs' knowledge or consent, has utilized and continues to utilize trade secrets and
proprietary information of plaintiffs, including customer lists and personal customer information,
for purposes of soliciting insureds of Farm Bureau Town & Country and Farm Bureau Life and/or
clients of Missouri Farm Bureau Insurance Brokerage, Inc. on behalf of defendant's current employer
and affiliated insurance companies.
12. Unless defendant is enjoined from continuing to contact or solicit insureds/clients of
the plaintiffs, and is enjoined from accessing, divulging or utilizing plaintiffs' trade secrets or other
proprietary information, including, but not limited to, its customer lists, as an insurance agent for
insurance companies who compete with plaintiffs, plaintiffs will suffer irreparable harm, injury and
damage, for which they have no adequate remedy at law.
WHEREFORE, plaintiffs Missouri Farm Bureau Insurance Brokerage, Inc., Farm Bureau T()wn & Country Insurance Company of Missouri and Farm Bureau Life Insurance Company pray for an order fUldjudgment of this Court against defendant as follows:
a. Enjoining defendant from directly or indirectly contacting or soliciting the plaintiffs' insurance customers/clients who were insurance customers/clients of plaintiffs as of the date of termination of defendant's employment agreement with Missouri Farm Bureau Insurance Brokerage;
b. Enjoining defendant from directly or indirectly divulging any of plaintiffs' trade secrets or proprietary information of which he has acquired knowledge during the course of his employment with plaintiff Missouri Farm Bureau Insurance Brokerage, Inc., or subsequent to the termination of such employment, to any third parties;
c. Ordering defendant to return to plaintiffs all trade secret and proprietary information, including, but not limited to, customer lists and customer insurance information, which defendant improperly obtained from plaintiffs.
d. Enjoining defendant frorn contacting or directly or indirectly inducing or attempting to induce any of plaintiffs' customers/clients as of June 7, 2006 to modify or terminate their business relationships with plaintiffs;
e. That pending final determination of this cause, the Court grant a preliminary
injunction to the same effect;
f. Grant plaintiffs such actual damages as plaintiffs have sustained as a result
of defendant's breach of the Agreement between plaintiffs and defendant;
g. Grant plaintiffs their attorney's fees and expenses in prosecuting this action; and
h. For such further relief as the Court deems just and proper.
COUNT II
COME NOW plaintiffs Missouri Farm Bureau Insurance Brokerage, Inc., Farm Bureau Tovm
& Country Insurance Company of Missouri and Farm Bureau Life Insurance Company and, for
Count II of their Petition against defendant Mitch Sheets, states:
13. Plaintiffs incorporate by reference, as if set forth in full herein, the allegations
contained in paragraphs 1-12 of Count I of plaintiffs' Petition.
14. As a result of defendant's breach of his contractual obligations, as aforesaid, plaintiffs
have sustained damages by reason of the loss of premium income and/or commissions as a result of
defendant's unlawful and unauthorized solicitation of plaintiffs' customers/clients and unlawfully
using plaintiffs' proprietary and trade secret information.
WHEREFORE, plaintiffs Missouri Farm Bureau Insurance Brokerage, Inc., Farm Bureau
Town & Country Insurance Company of Missouri and Farm Bureau Life Insurance Company pray
for judgment in their favor and against defendant for damages sustained; and for such further relief
as the Court deems just and proper.
Dana L. Frese #34646 
515 E. High Street
P.O. Box 28
Jefferson City, MO 65102 (573) 636-2177
(573) 636-7119

 

(court actions filed in this case)
16th Judicial Circuit (Jackson County)
0716-CV07705 - MO FARM BUREAU INS BROKERAGE V MITCH SHEETS
This information is provided as a service and is not considered an official court record.
Displaying 1 thru 17 of 17 dockets returned for case 0716-CV07705.

03/28/2007 Docket Entry: Pet Filed in Circuit Ct

Docket Entry: Filing:
Text: Form 4

04/12/2007 Docket Entry: Case Mgmt Conf Scheduled
Associated Events: 07/23/2007 , 10:30:00 - Case Management Conference

04/13/2007 Docket Entry: Summons Issued-Circuit
Text: Document ID: 07-SMCC-3393, for SHEETS, MITCH;

04/20/2007 Docket Entry: Member of Family Served
Text: Document ID - 07-SMCC-3393; Served To - SHEETS, MITCH; Server - THOMPSON, HAROLD L; Served Date - 18-APR-07; Served Time - 07:02:00; Service Type - Civil Process Server; Reason Description - Served; Service Text - BY LEAVING WITH SAMANTH SHEETS-DAUGHTER

05/03/2007 Docket Entry: Designation of Lead Attorney
Text: Kirk Rahm, Esq. is hereby designated as lead counsel for Defendant Mitch Sheets pursuant to Local Rule 3.5.1.
Filing Party: SHEETS, MITCH

Docket Entry: Entry of Appearance Filed
Text: Kirk Rahm, Esq. hereby enters his appearance as counsel for Mitch Sheets, Defendant
Filing Party: SHEETS, MITCH

05/11/2007 Docket Entry: Answer Filed
Text: to Petition
Filing Party: SHEETS, MITCH

06/11/2007 Docket Entry: Reply
Text: Reply to Answer to Petition
Filing Party: MISSOURI FARM BUREAU INSURANCE BROKERAGE INC,

06/13/2007 Docket Entry: Certificate of Service
Text: LP Interrogatories and Request for Production of Documents.
Filing Party: MISSOURI FARM BUREAU INSURANCE BROKERAGE INC,

06/15/2007 Docket Entry: Motion for Change of Judge
Text: LP
Filing Party: MISSOURI FARM BUREAU INSURANCE BROKERAGE INC,
Associated Docket Entries: 08/27/2007 - Motion Granted/Sustained


07/10/2007 Docket Entry: Objections Filed
Text: Objections to 1st Interrogatories
Filing Party: SHEETS, MITCH

Docket Entry: Objections Filed
Text: Objections to 1st Request for Production of Docmts
Filing Party: SHEETS, MITCH

07/13/2007 Docket Entry: Motion for Extension of Time
Text: LP W/Suggs
Filing Party: SHEETS, MITCH
Associated Docket Entries: 08/27/2007 - Motion Granted/Sustained


08/18/2007 Docket Entry: Certificate of Service
Text: LP Answers to 1st Set of Interr; Response to 1st Req for Prod of Docmnts
Filing Party: SHEETS, MITCH

08/27/2007 Docket Entry: Motion Granted/Sustained
Associated Docket Entries: 06/15/2007 - Motion for Change of Judge
LP
Associated Docket Entries: 07/13/2007 - Motion for Extension of Time
LP W/Suggs

08/31/2007 Docket Entry: Judge Assigned
Text: This case is transferred to Div 6

Displaying 1 thru 17 of 17 dockets returned for case 0716-CV07705.