IN THE CIRCUIT COURT OF JOHNSON COUNTY, MISSOURI AT WARRENSBURG

MCKELL YOUNG and LAUREL YOUNG  20 NW 750 Warrensburg, MISSOURI 64093 
May 27, 2005

Case No.CV405-382CC
Plaintiffs
v.
FARM BUREAU TOWN AND COUNTRY INSURANCE COMPANY OF MISSOURI 701 S. Country Club Drive
Jefferson City, Missouri 65102 
Defendant
SERVE:
Director or Deputy Director or Chief Clerk,
Division of Insurance, Jefferson City, Missouri
PETITION
COMES NOW Plaintiffs, McKell Young and Laurel Young, through their counsel,
Robert E. Harris, of Harris and Harris, L.L.C., and state the following for their cause of action
against Defendant, Farm Bureau Town and Country Insurance of Missouri:
1. Plaintiffs McKell Young alid Laurel Young, husband and wife (coliectively, the
"Youngs"), are and have been at all relevant times, residents of Warrensburg, Johnson County,
Missouri.
2. Defendant, Farm Bureau Town and Country Insurance Company of Missouri
("Farm Bureau") is an insurance company authorized to do business and issue insurance
contracts in the State of Missouri.
3. On or about August 26, 2004, for an agreed upon premium paid by the Youngs, Farm Bureau through its agent Johnson County Farm Bureau of Warrensburg, Johnson County, Missouri, issued to the Youngs a policy of insurance, PRO 025744901 ("Policy"), a copy of which is attached hereto as Exhibit A and incorporated herein by this reference, that insured the Youngs' home at 15 SE Higway Y, Johnson County, Missouri, their personal property, and provided for debris removal and the payment of additional living expenses.
4. In part, the Policy covered loss of the Youngs' home by fire and smoke, loss to their personal property within the home, the cost of debris removal, and additional living expenses. The Policy specifically provides for payment of the replacement cost with inflation of
the Youngs' home and persona! property.
5. The Policy valued the Youngs' home at $212,000.00 and their personal property contents at $159,000.00
6. On or about December 22, 2004, while the Policy was in full force and effect, the Youngs wholly lost from perils insured against by the Policy, their home on the insured premises generally described as 15 SE Highway Y, Johnson County, Missouri, 64093, together with items of personal property contained therein and as a result thereof have incurred costs of debris removal and additional living expenses, all of which was covered by the Policy.
7. At all time relevant herein, the Youngs had an insurable interest in their home at 15 SE highway Y, Warrensburg, Johnson County, Missouri, and the personal property contained therein.
8 The replacement cost of the Youngs' home is at least $212,000.00, and the replacement cost of the Youngs' personal property is $159,000.00. The Policy further provides for payment of the replacement cost of the Youngs' home up to $254,400.00 
9. As a result of the loss mentioned herein, the Youngs' home and personal property
were wholly lost.
10. The Youngs fully performed all conditions precedent under the Policy or the same were waived by Farm Bureau.
11. The Youngs notified Farm Bureau of said loss and requested full payment under
the Policy and Farm Bureau inspected the premises. The Youngs furnished to Farm Bureau all information it requested.
12. As a result of the loss, the Youngs sustained damage of$371,000.00, for which Farm Bureau is liable under the terms of the Policy. 13. Farm Bureau is further obligated under the Policy for payment of debris removal of the Youngs' home and for their family's additional living expenses while they are displaced from their home.
14. The Youngs demanded of Farm Bureau the sum of$371,000.00 - the value of their home (including debris removal) and their personal property.
15. Farm Bureau failed and refused to accept liability for the loss and pay the sums due and owing under the Policy, in breach of its obligations under said Policy.
16. For the reasons set forth herein, Farm Bureau owes the Youngs the amount of $371,000.00, with interest from the date payment was demanded, as provided by law.
17. At all times, Farm Bureau has failed and refused, and continues to fail and refuse, to pay those sums demanded under the policy.
18. Section 375.420, RSMo., provides for statutory damages and attorney fees if an insurance company fails to pay for a loss, "without reasonable cause or excuse". 
19. Farm Bureau's repeated failure and refusal to pay for theY oungs' loss, despite demand therefor as set forth herein, was and is without reasonable cause or excuse. Accordingly, Farm Bureau owes the Youngs the full amount demanded under the Policy, with statutory damages and reasonable attorneys fees under § 375.420, RSMo.
20. As a result of Farm Bureau's unreasonable and vexatious refusal to pay as obligated under the Policy, there is now due and owing pursuant to law and in addition to the amounts due under the Policy, statutory da.mages of $37,250.00 and reasonable attorneys' fees.
WHEREFORE, for the foregoing reasons, McKell Young and Laurel Young, pray for
damages in the amount of $371,000.00 under the Policy, plus interest as provided for by law, for
their reasonable attorneys' fees and for statutory damages in the amount of$37,250.00, and for
such other relief as the Court deems just and proper under the circumstances.
Robert E Harris  (No. 22096) 
Barry A. Gilbert  (No. 42402)
Harris and Harris, L.L.C.
206 North Holden Street Warrensburg, Missouri 64093 Tel.: (660) 747-8131 Fax: (660) 747-8149

ATTORNEY FOR PLAINTIFFS

June 16,2006

Cause No. 05CA-CV01686

IN THE CIRCUIT COURT OF CASS COUNTY, MISSOURI AT HARRISONVILLE   

MCKELL YOUNG and LAUREL YOUNG  Plaintiffs,
v.
FARM BUREAU TOWN & COUNTRY INSURANCE OF MISSOURI,
Defendant.
STIPULATION FOR DISMISSAL
COME NOW the parties, by and through undersigned counsel, and hereby stipulate that
the instant cause of action shall be dismissed with prejudice, each party to bear its own cost.
Robert L. Brady, #47522 BROWN & JAMES, P.C. 1010 Market Street, 20th Floor St. Louis, Missouri 63101 314421-3400
314421-3128 (Fax)
Attorney for Defendant