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The original document is part of the Missouri State Archives St Louis Circuit Court collection.
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
Before the Subscribing witness personally ap-
peared the
untarily
himself to
capacity of Clerk and
the Indian Trade in the missouri and its
commence at the date of that
to expire on arrival of said outfits boats
in
and thirty four on the following term and condi-
tions to say_ Said
said promises and
sum of five hundred dollars and a Suit of
Clothes
Said
obey,
or know wishes of his employers or any
person in charge of their business to the
of his knowledge and abilities, keep their
give them information of any thing which
may come to his knowledge affecting their in-
terest, take care of and protect their prop-
erty of whatsoever nature or kind it may be
and to do all such things as an usually
or ought to be done by a good and faithful
Clerk and Trader It is further agreed and
understood that the said Labour is not all-
owed to trade with whites, or
on his own account
Engagement
$ 500
Suit
paid in full.
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
plains of
upon the case upon promises: For that whereas hereto
fore to wit on the
our Lord one thousand eight hundred & thirty one
the County aforesaid, by a certain instrument in writing
(which the plaintiff cannot produce in court, because
the same is in the possession & power of the defendant)
in consideration that the said plaintiff at the special in-
stance
was
of the
said him as a clerk & trader the said defendant undertook & then &
there faithfully promised the said plaintiff to
pay him, yearly & every year during the said
term, the sum of five hundred dollars, and a
fine suit of clothes. And the said plaintiff
that in pursance of his said obligation, he did immedi
ately
defendant being then & now one of the said company)
and served the said company as a clerk &
one whole year then next following of which the
defendant had one notice, yet the defendant
requested so to do, has not paid to the plaintiff
the said sum of five hundered dollars and a fine
suit of clothes or either or any part thereof but
so to do has
& still does neglect & refuse.
And also for that whereas heretofore to wit
on the
eight hundred & thirty one
consideration that the said plaintiff had then & there, at
the special instance request of the defendant
a clerk & trader, in his commerce with the
term of three years the said defendant undertook &
then & there faithfully promised the said plaintiff to
pay him,
year he should serve as aforesaid, the sum of five
Hundred Dollars and also pay
of fine clothes. And the said plaintiff avers that, in
pursuance of his said enagagement, he did then & there
enter into the service of the said defendant, and did
serve him as a clerk & trader in his commerce with
the indians for one whole year, of which the defend
ant had notice; yet the said defendant although
often requested, has not paid to the plaintiff the
said sum of five hundred dollars or any part thereof,
nor paid
or any part thereof, but so to do has
neglated refused, & still does neglect
And also for that whereas heretofore to wit on
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
the
eight hundred & thirty one
in consideration that the plaintiff, at the special
instance & request of the defendant, had then & there
engaged
as a clerk
with the indians, for the term of three years, the said
defendant
=mised the plaintiff, to keep
in the service & employment of him the defendant,
as a clerk
with the indians, for the term of three year then
next following, and to pay him,
end of every year of said term the
hundred dollars and a suit of fine clothes. And
the said plaintiff
engagement,
of the defendant, last aforesaid, he did then & there
enter into the service of the said defendant, and served
him as a clerk
indians, for a long time, to wit one whole year, and
was then & there ready & willing,
to serve the said defendant during the whole term
of three years as aforesaid, as such clerk
yet the said defendant, not regarding his promise &
undertaking, did not nor would keep
said plaintiff in the service
the defendant, as a clerk
thereof, afterwards to wit on the
in the year of our Lord one thousand eight hundred
& thirty two
the plaintiff from the service
the defendant, as such clerk
keep
as aforesaid.
And also, for that whereas, heretofore to wit
on the
year of our Lord one thousand eight hundred &
thirty two
=tion that the said defendant was then & there
indebted to the said plaintiff in a large
money, to
before that time done & performed for the defendant
at his request, and for goods,
by the plaintiff before that time sold
to the defendant at his request, he the defendant,
undertook & then & there faithfully promised
the plaintiff to pay him the last mentioned
be
defendant, although often requested, has not
paid the same on
has hitherto wholly neglected refused,
does
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
Wherefore the plaintiff says he is injured &
has sustained damage to the value of three thousand
dollars, & therefore he
We command you to Summon
appear before the judge of our
at the
Monday of November next then and there to answer unto
of a plea of trespass upon the case upon promises wherefore the plaintiff
says he is
dollars and have you then there this writ
Executed this writ by offering to read it
and the declaration to
day of October 1832
to hear & acknowledge the
of the same
Damage $ 3000.
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
And the said Defendant
wrong and injury when & and says he did not
undertake and promise in manner and form as
the said plaintiff hath above thereof complained
against him and of this he puts himself
upon the country
And for further plea in this behalf the
said Defendant says that the said plaintiff
not to have and maintain his aforesaid action
against the said defendant because he says
that before and at the time of the commence-
ment of this suit the said plaintiff was
to this defendant and others
of this defendant in the said several supposed
promises and undertakings in the declaration
set forth in the sum of two thousand dollars for
-fendants and his said partners before that
sold and delivered to the said plaintiff at his spe-
-cial instance and request and also in the further
sum of two thousand dollars for so much money
by the said defendant and his said partners before
that time
out and expended for the said plaintiff at his said
special instance and request
money exceed the damage sustained by the said
plaintiff by reason of the non performance of the said supposed prom
ises and undertakings in the declaration mentioned
and of out of which said sums this defendant is willing
and offers to set off and allow to the said plaintiff the said
and this the said defendant is ready to verify wherefore
he prays judgement &
And the said plaintiff,as to the plea of the said defendant
by him first above pleaded and whereof he has put him
And as to the plea of said
above pleaded, the said plaintiff says that by any thing
in that plea alleged he ought not to be barred or
not indebted to the said defendant & others his
in manner & form as the said defendant has
above in said second plea alleged and this he
prays may he
wherefore he prays judgment &
Pleas
1 Non
2 Set off
continued at defendants
Verdict & judgt for $ 275 ---"--- 358
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
You are hereby commanded to summon
that setting aside all manner of excuse and delay,
before the Judge of our
the truth to say in a certain matter of controversy now pending in our said Court,
wherein
part of the
for
Executed this writ on
26th
St Louis County
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
You are hereby commanded to summon
that setting aside all manner of excuse and delay, he be and appear in proper person
before the judge of our
at the
the truth to say in a certain matter of controversy now pending in our said Court,
wherein
part of the
Served this writ on
on the
1834
for
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
You are herby commanded to summon
that setting aside all manner of excuse and delay, they be and appear in proper person
before the judge of our
the truth to say in a certain matter of controversy now pending in our said Court,
wherein
part of the
for
Executed this writ on
city of
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
You are herby commanded to summon
that setting aside all manner of excuse and delay, they be and appear in proper person
before the judge of our
the truth to say in a certain matter of controversy now pending in our said Court,
wherein
part of the
Served this writ on
April 1834
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
Take notice that on wednesday the
April
in
the
day the depositions of witnesses will be
to be
on the part
notice to take depositions.
Executed this notice by delivering a true copy
of it to
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
Depositions of witnesses produced
day of April eighteen hundred and thirty four
seven O'clock in the
at the Office of
depending in the
between
defendant on the part of the plaintiff.
examined on the part of the plaintiff
hundred and thirty two
in the common jail of St Louis County upon a charge of murder.
me to hand
was read to me by
defendant to
the same manner as if he
me the amount of
by me to Mr
read it
of accounts to make with
to pay
hired to him - He answered that
to him - I said that
years yet - he
Services -
Being
Question. When you came with the letter from
times thereafter to see me; as you have above Stated, were
me to pay me money?
Answer. I was authorized by Labour to settle his account
with you, and to pay to you either the
or part of a demand of Francis A
in your
Question. Although I constantly refused to pay any thing to
was taken to
a formal obligation to pay me four hundred dollars on
account of
Answer. No, I did not_ I told you that
after
of his
Question. After your
I should pay several debts of which you gave me a
and also
Answer. On my
not
me one thousand dollars for it, I would pay you two hundred
dollars on
I
was by me
in controversy aforesaid, that he was examined and
and by him subscribed in my presence on the day, between the hours and at the place in
that behalf first aforesaid.
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
Depos for Defendant
opened & filed
21st 1834
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
You are hereby commanded to summon
that setting aside all manner of excuse and delay,
before the Judge of our
the truth to say in a certain matter of controversy now pending in our said Court,
wherein
part of the
for
Executed this writ on
county
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
You are hereby commanded to summon
that setting aside all manner of excuse and delay,
person before the Judge of our
day of
testify and the truth to say in a certain matter of controversy now pending in
our said Court, wherein
plaintiff and
Jr is
the
for
Executed this writ by
Sarpey on the
delivering a true copy of it to a free
of the family of
15 years at his place of Residence in the
ty of
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
You are hereby commanded to summon
that setting aside all manner of excuse and delay, he be and appear in proper
person before the Judge of our
at the city of
testify and the truth to say in a certain matter of controversy now pending in
our said Court, wherein
plaintiff and
defendant on the part of
for Dft
Executed this writ by
in the city of
of April 1835
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
You are hereby commanded to summon
that setting aside all manner of excuse and delay,
before the Judge of our
the truth to say in a certain matter of controversy now pending in our said Court,
wherein
part of the
for
Executed this writ on
the
him in the county of
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
Plaintiff Two