Joseph by his attorney complains of Auguste , Chouteau , administrator of all and singular the goods and chattels, rights and credits, which were of St Paul Lacroix, deceased, who died interstate, of a plea of trespass, on the case for that, whereas the said St Paul Lacroix, his life time to wit, on the fifteenth day of August the year of our Lord one thousand eight hundred and four-teen at the county of Saint Charles , court at the county of Saint Louis aforesaid and within the juris- diction of this court was indebted to the said Joseph in the sum of three hundred and seven dollars and fifty cents lawful money of the United States for divers, goods, wares, , oil and tallow, before that sold and delivered to the said St Paul at his special instance and request and being so indebted be the said, St Paul undertook and then and there faithfully promised to the said Joseph to pay him the said sum of money when he should be thereto afterwards requested.

And whereas afterwards, to wit on the day and year aforesaid at the place aforesaid in consider-ation that the said Joseph at the like special, instance and request of the said St Paul had before that time sold, and delivered to the said St Paul divers other goods wares merchandise furs oil, and tallow, he the said St Paul undertook and then and there faithfully promised the said Joseph to pay him so much money therefore as the said last mentioned goods wares merchandise

And for Replication to the defendants second, plea in the behalf above pleaded the said plaintiff say that for anything alleged in said plea he ought not to be and precluded, because he says that the said St Paul did not in manner, and form as the said defendant has alleged in said plea pay the plaintiff his demand as stated, in his declaration and this he prays may be enquired, of by the country

And the said plaintiff for Replication to the third plea of the said defendant this behalf above pleaded say that for anything alledged in said plea he ought, not to be barred or precluded, from having his, said thereof against said defendant because he says that the said defendant did not in manner & form, as he has alleged in his said plea pay to said plaintiff the demand in the declaration mentioned and this he prays may be enquired of by, the country

And, for the plea in this behalf the said defendant the charge of the plea injury where he had saith, then the plaintiff of having maintaining, his said against him ought to be barred, and precluded, because he says that the said Saint Paul Lacroix in, his life time, to wit at the county aforesaid in day of Auguste in the year, of one thousand eight hundred and this defendant and pay and satisfy to the said plaintiff the sums of money, said , and this he is ready to verify, , whereas he prays judgment his .

for further plea in this behalf the said defendant further defends the charge of the plea of injury when the and saith, that the plaintiff of having and maintaining, in said action thereof against him ought to be barred, and precluded, because he says that he said the of the said Saint Paul Lacroix, . To wit, at the county aforesaid on the of in the year thousand eight hundred and , this defendant did and truly pay and satisfy to the said

Personally came before in a justice of the peace for the township of St Charles in the county and territory aforesaid Amable Que, - nelle, and Joseph Grezas, and being duly sworn, say that they know of the delivery of there first item of the within account but know not that any prices were agreed, on; and Amable Quenelle, says he knows that the last item was paid to col. Auguste Chouteau ,

his sworn to and subscribed, before me a justice of the peace for the charles the day and

The above is a true translation of the evidence recording to the best of my skill,

Sworn, to before me a justice, of the peace

The Estate of St Paul Lacroix, $ pts To Joseph Quenelle , 1814 25th Beaver $ 2 1/2, per pound...... 62 50 Do.. 125 gallons bears, oil at $ 1 per Gallon 187 50 Do.. 110 Suet or Deers, Tallocs at 25 cts, 27 50 Do.. Remittances to Aug Chouteau, in cash.. 64 .. Total $ 341 50 Do 1814 to 30 Bear Skins . . . . 30 .. $ 371 50

You are hereby commanded to summon Francois Frenault , Reynold that setting aside all manner of excuse and delay they be and appear in proper person before the judge of our circuit court on the seventh day of May next at the town of St. Louis , then there to testify and the truth to say in a certain matter of controversy now pending in our said court, wherein Joseph Quennel , is plaintiff and August Chouteau , administrator of St Paul Lacroix defendant, on the part of the defendant and have you then there this writ.