Territory of Missouri
County of St Louis In the Circuit Court
October Term 1817

Joseph Beaudoin complains
of John Cabanne, and Antoine Chenie
late merchants and traders trading and
doing business under the name title
and firm of Cabanne and Chenie,
of a plea of trespass on the case
for that whereas on the twenty fifth day
of august in the year of our lord one
thousand eight hundred and fifteen
at the town of St Louis in the county
of St Louis aforesaid and within the Juris-
dition of this court, in consideration
that the said plaintiff at the special
instance and request of them said Defen-
dants would enter their service in the
capacity of their clerk and go into the
Missouri river and its dependencies, on
a trading voyage and expedition of
them said defendants, there on foot, and
to continue and last from that time
untill the month of June there next
following at which last said time it was
to expire and and for and during
that voyage and trading expedition
take due care of sell trade and
such goods and
as he to his case
to the best advantage and benefit, of them
said Defendants, and obey this lawfull
commands and and attend to there
interests, they said Defendants undertook
and faithfully promised to the said
plaintiff to pay him the sum of three
hundred Dollars in June next follow-
ing to wit at the town and county aforesaid

and within the jurisdiction aforesaid and
the said plaintiff avows that confiding in
the said promise and undertaking of them
said Defendants did immediately thereafter
enter the service of the said defendants in the
capacity of their Clerk and did go into the
Missouri river and its dependencies, in their
imploy for and during the said expidition,
and voyage and untill the expiration,
ending thereof in June following did continue
in their employ as aforesaid and did for
and during that time take due care of bill
dispose and barter, to the best advantage
and benefit of the said defendants such
goods and Merchandizes, as were committed
and entrusted to him for that purpose
and did obey the lawfull commands
and did and attend to the interests of
the said defendants as aforesaid yet the
said defendants not regarding their said
promise and undertaking atthough often
requested so to do have not paid
to him the said plaintiff the said sum
of money or any part thereof but have
wholly neglected and refused, and still
do wholly neglect and refuse do to do so
the damage of the said plaintiff of
five hundred dollars wherefore he sues
and whereas the said defendants on the
first day of august in the year of our lord
one thousand eight hundred and sixteen
at the town county and within the Juris-
diction aforesaid were indebted to the
said plaintiffs in the further sum of three hundred
Dollars lawfull money of the united states

for the work and labour care and dilligence
of the said plaintiff by him before that
time done performed, and bestowed as the
Clerk and agent of the said Defendants
in and about the selling and disposing
of divers, other goods wares and merchandizes,
of the said Defendants, and in and about
the other business of the said defendants
at their special instance and request and
being so indebted they said Defendants
in consideration thereof afterwards to wit
on the day and year last aforesaid
at the place and within the jurisdiction
last aforesaid undertook and faithfully
promised to the said plaintiff to pay him
the said last mentioned sum of money
when they when they the, said defendants should be
thereunto afterwards requested- and whereas
afterwards to wit on the day and year at the
place and within jurisdiction last aforesaid
in consideration that the said plaintiff
at the like, special instance and request of
of the said defendants had before that time
done performed and bestowed his work and labour,
care and dilligence as the clerk and agent
of the said defendants, in and about selling
and disposing of divers other goods wares, and
merchandizes of them said defendants and in
and, about the other business of the said defendants
and for the said defendants at their special
instance and request, they said defendanst
undertook and then and there faithfully promised
the said plaintiff to pay him so money
as he therefore reasonably deserved to have
where they said defendants should be thereunto
afterwards requested and the said plaintiff avows
that he therefore reasonably deserved to have
of the said defendants the further sum of
three hundred dollars of like lawfull money

to wit at the place and within the jurisdiction aforesaid
whereof the said defendants afterwards to wit on
the day and year last aforesaid there had notice
yet the said defendants although often requested
have not paid the said sum of money on
any of there to said plaintiff untto pay the
same or any of them to him, have hitertoto ever
and yet do refuse, wherefore the said plaintiff
saith he is injured and hath sustained damage
to the value of five hundred Dollars
wherefore he does &c.

Cha Lucas
Atto. for Plff

No. 70- St Louis County
Circuit Court
October Term 1817

Joseph Beaudoin
vs
John C Cabbanne
Antoine Chenie
Declaration in

> Damage $ 5 00-

This is an action of
Issue a
summons, in a plea
of Tresspass on the
case Damage $ 500

Cha Lucas
Atto. P . Q.M. P. Leduc Esq
Clerk &c.filed sept 13th 1817
(sep 18) A. S. M. Girk

Executed this writ within named
Defendants - acknowledging the service
of the
same and informing them of
the contents - in the Town & County
of Saint Louis . september 13th 1817

A. V. Carr Dshff
for JW Thompson Shff 2 service $ 1.20

And the said Antoine Chenie & John P . Caban-
ne the defendants by their attorney come & defend the wrong
& injury when &c. and say that the afterward Joseph Beau-
doin the plaintiff is dead and was dead al & before the
bringing of this suit had, at the county of St Louis afore
said & within the jurisdiction, of this court and this
they are ready to verify - wherefore the said Antoine
& John P. the defendants pray judgment of the said
plaintiffs writ and that the same may be quashed &
abated &c.

Carr , atty

In. C. Cabanne being duly sworn saith that
he is one of the defendants need in this case and
that the plea herein above pleaded is true in
substance & fact

Cabenn HSworn to and subscribed
this 18th october 1817A. P. Mc. Girk DClk for
M. P. Ledue Clk

Chenie & Cabanne
ads
Joseph Beaudoin
plea

filed october 18th
1817.M P. Leduc Clk
By A. P. Mc. Girk Carr Atty

Territory of Missouri
County of St Louis
SsThe united
of America to the
Sheriff of said County ... Greeting

We command you to summon John
P Cabbanne and Antoine Chenie take
merchants and Traders trading and doing
business under the name style and firm
of Cabbanne & Chenie that they be and
appear before our Circuit Court to be held
at the Town of St Louis within and for
the county of St Louis before our Judge
thereof on the second monday of october
next then there to answer unto Joseph
Beaudoin of a plea of trespass on the
case to the damage of the said Joseph
five hundred dollars and have you then,
there this writ

Witness Mc Psedue Clerk M P Leduc ,
said court at St Louis this thirteenth day of september in
the year eighteen hundred
and seventeen and of
an Independence the forty
second Anowf. Mc. Girk Dbft
M. P. Ledue Clerk