In the Circuit Court
October Term 1817

Saint Louis County to wit, Hugh Richard by his
attorney complains of Benjamin O Fallen of a
plea of trespass on the case upon promises,
To no the said Benjamin O Fallen
heretofore towit, on the first day of august
in the year of our Lord one thousand eight
hundred and sixteen at the County aforesaid,
in consideration that the said Hugh Richard at
the special instance and request of him the said
Benjamin O Fallen would engage himself to
and go along with the said Benjamin O Fallen
in the capacity of clerk on a certain trading
voyage which the said Benjamin , then starting
on up the river Mississippi , and its tributary,
streams and that the said Hugh during the
said voyage would perform the duties of a
clerk to and under, the said Benjamin ,
to the said Benjanium O Fallen undertook
and faithfully promised the said Hugh
Richards to allow and pay the said Hugh
for his service in the aforesaid capacity during the
said voyage at the rate and proportion of
four hundred dollars a year And
the said Hugh Richard in fact saith that
confiding, in the aforesaid promise and
undertaking of the said Benjamin , he
did engage himself to and go along with

the said Benjamin O. Fallen in the capacity of
clerk on the said trading voyage which the said
Benjamin was then starting on up the river,
Mississippi , and its tributary streams to wit all
the aforesaid and the said Hugh that
he did during the said voyage perform the duties
of clerk to and under the said Benjamin O
Fallen and the said Hugh further in fact saith
that he was in the service of the said Benjamin ,
on the said voyage for a long time towit for
ten months Nevertheless, the said Benjamin
O Fallen not regarding his aforesaid promise and
undertaking did not and has not allowed and
payed the said Hugh Richard for his services in
the capacity aforesaid during the time that the said
Hugh was in the service of the said Benjamin
as aforesaid at the rate and proportion of four
hundred dollars a year nor hath the said Benjamin ,
as yet paid the said Hugh any thing
for his aforesaid services Bat so to do the often
requested hath hitherto, wholly refused and
still doth refuse

And for that whereas also the said
Benjamin O Fallen afterward towit on the
day an d year aforesaid at the county afore
said in consideration that the said Hugh Richard
at the like special instance and request of the
said Benjamin would go along with and
serve him the said Benjamin in the capacity
of clerk on certain trading voyage up the
river Mississippi , and its tributary, streams he
the said Benjamin O Fallen undertook and then
and there faithfully promised the said Hugh

to allow and pay him for the time that he should
serve him the said Benjamin as last aforesaid at
the rate and proportion of four hundred dollars
a year and the said Hugh Richards in fact
saith that confiding in the said last mentioned, promise
and undertaking of him the said Benjanium he
did go a long with and serve the said Benjamin
O Fallon in the capacity of clerk on certain
trading voyages up the river Mississippi and its
tributary streams for a long time towit for
nine months towit at the county aforesaid the said Benjamin ,
O , Fallon not regarding his said last men
tioned promise and undertaking would not and
did not allow and pay to the said Hugh Richards
for the time he was, in the service of the said Benjamin ,
as last aforesaid at the rate and propostion
of four hundred dollars a year nor hath
the said Benjamin as yet paid the said Hugh
any thing, therefor But so to do although
often requested hath hitherto wholly refused
and still doth refuse

And for that whereas also the said Benjamin ,
O Fallen afterwards towit on the day
and year last aforesaid at the county aforesaid
in consideration that the said Hugh Richard
at the like special instance and request of
the said Benjanium would serve the said Benjamin ,
O Fallen in the capacity of clerk during
and until the completion of a certain trading
voyage which the said Benjamin was then
about making up the river Mississippi , and

its tributary, streams he the said Benjamin O Fallon
undertook and then and there faithfully promised
that said Hugh to pay him therefor four hundred
dollars And the said Hugh Richard in fact
saith that confiding in the said last mentioned
promise and undertaking of the said Benjamin
he did serve the said Benjamin in the capacity,
of clerk during and until the completion of the said
last mentioned voyage towit at the county aforesaid Nevertheless, the said
Benjamin O Fallen not regarding his said last
promise and undertaking hath not as yet
paid the said Hugh the said sum of four
hundred dollars or any past thereof But the
same to pay hath hitherto, wholly refused and
still doth refuse

And for that whereas also afterward towit
on the first day of august in the year of our
Lord one thousand eight hundred and seven
teen at the county aforesaid the said Benja
min O Fallon was, indebted to the said Hugh
Richard in the sum of other four hundred dollars
for the work and labor care and diligence, of
the said Hugh before that time done and promised,
to and for the said Benjamin and
at his like special instance and request, and
being so indebted he the said Benjamin ,
in consideration, thereof afterward towit on
the day and year last aforesaid at the
county aforesaid undertook and faithfully

promised the said Hugh to pay him the said
last mentioned sum of money when he the
said Benjamin should be thereto afterwards
requested Nevertheless, the said Benjamin
O Fallen not regarding his last mentioned promise
and undertaking hath not as yet paid the
said Hugh Richards the said last mentioned
sum of money or any part thereof but the
same to pay hath hitherto, wholly neglected
and refused and still doth neglect
and refuse to the damage of the
said Hugh Richard four hundred dollars
and therefore he brings his and suit,

J Barton atty

This summons was excuted on the 12th day of Augt
1817 by reading to Benjamin O Fallon in the
Town of S Louis

John W. Thompson
80

No 42
St Louis C Court
October Term 1817

This is an action of
Damage
$ 400 let a

atty Filed August 11th
1817.
girk
for M.P.LedueClk
(Augt 11)

Territory of Missouri
County of St Louis
ssThe United States of America ,
to the sheriff of said County
greeting

we command you to summon Benjamin ,
O Fallon if he may be found, within your
bailiwick, that he be and appear before
the judge of our Circuit Court to be held
at the Court house in the Town of St Louis
within and for the county of St Louis on the
second monday of October next then, there to any
unto Hugh Richard of a plea of trespass,
the upon promises, to the damages of the said
hundred Dollars, and have you then

Witness M. P. Leduc , clerk of and said
court at the town of St Louis this
eleventh day of August eighteen
hundred and seventeen
A.M.Girk D Clk for
Clerk

Territory Of Missouri , County Of St. Louis , sct.The United States of America , to the Sheriff of said County,
Greeting.

You are hereby commanded to summon Theodore Haut,
that setting aside all manner of execuse and delay he be and appear in proper
person before the Judge of our Circuit court on the 14th day of February
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 Hugh Richards ,
is plaintiff, and Benjamin O Fallen , defendant, on the
part of the plaintiff and have you then there this writ.

Witness, Mary P.Leduc, Clerk of our said circuit court, at the town of
St. Louis , this 12 th day of December in the year of our
Lord, one thousand eight hundred and 17 and of the Inde
pendence of the United States , the 42ndM. P Leduc ,Clerk, St. L .C.C. By

75251820

174148

Executed

333380331.79

J.W. Thompson

St Louis
February of 1818

St Louis County
for
Theodore Haut,
February 14th 1818

y J Barton , atty plff

Territory Of Missouri , County Of St. Louis , sct.The United States of America , to the Sheriff of said County,
Greeting.

You are hereby commanded to summon Thomas Handly,
that setting aside all manner of excuse and delay he be and appear in proper
person before the judge of our Circuit court on the 18th day of Febry
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 Hugh Richards ,
is plaintiff, and Benj O Fallon , defendant, on the
part of the Defendant and have you then there this writ.

Witness, Mary P.Leduc, Clerk of our said circuit court, at the town of
St. Louis , this 18th day of Febry in the year of
our Lord, one thousand eight hundred and 18 and of the
Independence of the United States , the M. P. Leduc ,Clerk, St. L .C.C. By

sub

Tho Handly

Executed

ser 33

Territory Of Missouri , County Of St. Louis , sct.The United States of America , to the Sheriff of said County,
Greeting.

You are hereby commanded to summon Lilburn, W Boggs,
that setting aside all manner of excuse and delay he be and appear in proper
person before the judge of our Circuit court on the 18th day of Febry
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 Hugh Richards ,
is plaintiff, and Benj . O Fallon , defendant, on the
part of the Defdt and have you then there this writ.

Witness, Mary P.Leduc, Clerk of our said circuit court, at the town of
St. Louis , this 18 th day of Febry in the year of our
Lord, one thousand eight hundred and 18 and of the Inde
pendence of the United States , the 42 M. P. Leduc ,Clerk, St. L .C.C.
By

Executed

Ser 33

sub

L.W.Boggs