northern circuitterritory of missouriThe United States of America Louis Tayon Maurice Bondeau and Bazile Proulx their counselors attornies solicitors or agents. Greetings

Whereas it has been represented to our judges of our Superior Court of our Territory of Missouri in and for the northern
Circuit sitting as a court of Chancery, on the part of Michel Lacroix complainant that he hath lateley exhibited
his bill of complaint into our said court sitting as a court of chancery, against you the Said Louis Tayon, Maurice Blondeau and Bazil Proulx defendants to be relieved touching the matters therein contained, namely that sometime in the year eighteen hundred and fifteen he equipped and furnished to you the said Bazile Proulx
an assortment of merchandise suitable for the Indian Trade, and was to receive payment therefore out of the process of sales. That you afterwards sold the said goods to Maurice Blondeau whose note you
took therefore amounting to the sum of twelve thousandtwo hundred and forty three livres ten sols
payable in the spring following - that the said Proulx before the said note became due placed
the same into the hands of the said Louis Tayon for the mere purpose of collection and where the representation of to said Tayon to said Proulx , in order to enable him to collect the same that it was necessary that his name should
be endorsed on the back thereof which was accordingly done that a regular endorsement was afterwards
written by said Tayon or someone for him over the name of the said Proulx - That a suit was brought on said
note against the said Maurice Blondeau in the circuit court of the county of St. Louis and a judgment thereonobtained against him for the sum of one thousand seven hundred and twenty dollars and twenty cents besides the costs of the suit - that the said Louis Tayon never paid said Proulx one cent thereof nor therefore and that he the said complainant is justly and equitably entitled to more than the whole amount of the
same that both said Proulx and said Tayon are poor the latter of whom never had nor has he now property or means sufficient to purchase either a note or any other article of property and that unless he can join on the payment of the judgment aforesaid in the hands of Blondeau he knows of no property or means of getting the same either from Proulx or Tayon who well knowing the advantages he has at law against
your orator is proceeding to collect the same by execution against said Blondeau or his bail. Therefore
it was prayed that the conplainant might have an injunction to stay the proceedings at law until the hearing of this case. Then therefore in consideration of the previous aforesaid do strictly enjoin and commanded you
the said Louis Tayon and all and every the previous before mentioned that you absolutely desist from proceedings at law in the premises you the said Louis Tayon in taking out execution against the
said Maurice Blondeau for the amount of the said judgment, You the said Maurice in paying the henceover and you the said Bazile in receiving the same or any part or parcel of the same until the hearing after cause

by our said Superior Court sitting as a court of chancery as aforesaid

Witness the Honorable Alexander Stuart Esquire presiding Judge of our said court at St. Louis this fourteenth day of June until year of our Lord one thousand eight
hundred and seventeen and of our independence the fourty first J. V. Garnier atty S. C. N. C.

This writ was executed by reading to Louis Tayon
and Maurice Blondeau in the Town and Count
of St Louis and territory of Missouri June 14, 1917 Bazil Proulx not found in St . Louis county

J W Thompson

2 serves$ 1.201 non Ext.50$ 1.70

No 3
In Chancery
September term 1817

Injunction

Sir

Take notice that on friday next the 13th of this
month between the hours of ten in the morning and five
O Clock in the afternoon of that day of shall apply to the
honorable Silas Bent at his house near the town of
St Louis for an injunction to stay all proceedings at
law in a certain suit wherein you attained judge-
ment against Maurice Blondeau on a note
purporting to be have been endorsed by Bazile
Proulx to you

Michel Lacroix10th june 1817Louis Tayon

County of St louisss

Auguste Dardenne being duly
sworn on his oath saith that he did on the twelfth instant personally serve Louis Tayon with a copy
of the within notice by leaving the same with
the said Louis Tayon in the church street near
the church ground

Auguste Dardenne

Sworn to & subscribed this19th day June 1817before me

J V Garnier JP

To the honorable the judges of the superior court for
the territory of Missouri in chancery sitting for the
northern circuit in said territory

humbly complaining showeth unto your honors young orator Michel Lacroix of the town of St. Louis that some time in the year eighteen hundred & fifteen he equipped
or furnished to one certain Bazile Proulx an assortment
of merchandise suitable for the Indian trade and
was to receive payment therefore out of the proceeds
of the sales - the said Proulx sold the said good to one
Maurice Blondeau & took his note therefore amounting
to the sum of twelve thousand two hundred and forty three livres ten sols payable in the spring following
as will be seen by a copy of said note hereonto an-
nexed & prayed to be made and taken as part and parcel of this bill - before this note became due, Proulx
for the mere purposes of collection placed the same with the said Bazille Proulx and Maurice Blondeau in the hands of one Louis Tayon who your orator Prays may be made defendants to this his Bill of
complaint - Tayon told Proulx as your orator is
informed & expects to prove that in order to enable him to collect the note it would be necessary for his
name to be endorsed on the Back thereof. This
was accordingly done by said Proulx as your orator
is informed and believes it to be true - and the said Louis
Tayon afterwards wroteor caused to be written over
said Proulx's name a regular endorsement as is stated and written on the back of said note and the copy thereof here - with exhibited- On this note said was brought by
Tayon in the circuit court for the county of St Louis and
Judgement thereon obtainedat the November termEighteen hundred & sixteen of said court against said
Blondeau for the sum of - one thousand seven hundred
and twenty six dollars and twenty cents besides the costs of
said said amounting to thirty five dollars, eighty cents

In this said your orator & one Patrick Lee entered as the bail of Blondeau and are now liable to be
proceeded against as such by said Tayon Your
orator was ordered to become Blondeau's bail for a very obvious reason which was that the amount then due from Blondeau to said Proulx was justly coming to him as the equipper of said Proulx and therefore the said aforesaid at common law was defended
by him in said Blondeau's name But the name -
of said Proulx having in fact as your orator has before
stated been endorsed on said note though without any
valuable consideration therefore no defense at law could be made sufficient to avoid Judgement nor was your orator permitted to show under what circumstances the said note
was assigned - your orator
however charges that the fact to be that the said note was
endorsed to said Tayon merely to collect and not to transfer the property therein to him and that he never
paid said Proulx one cent thereof nor therefore and
that your orator is justly and equitably
entitled to more than the remanding their due to wit about sixteen hundred dollars whole amount thereof that both Proulx and
Tayon as a poor - the latter of whom your orator is very able to prove to your honours never had nor
has he now property or means sufficient to purchase either a note or any other article of property of the
value of the saidnote - and that unless your orator
can enjoin the payment of this judgment in the
hands of Blondeau he knows of no property or means

of getting paid either by Proulx or Tayon that the said
Tayon will knowing he never paid one cent to Proulx
for said note and that the assignment there of was only
intended to enable him (as he himself stated and
persuaded said Proulx to believe) to collect the debt &
not to transfer the property therein to him and will
knowing moreover the advantage he has over your orator
at common law by said endorsement in
order to displace your orator out of the amount
due on said note; is proceeding to collect the same
by execution against said Blondeau & if not
from him then from your orator & said Lee as
his bail

But now so it is may it please your honors the said
Louis Tayon and confederating to and with them the said Proulx & Blondeau & with divers
other persons at present unknown to whose names
where discovered your orator prays may be inserted in
this his bill of complaint with apt words to charge them
the order to defraud & cheat your orator out of the amount
remaining due as aforesaid on said note amounting
as aforesaid to the sum of about sixteen hundred
dollars currency of the United States , pretends that
he is entitled to the whole amount of said balance he well knows that he paid nothing for said
note - that it was endorsed by said Proulx in
blank that is merely with his name or signature
on the back thereof, merely to enable him the more
certainty to collect the amount thereof and not to
transfer the property therein to him, and altho he
well knew that the aforesaid amount then
due on said note was due andowing to your orator as the equipper of said Proulx at and
before the time of said endorsement yet of his own accord
if he did not purchase said note in fact & intruth & on that can in collusionwith said Proulx is endeavoring to cheat & defraud your orator of the same
your oratorfurthermore states that the said note has been
repeatedly demanded of said Tayon both by your orator
and the said Proulx as has been stated to your orator by this last also that he should desist from
the collection thereof. To which he replies that if your
orator will give him five or six hundred dollars out
of the aforesaid ballance of said note he will give it up
Being fully aware that your orator would be able in this
honorable court where the merits of this transaction can be
fully searched into, thoroughly to develope and expose to the
scorn & contempt of the publick this most wicked and
nefarious fraud the said Louis Tayon has also through
different persons and at different times, proposed a
compromise to your orator and offered to relinquish
his claim to the contents of said note of your orator
would pay him a certain sum of money less than
half the amount of said balance for which he has
obtained judgement. In the fullness of his hopes
that the laws of this country would afford him an
opportunity of showing the justice of his claim
to the which amount of said judgement, your orator
has uniformly spurned with indignation
at all their offers of a compromise for a part thereof. All which actings &
doings of the said Louis Tayon & the confederates are fraudulent oppresive & unjust

In under consideration whereof and
for as much as your orator is perfectly remedyless
at Common law and cannot have a discovery from
said Tayon & the said Proulx themselves on their oaths whether the said Tayon did
really in truth purchase said note of Proulx &
of so how much he paid for or whether the same
was not left in his hands & opposition merely for
collection & endorsed by said Proulx in blank for

that porpose only to the end therefore that the said
and the said Louis
Tayon & his conferates when discovered and the said Maurice Blondeau & Proulx may trueful distinct and the perfect answerrespectively make to all and
singular the matters & things herein and hereby charged &
that in as full and ample a manner as if the same
were here again particularly repeated & interrogated;
and
that the said Louis Tayon in particular and the other defendants may set
forth discover and say whether the copy of the note
hereunto annexed is correct. If it is not that the vari-
ancce may be shown. If it is correct whether the origin-
al was endorsed by Bazille Proulx the payee and
left with him said Tayon for collection. If not left with him to
collect merely for said Proulx or your orator did
he purchase it. If so how much he paid for it whether
any person and who was present when he bought it or
paid In what did he pay for it? whether he
did not know before and at the time the note was
and endorsed that the balance then remaining due on
it and more was coming to your orater from said Proulx
for the said merchandise for which the note was
given did not said Proulx tell him so? in what manner was the endorsement
made - who was present at the time. Who wrote
the endorsement over the name of Proulx - whether
he did not tell Proulx that his name was necessary
to be endorsed on the back of said note inorderto
enable him to collect it for her said Proulx's and
was the endorsement made on to when of was
first to him said Tayon & if not how long after
wards was it till the endorsement was made
whether their he did not know at and before the endorsement that your orator was the equipper of said
Proulx & that he owed him for said goods - Whether
it is not usual customary in this country for Indian tradersTraders to be equipped or furnished with merchandise
on credit to trade with the indians on their promise
to pay the equipper out of the first proceeds of the
trade - whether in fact it was not the custom and
usage inferred in this country under the spanish
government to give the equipper a lien on the goods
sold to the trader and the privilege of being first
paid in preference of every other creditor that they may state whether such proceedings were
not had on said note in court as is stated above
and whether your orator and said Lee and not bail
in said suit - whether the said Tayon has not obtained judge-
ment therein & for how much - whether he is not
now proceeding by execution at law against said
Blondeau for the recovery of said judgement &
if not obtained by execution against him whether
he does not mean to pursue your orator as
his bail first how much said Proulx owed your orator at that
endorsement & now owes him - whatever circumstances as
property your orator therefore prays your honours that
an injunction may be granted him in the aforesaid
suit commanding & enjoining him the said Louis Tayon
from proceeding at law against the aforesaid
Maurice Blondeau for the amount of said judge-
ment until the final hearing in this cause and
that on such final hearing the said writ of in-
juction may be decreed to be perpetual and that
the said Blondeau be authorized and decreed to
pay the amount of said judgement to your orator
and generally that your orator may have such
other & further relief in the principles as the nature
of his case may require & your honors may
thereof meet and proper to grant and your

orator will ever pray

Carr atty for complainant

Michel Lacroix the above named Complainant
being duly sworn on his oath saith that the matters
& things contained & stated in the above & foregoingbill
are true so far as they are stated from his knowledge
& so far as they are stated from the knowledge
of others he verily believes them to be true

Michel Lacroix

Sworn to & subscribed before me one of the Judges of the superior court for said territory this 13th of June 1817

Silas Bent

Copy

Temoie Soufique Maurice Blondeau en presen
de Temoint soufique Recconoit devoir et
Promet payer au sieur Bazil Proulx la Somme
de Douze mille deux cent guarantee trois livre in
solls pour valeur recue in marchandises payable
dans le courant du moil de mars mille seize

Riviere des grande os Riviere Maria le 12 Dec 1815
Maurice Blondeau
Temoint
la
Batiste Roy
mark
John B . Gated
(on the back is written)

Billet de Maurice Bloudeau

livre

12243-10

avoir par tout compte product
deux cent treute six
livres dex sols

2236-1

10 007 -00

La presente obligation , Louis Tayon cautte
laws dessain cest
1816Bllle Proulx

Territory of Missouri
County of St Louis

M. P. Leduc Clerk of the circuit
within and for the countyaforesaid certify the foregoing to be a true
of copy of a note and file in my office Drawn by Maurice Blondeau in favor of Bazile Proulx

In The witness whereof I have here unto aforesaid aforesaid
the end of the office of the clerk of the county
aforesaid this day of June in the year
one thousand eight hundred and seventeenM .P . Leduc Clerk McGirk , Dep Clerk

57 no2In ChancerySeptember term 1817

Bill

No57

filed June 11th 1817

J. V. Garnier atty (Discontinned)

To the clerk of the superior court for the territory of Missouri

You are hereby directed to issue a writ of injunction
against Louis Tayon & Maurice Blon-
deau
their agents & attornies for the amount
of the judgement specified in the Bill
take Bond agreeably to Law in double the
amount of the judgment at law being the
sum prayed to be enjoined, Antoine Soulard , Manuel (Lisa) or Jean P. Cabanne are either of them approved
if as securely to the bond-the Bill being
one filed by Michel Lacroix against
said Tayon, Maurice Blondeau and
Bazile Proulx & filed in your office 12 June 1817

Silas Bent

Territory of Missouri
Northern Circuit
The United States of America to Louis Tayon and Bazile Proulx Greeting

We command you that all excuses and delays being set aside, you and each of you personally be and appear
before the judges of our superior court of our territory of Missouri , at our said superior court sitting a court of chancery
and to be held in for the northern circuit of the said territory at the town of St Louis , on the third monday
in September next, then and there in our said court before our judges of our said court to answer the Bill of
complaint of Michel Lacroix exhibited against you and of this you are not to fail at your peril and
our Sheriff of our county of St Charles , is hereby commanded and required then and there to make return of this
our writ, and certify to our said court before our judges how he executed the service

Witness The Honorable Silas Bent Esquire presiding judge of our said court at
St. Louis thisfourteenth day of June in the year of our Lordone thousand and eight hundred
and seventeen and of our Independence the forty first J. V. Garnier , J P S C N C

Executed on Bazile Proulx in the town and township of
Saint Charles on the seventh day of July 1817,and on Louis
Tayon on the twentysecond day of July1817 in the aforesaid
town and township of Saint Charles

Wm. Devore, Shff

Executed St. Charles
In ChancerySeptember term 1817

subpoena

Sheriff feesServices $1.20

In the Superior sitting as a Court of chancery; In the northern Circuit of the term of August 1817
The Demurrer of Louis Tayon one of the defendants
to the Bill of complaint of Michel Lacroix

Louis Tayon , Baxil Proulx and Maurice Blondeau, Defendants Michel Lacroix - Complainant,

Louis Tayon one of the defendents in this
case by protestation not confessing or acknowledging
all or any of the matters or things in and by the
said Bill set forth and complained of to be true
in manner and form as the same are therein and
thereby set forth are alleged saith he is advised
by his counsel that there is no matter or thing
in law
to to call this defendant in question in this
honorable court for the same and that there
is good cause of demurrer thereunto and therefore
this defendant doth demur thereunto and for cause of demurrer this defendant saith that
the complainants said Bill in case the allegations therein contained were true which this defendant doth in no admit contains not any matter
of equity whereon this court can ground any matter of equity whereon the court can ground any decree or
give the complainant any relief or assistance as against him this defendant wherefore and for devious other error and imperfectionsIn the said Bill appearing this defendant doth demur in said thereunto and humbly demand the
judgment of this honorable court whether he
shall be compelled to to put in any other or further answer to the said bill and humbly prays
to be hence dismissed with his reasonable costs in this behalf most wrongfully sustained

M McGirk Solicitor
and counselor for defendant

demurrer to
bill for injunction to stay proceedings at law1827

Michel Lacroix filed August 25th 1817 J. V. Garnier atty S. C. N. C.

Territory of Missouri to Northerncircuit

The United States of America
to LouisTayon, Maurice Blondeau and Bazile Proulx Greeting-
We command you that all excused and delays being set aside you and each of you personally be and appear before the judges of our superior court of our Territory of Missouri at our said superior court sitting as a court of chancery in and for the northern circuit at the Town of St. Louis on the thirdMondayin Septmebernextthen and there in our said court
before our judges of our saidcourt to answer the Bill of complaint of Michel Lacroix then and there against them and of this you are not to fail at your peril and our sheriff of our county of St. Louis is hereby - commanded then and there to make return of this our writ and certify to our said court before our judges how
he executes this writ.

Witness The Honorable Alexander Stuart Esquire presiding judge of our said court at St. Louis thisfourteenth day of June in the year of our Lord one Thousand-eight hundred and seventeenth and of our Independence the forty first. J. V. Garnier S. C. N. C.

In ChancerySeptember Term 1817

subpoena

Carr for complainant

This summons was executed by Reading to Louis
Tayon and Maurice Blondeau on the 14th day
of June 1817 in the Town of St. Louis and Territory of Missouri
and leaving a copy of the Billwith Louis Tayon
Bazil Proulxnot found in the
county of St Louis

J. W. Thompson SHFF

2 services$ 1.201 non est.50$ 1.70

The word which is blotted
in this is Bill

JWT Shff

Territory of Missouri Northern circuit In ChanceryThe United States of America to Louis Tayon & Maurice Blondeau, their counselors attornies or agents-
Greeting -

Whereas it Hath been represented to our judges of our superior Court of our Territory
of Missouri sitting as a court of chancery in and for the Northern Circuit, on
the part of Bazile Proulx, Michel Lacroix and Frederick Olivercomplainants
against you the said Louis Tayon and Maurice Blondeau defendants that they the said Michael Lacroix and Frederick Oliver being possessed of large quantities of merchandise suitable for the Indian fur trade in the fall
of the yeareighteen hundred and fifteen at St Louis , they made a sale of
a part thereof to the aforesaid Bazile Proulx to the amount of one thousand
six hundred and ninety four dollars or there abouts the payment for which was assured to them by the note in writing, of the said Bazile Proulx for that
amount the same dated in October or November of the year
some time in the enduring spring out of the proceeds of the sale of the said
goods-that the said Bazile Proulx made sale of the said good to you
the said Maurice Blondeau for the sum of twelve thousand two hundred
and forty three livres ten sols and took your note therefore payble to him-
self in the course of the month of March then next following, which
said note was in his hands humbly as trustee for the use and benefit of his equippers of which you the said Blondeau had notice that after said
note became due at cote sans dessein the said Bazile Proulx delivered the
said note to you the said Louis Tayon withintention to make collection
of the same by seizing the packs of fur and pelts of said Maurice upon their arrival at St Louis or St. Charles , which the said Louis undertook
to do but represented to the said Proulx that to give him authority
to collect the said amount, it was necessary that the said Bazile Proulx
should set his name on the back of said note, which was by him done in over to enable you the said Louis to collect the said note
for the benefit of himself and equippers that the name of the said Bazile
was placed in Blank on the Back of said note, unaccompanied by any Words, importing an assignment of the contracts there of to you the said
Tayon , nor was any made or contemplated to the made to you nor any
sum whatever paid or offered to the paid by you said Proulx for said
note that on the arrival of the said Bazile Proulx at St. Charles , earlier in
the month of April and before the payment of the said note to you said
Louis he demanded the same of you said Louis who informed him that
you had placed the same in the hands of Edward Hempstead for collection, but
promised to get it back for said Bazile and afterwardspretended that you
had actually sent for it but that Mr. Hempstead was at Misere and that
on his return or at the next court at St. Charles you would get it for
where upon a second demand in presence of said Hempstead you pretended
and avered that you had bought the same you the said Bazile for the
sum of about six hundred dollars. That you the said Blondeau afterwards with the approbation of said Proulx paid to said Michel Lacroix the amount of said note taking his receipt for the same, together
with a written understanding to indemnify him against all costs and
damages which Tayon might be entitled to an account of said payment
That a suit was accordingly entitled against said Blondeau by you
said Louis and a recovery had of the lawsuit of said note and execution issued against said Blondeau, which said execution has since been satisfied
and the said Maurice wholly acquitted and discharged therefore in virtue of an arrangement made between the said Maurice Blondeau an
and the said Tayon whereby the said Blondeau to him the said
Tayon the said written undertaking by said Michel given to said Maurice against the decrees and demands of the said Louis on
account of the said note which said written undertaking is now in the hands
of the said Louis Tayon had his since been put in against the said Michel Lacroix in the circuit court of the county of St Louis and praying the most gracious writ of injunction directed to you the said Louis Tayon & Maurice Blondeau your counsellors, attornies, solicitors and agents commanding
you and each of you to desist and proceed no further at law
against the said Michel Lacroix until the final hearing of this

Cause and that on said final hearing the said injunction may be decreed
to he perpetual. We therefore in consideration of the premises, aforesaid, do
strictly enjoin and commandyou the said Louis Tayon and Maurice Blondeau, your counsellors attornies solicitors or agents, the said Michel Lacroix having filed a bond with security as required by laws, you desist from proceeding any further in the suit at law so by you entitled against the said Michel Lacroix in the said circuit court of the county of St. Louis aforesaid until the hearing of this cause by our said Superior court sitting as a court of chancery.

Witness the Honorable Alexander Stuart Esquire presiding judge of our said court at St. Louis this
thirteenth day of October in the year of our Lord one thousand
eight hundred and seventeen and of our Independence
the forty second J. V. Garnier S. C. N. C.

In Chancery Northern CircuitMarch term 1818

Executed this writ
October 13th 1817 in the Town of
St Louis

A. V. Carr Deft (attorney for defendant)2 services $1. 60
Filed request1818 J. V. Garnier

october 13th 1817

In Chancery, Northern CircuitThe United States of America to Louis Tayon and Maurice Blondeau Greeting

You are summoned that all excuses and delays being set aside, You and each of you personally be and appear
Before the judges of our superior court of our Territory of Missouri at our said superior sitting as a court of chancery in and for the Northern Circuit, at the Town of St. Louis on the fourth Monday in March next, then and there in our said
Court before our Judges of our Said Court to answer the Bill of complaint of Bazile Proulx, Michel Lacroix and Frederick Oliverexhibited againstYou, and to do further and receive what our said court shall have considered in
this Behalf and this your may in quit at your peril - and our Sheriff of our county of St. Charles is hereby commanded then and there to make return of this our writ and certify to our court how he executes the same

Witness the Honorable Alexander Stuart Esquire presiding Judge of our said court at St Louis this
thirty first day of October in the year of our Lord one thousand and eight hundred and Seventeen and of our
independence the forty Second J. V. Garnier S. C. N. C.

No.1 In Chancery, Northern CircuitMarch Term 1818

SUBPOENA

Executed Sheriffs fees

Service80ctsTravel120.92

Executed on Louis Tayon in the town and township of Saint Charles on the6th day of January 1818, & delivered a copy
of the Complainants BillMaurice Blondeau is not to be found in my county

Uriah J. Devore, Shff