For H C Simmons
1829
Aug 31st To Balance of amount 2253.82

for
By due in H E Summons
accept this draft 26th March 1829
at 4 months 500.00

paid 250 00

due 250.00

By due on Accept. 18th
Apl. 1829 6 months 233.70

,, Claimd by them for on 200 00

683 70

We Labeaumin & $1570 12

19 apr 1832

the amount of fifteen
Hundred and seventy dollars twelve and half
it being the balance due

H. C. Simmons
ME acknowledged

P. Labeaumin

In the St Louis Circuit Court
November Term 1830 County of St Louis , sct,

Hezekiah C. Sriumons (who sues to the use of
John Newman William K Rule Edward Walsh
as Trustees of said Sriumons, for the benefit of the creditors
of said Sriumons) complains of Pierre A Lebeaume
in custody of a plea of trespass on the case on
. For that whereas the said Defendants
heretofore to wit on the first day of July in the
year Eighteen hundred and thirty, at the county
aforesaid was indebted to the said Plaintiff in the
sum of four thousand dollars lawful money for
divers good wares and merchandize by the said
plaintiff before that time sold and delivered to
the said Defendant, and at his special insistence and
request; and living so indebted he the said Defendant
in consideration there of afterwards, to wit another
day and year last aforesaid, at the county aforesaid
undertook & then and there faithfully for
the said plaintiff to pay him the said sum of money
when he the said defendant should be thereunto
afterwards requested. And whereas also the said
Defendant afterwards to wit, on the day and year
last aforesaid, at the county aforesaid, accounted
with said Plaintiff of and concerning chooses
other sums of money from the said Defendant to
the said Plaintiff before that time due and owing
and there in arrear and unpaid and upon such
accounting the said Defendant was then and there
found to be in arear and indebted to the said
Plaintiff in the further sum of three thousand
dollars of like lawful money and bring so found
in arrear and indebited he the said Defendant in con
sideration thereof afterwards to wit another day
and year last aforesaid, at the county aforesaid,
undertook and then and there faithfully promised
the said Plaintiff to pay him the said last mentioned
sum of money when he the said Defendants
should be thereunto afterwards requested.

Nevertheless the said Defendants not regarding
his said several promises and undertakings truth
contraversy and fraudulently intending to deceive
and defraud the said Plaintiff in this behalf
hath not as yet paid sum the said several
sums of money or any neither of them or any
part thereof to the said Plaintiff who sues to the
use aforesaid often requested to so do.)
But to the said Defendant to pay him the same
hath hitherto wholly neglected and refused
and still doth neglect and refuse. To the damage
five thousand dollars and therefore of the
said Plaintiff, who sues to the use aforesaid,
of five thousand dollars and therefore he should.

J. Newman ..

State of Missouri
County of St. Louis
sct,

This day John Newman personally appeared
before me Archibald Gamble clerk of the circuit court for the
county of St. Louis and being by me first duly sworn, upon his
oath deposeth and Saith, that Hezekiah C. Simmons the plaintiffs
in the foregoing declaration, hath now a real,
and un satisfied cause of action against Pierre A
Lebeaume the defendant in said declaration, which
is the same cause of action set in the above
declaration and amounts to the sum of two
thousand dollars, and upwards and this affiant further says that
he is informed and verily believes that the said Defendant
Lbeaume, is now engaged in disposing of all of his property
in the State of Missouri , and is now preparing to secretly
leave the State of Missouri , in a few days. And this affiant
further says that he virely believes that the said plaintiff
will be in danger of losing his said debt unless the said
Defendant Lebeaume be held to bail

Sworn to
before me this 24th day
of September 1830 John Newman A Gamble Clerk

this affidavit it is ordered that
a issued and the defendant Pierre
A Lebeaume he held to bail in the sum
of two thousand five hundred dollars

A Gamble Clerk

Executed this writ on Pierre A Labeaume on the 25th day of September 1830 in
the county of St. Louis by giving to him the writ and declaration to read
and taking the body of the said Pierre A. Lebeaume in to custody he the
said Labeaume being afterwards discharged on the same day by Mary
P Le due a justice of the county court for the county of St. Louis under
the Laws of this State. The said Labeaume being at the
time in custody under an execution in favor of Thomas
to the use of Scott & Rule against Pierre A Labeaume & Charles D.
St. Vrain the warrant of said here with Returned

Service. $1.00

John K Walker sheriff
by Brotherton

No 22.
St. Louis Circuit Court
November Term 1830

Hezekiah C. Simmons &
vs Declaration
Pierre A Labeaume

filed Septr 24th 1830.
A Gamble Clk

This is an action of trespass on the
case on promises. $5000
On the written affidavit
a

The State of Missouri County of St. Louis sctTo the Sheriff of St. Louis County
Greeting

We command you to take Peirre
A Labeaume if he may be found in your County
and him safe by so that you may have his
body before the judge of our Circuit Court at
the next term thereof to be held at the city of
St. Louis within and for the County of St. Louis
on the fourth Monday of November next then
and there to answerunto Hezekiah A Simmons
of a plea of (who sues to the use of John Newman
William Rule & Edward Walsh as Trustees of said
Summons for the of his creditors of a
file of trespass on the case upon promises to the
damage of said plaintiff of five Thousand
dollars and how you then there this writ

Witness Archibald Gamble Clerk
of our said Circut Court office this
24th day of September 1830 Archibald Gamble Clerk

Pierre A Labeaume
ads
Hezekiah C Simmons &c

And now at this
day comes the said Peirre A Labeaume by
Bent his attorney and says he did not under
take and promise in manner and form as the
said Simmons , the plaintiff, hath above thereof
in declaring alledged and of this he puts himself
duly upon our County &c

Bent
for dft

filed April 6th 1831 A Gamble Clk

Submission and judgment for $1870 12 Book 6 page 315

Archibald Gamble

No 22 Novr. Term 1831

Hezekiah C Simmons to writ
vs
Peirre A Labeaume
ads Plea
H C Simmons trespass

filed April 6th 1831. A Gamble Clk

County Of St. Louis , Sct.
State of Missouri ,To the Sheriff of Saint Louis County---Greeting.

You are hereby commanded to summon Louis Bompart and Richard Atkinson
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 29th day of Marchnext at the
City of St. Louis , then and there to testify and the truth to say in a certain matter of controversy now
pending in our said Court, wherein Hezekiah C Simmons to use of is
plaintiff, and Pierre A Labeaume is defendant,
on the part of the plaintiff; and have you then there this writ.

Witness, Archibald Gamble , Clerk of our said
Circuit Court , at the City of St. Louis , this 20th
day of February in the year of our Lord one
thousand eight hundred and thirty-two Archibald Gamble Clerk C.C.

Served this
writ an Louis
Bompart on the
29 July 1832
R Atkinson in wrt
are found in
my County

Walker Shff

50.5

12 1/2

$ 62 1/2

March Term 1832

H.C Simmons to
vs
Pierre A Labeaume

for
Louis Bompart
Richard Atkinson

on 29th March