Before the Subscribing witness personally ap-
peared the endangered Fredrick Labone who vol-
untarily binds, and by their presence does engage
himself to Kenneth McKensie Agent of the American
Fur Company for Upper Missouri Outfit in the
capacity of Clerk and Trader to the business of
the Indian Trade in the missouri and its
for and during the space of a year to
commence at the date of that and
to expire on arrival of said outfits boats
in Saint Louis the summer of eighteen hundred
and thirty four on the following term and condi-
tions to say_ Said McKensie agent as afore-
said promises and obliges himself to pay said
for such services faithfully rendered the
sum of five hundred dollars and a Suit of
Clothes annum

Said on his part binds himself to serve
obey, and excute with fidelity the orders
or know wishes of his employers or any
person in charge of their business to the
of his knowledge and abilities, keep their
give them information of any thing which
may come to his knowledge affecting their in-
terest, take care of and protect their prop-
erty of whatsoever nature or kind it may be
and to do all such things as an usually done
or ought to be done by a good and faithful
Clerk and Trader It is further agreed and
understood that the said Labour is not all-
owed to trade with whites, or Indians
on his own account

Frederick Laboue Agt. upper missouri outfit Witness Fort Tecumseh June 20th 1832June 20th 1831

Frederick Laboue
Engagement
Saint Louis Sumr 18341834
$ 500
per annum
Suit Clothes for 1st Year
paid in full.

In the Circuit Court
November term 1832

Saint Louis County to wit: Frederick Laboue com
plains of Pierre Chouteau Junior of a plea of trespass
upon the case upon promises: For that whereas hereto
fore to wit on the fifteenth day of June in the year of
our Lord one thousand eight hundred & thirty one, at
the County aforesaid, by a certain instrument in writing
(which the plaintiff cannot produce in court, because
the same is in the possession & power of the defendant)
in consideration that the said plaintiff at the special in-
stance & request of the defendant had then & there
engaged & bound himself to serve the American
Fur Company (of which company the said defendant
was & is one, & was &is the agent of the said company,
& director of its business & affairs at St Louis for the waters
of the Missouri ) for the term of three years from the
said him as a clerk & trader the said defendant undertook & then &
there faithfully promised the said plaintiff to
pay him, yearly & every year during the said
term, the sum of five hundred dollars, and a
fine suit of clothes. And the said plaintiff says
that in pursance of his said obligation, he did immedi
ately enter into the service of the said company (the
defendant being then & now one of the said company)
and served the said company as a clerk & trader for
one whole year then next following of which the
defendant had one notice, yet the defendant has not paid to the plaintiff although often
requested so to do, has not paid to the plaintiff
the said sum of five hundered dollars and a fine
suit of clothes or either or any part thereof but
so to do has hitherto wholly neglected refused
& still does neglect & refuse.

And also for that whereas heretofore to wit
on the fifteenth day of June in the year one thousand
eight hundred & thirty one at the County aforesaid, in
consideration that the said plaintiff had then & there, at
the special instance request of the defendant engaged
& bound himself to serve the said defendant as
a clerk & trader, in his commerce with the Indians, for the
term of three years the said defendant undertook &
then & there faithfully promised the said plaintiff to
pay him, from year to year, and at the end of every
year he should serve as aforesaid, the sum of five
Hundred Dollars and also pay & deliver to him a suit
of fine clothes. And the said plaintiff avers that, in
pursuance of his said enagagement, he did then & there
enter into the service of the said defendant, and did
serve him as a clerk & trader in his commerce with
the indians for one whole year, of which the defend
ant had notice; yet the said defendant although
often requested, has not paid to the plaintiff the
said sum of five hundred dollars or any part thereof,
nor paid & delivered to him a suit of fine clothes
or any part thereof, but so to do has hitherto wholly
neglated refused, & still does neglect & refuse

And also for that whereas heretofore to wit on

the fifteenth day of June in the year one thousand
eight hundred & thirty one, at the County aforesaid,
in consideration that the plaintiff, at the special
instance & request of the defendant, had then & there
engaged & bound himself to serve the defendant
as a clerk & trader, in his the defendant's commerce
with the indians, for the term of three years, the said
defendant undertook & then & there faithfully pro=
=mised the plaintiff, to keep & retain him the plaintiff
in the service & employment of him the defendant,
as a clerk & trader, in his the defendant's commerce
with the indians, for the term of three year then
next following, and to pay him, yearly & at the
end of every year of said term the sum of five
hundred dollars and a suit of fine clothes. And
the said plaintiff avers, that in pursuance of his said
engagement, & in confidence of the promise & undertaking
of the defendant, last aforesaid, he did then & there
enter into the service of the said defendant, and served
him as a clerk & trader, in his commerce with the
indians, for a long time, to wit one whole year, and
was then & there ready & willing, & did offer to continue
to serve the said defendant during the whole term
of three years as aforesaid, as such clerk & trader,
yet the said defendant, not regarding his promise &
undertaking, did not nor would keep & retain the
said plaintiff in the service & employment of him
the defendant, as a clerk & trader as aforesaid for the term of three years as aforesaid, but on the contrary
thereof, afterwards to wit on the sixteenth day of June
in the year of our Lord one thousand eight hundred
& thirty two, at the county aforesaid, did dismiss & discard
the plaintiff from the service & employment of him
the defendant, as such clerk & trader, & from thence
hitherto has wholly refused & still does refuse to
keep & retain the plaintiff in his service employment
as aforesaid.

And also, for that whereas, heretofore to wit
on the twenty second day of October in the
year of our Lord one thousand eight hundred &
thirty two, at the county aforesaid, in considera
=tion that the said defendant was then & there
indebted to the said plaintiff in a large sum of
money, to wit two thousand dollars, for the work
& labor care & diligence of him the said plaintiff
before that time done & performed for the defendant
at his request, and for goods, wares & merchandize
by the plaintiff before that time sold & delivered
to the defendant at his request, he the defendant,
undertook & then & there faithfully promised
the plaintiff to pay him the last mentioned
sum of money whenever he should
be thereunto afterwards requested yet the said
defendant, although often requested, has not
paid the same on any part thereof, but so to do
has hitherto wholly neglected refused, & still
does neglect & refuse.

Wherefore the plaintiff says he is injured &
has sustained damage to the value of three thousand
dollars, & therefore he sues

By his attorney
Edwd Bates

County of Saint Louis Ss
The State of Missouri To the Sheriff of the County of Saint Louis Greeting

We command you to Summon Pierre Chouteau Junior that he be and
appear 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 Saint Louis on the fourth
Monday of November next then and there to answer unto Frederick Laboue
of a plea of trespass upon the case upon promises wherefore the plaintiff
says he is injured and has sustained damage to the value of three thousand
dollars and have you then there this writ

Witness Archibald Gamble Clerk of our said Circuit
Court at office this Twenty seventh day of October
One thousand Eight Hundred and thirty two Archibald Gamble Clerk

Executed this writ by offering to read it
and the declaration to Pierre Chouteau
Junior in the city of St Louis on the 31st
day of October 1832 which he refused
to hear & acknowledge the
of the same

John K Walker Shff by J Brotherton Dpty Service $ 1.00

No 93
Saint Louis Circuit Court
November Term 1832

4 Counts
Damage $ 3000.

Issue a summons

Edw . Bates
atty. Filed 27th October 1832 Archibald Gamble Clerk

And the said Defendant Pierre Chouteau
Jr by Gamble his Attorney comes and defends the
wrong and injury when & and says he did not
undertake and promise in manner and form as
the said plaintiff hath above thereof complained
against him and of this he puts himself
upon the country

And for further plea in this behalf the
said Defendant says that the said plaintiff ought
not to have and maintain his aforesaid action
against the said defendant because he says
that before and at the time of the commence-
ment of this suit the said plaintiff was
to this defendant and others the partners
of this defendant in the said several supposed
promises and undertakings in the declaration
set forth in the sum of two thousand dollars for
goods wares and merchandise by the said de-
-fendants and his said partners before that time
sold and delivered to the said plaintiff at his spe-
-cial instance and request and also in the further
sum of two thousand dollars for so much money
by the said defendant and his said partners before
that time lent and advanced to and laid
out and expended for the said plaintiff at his said
special instance and request which said sums of
money exceed the damage sustained by the said
plaintiff by reason of the non performance of the said supposed prom
ises and undertakings in the declaration mentioned
and of out of which said sums this defendant is willing
and offers to set off and allow to the said plaintiff the said damages which he may have sustained as aforesaid
and this the said defendant is ready to verify wherefore
he prays judgement &

Filed march 23 1833 Gamble atto
for deft

And the said plaintiff,as to the plea of the said defendant
by him first above pleaded and whereof he has put him
self upon the county does the like

And as to the plea of said defendant by him Secondly
above pleaded, the said plaintiff says that by any thing
in that plea alleged he ought not to be barred or
precluded because he says that that he was not & is
not indebted to the said defendant & others his partners
in manner & form as the said defendant has
above in said second plea alleged and this he
prays may he of by the country
wherefore he prays judgment &

Edw Bates

No 93
Nov Term 1832

Pleas

1 Non

2 Set off

Filed march 25th
1833 A Gamble Clk

continued at defendants untoBook 7 page 104 & page 174104
Verdict & judgt for $ 275 ---"--- 358174

Fee bill 176

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

You are hereby commanded to summon Francis Guieran
J P Sarpy
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 nineteenth day of
Decr 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 Frederick Laboue is plaintiff and
P Chouteau Jr 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 10th day of Decr
in the year of our Lord, one thousand eight hundred and thirty three A Gamble Clerk, C.C.

for

Sarpy 26 19th Dec for
Pltf

Executed this writ on J.P. Sarpy
26th not Summon
St Louis County jan 1834

John K Walker Shff

Service$ .5012 1/20.62 1/2

County of St. Louis , sct. State of Missouri ,To the Sheriff of St. Louis County-Greeting.

You are hereby commanded to summon
that setting aside all manner of excuse and delay, he be and appear in proper person
before the judge of our Circuit Court , forthwith
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 Frederick Laboue plaintiff and
P Chouteau Jr is defendant, on the
part of the and have you then there this writ.

Witness, Archibald Gamble , Clerk of our said Circuit Court , at the
City of St. Louis , this 3rd day of January
in the year of our Lord, one thousand eight hundred and thirty four A Gamble Clerk, C.C.

Served this writ on
on the 3rd Day of july
1834 in the City of St Louis

Jno K Walker
Ser.50 cts

for

forthwith for Plaintiff

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

You are herby commanded to summon Francois Geuran
Jno B Sarpy
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 fourth day of
April 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 Frederick Laboue is plaintiff and
Pierre Chouteau 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 four A Gamble Clerk, C.C.

March Term 1834

for

Francois Jno B Sarpy 4th April for
plaintiff

Executed this writ on Francis on
John B Sarpy 7th days of March 1834 in the
city of St Louis

John K Walker Shff Service 50 cts

County of St. Louis , sct. State of Missouri ,To the Sheriff of St. Louis County-Greeting.

You are herby commanded to summon Francis
Jno B Sarpy
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 forthwith day of
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 Frederick Laboue is plaintiff and
Pierre Chouteau 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 11th day of April
in the year of our Lord, one thousand eight hundred and thirty four A Gamble Clerk, C.C.

Jno B. Sarpy

Served this writ on Jno B. Sarpy
on the 11th
April 1834

Jno K. Walker
$ 1.00

To the above named defendant &Mr. Gamble his attorney

Take notice that on wednesday the 16th - day of
April instant at the office of Wilson Primm Esqr
in St Louis , between the hours of seven oclock in
the forenoon & six in the afternoon of the
day the depositions of witnesses will be taken
to be read in evidence of this cause
on the part of the plaintiff

St Louis April 11 1834
for the plff Edwd Bates atty

notice to take depositions.

Executed this notice by delivering a true copy
of it to Pierre Chouteau Jr in the City of St Louis
April 11th 1834

John K Walker Shff
by Isaac StonerDP Service .50

Depositions of witnesses produced sworn and examined on the sixteenth
day of April eighteen hundred and thirty four between the hours of
seven O'clock in the forenoon and six in the afternoon of that day
at the Office of Wilson Primm in St. Louis , before me the said
Wilson Primm, a Justice of the peace within and for the County
of St Louis in the state of Missouri , in a certain cause now
depending in the Circuit Court of St. Louis County aforesaid,
between Frederick Laboue plaintiff and Pierre Chouteau Jr
defendant on the part of the plaintiff.

Francois of lawful age being produced sworn and
examined on the part of the plaintiff deposeth and saith.
About the end of July or beginning of August eighteen
hundred and thirty two Frederick Laboue the plaintiff was imprisoned
in the common jail of St Louis County upon a charge of murder.
He sent for me and handed me a letter which he requested
me to hand Peter Chouteau Jr the defendant. The letter
was read to me by Laboue it contained a request to the
defendant to settle his plaintiff's account with me in
the same manner as if he were present and to pay over to
me the amount of wages due him. (The letter was handed
by me to Mr Chouteau the defendant, who after having
read it answered and told me that he had no settlement
of accounts to make with Laboue and that he would pay him nothing
to pay Thereupon I asked him if Laboue was not
hired to him - He answered that Laboue was still hired
to him - I said that Laboue was hired to him for two
years yet - he answered the he no longer needed Laboue's
Services -

Being cross- examined by defendant, deponent says
Question. When you came with the letter from Laboue and Several
times thereafter to see me; as you have above Stated, were you not authorized by Laboue to enter into negociations with
me to pay me money?

Answer. I was authorized by Labour to settle his account
with you, and to pay to you either the whole
or part of a demand of Francis A against him,
in your hands.

Question. Although I constantly refused to pay any thing to
Laboue , did you not come to me a short time before Laboue
was taken to Jefferson City for trial, and enter into
a formal obligation to pay me four hundred dollars on
account of debt ?

Answer. No, I did not_ I told you that Laboue ,
after his house should be sold and his necessary debts paid
the residue of the money to be applied to the payment
of his debt of Chardon.

Question. After your return from Jefferson City , did you not
come to me and offer me Laboue's house on condition that
I should pay several debts of which you gave me a schedule
and also extinguish Charson's debt?

Answer. On my return from Jefferson , finding that I could
not sell Laboue's house, I told you that if you would give
me one thousand dollars for it, I would pay you two hundred
dollars on amount of Laboue's debt to Chardon

Sworn to and subscribed before me
this 16th day of April 1834
Wilson Primm J.P.F

I Wilson Primm,, a Justice of the peace within and for the county of
St. Louis in the State of Missouri do hereby certify, that Francois Guerin the deponent
was by me first duly sworn to testify the whole truth of his knowledge touching the matters
in controversy aforesaid, that he was examined and his examination reduced to writing
and by him subscribed in my presence on the day, between the hours and at the place in
that behalf first aforesaid.

Wilson Primm Justice of the peace.

Depos for Defendant
opened & filed April
21st 1834

A Gamble Clk

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

You are hereby commanded to summon Francis &
John B Sarpy
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 Third day of
December 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 Frederick Laboue is plaintiff and
Pierre Chouteau Jr 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 Seventh day of Nov.
in the year of our Lord, one thousand eight hundred and thirty four A Gamble Clerk, C.C.

Nov Term 1834

for

Francis Geurin Jno B Sarpy 12 3rd Decr for
Plaintiff

Executed this writ on John B
Sarpy 12th in the county of St Louis
Francis Guerin not found in my
county St Louis Nov 1834

Jas Brotherton Shff By Isaac Stoner D.P

Service5012 1/262 1/2

County of St. Louis , sct. State of Missouri ,To the Sheriff of St. Louis County-Greeting.

You are hereby commanded to summon Francois Geurin
Jno B Sarpy
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 30th
day of March 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 Frederick Laboue is
plaintiff and Peter Chouteau
Jr is defendant on the part of
the plaintiff and have you then and there this writ.

Witness, Archibald Gamble , Clerk of our said Circuit Court , at the
City of St. Louis , this 25th day of February
in the year of our Lord one thousand eight hundred and thirty five A Gamble Clerk, C.C.

St Louis not found

Service5012 1/262 1/2

March T 1835

for

Fr Geurin Jno B Sarpy
30th March
for plff

Executed this writ by reading it to Jno B
Sarpey on the 5th day of March 1835 and by
delivering a true copy of it to a free white member
of the family of Frs Geurin above the age of
15 years at his place of Residence in the coun
ty of St. Louis on the 26th day of March 1835

J Brotherton Shff
By M . Brotherton Deputy Service $ 1.00

County of St. Louis , sct. State of Missouri ,To the Sheriff of St. Louis County-Greeting.

You are hereby commanded to summon Gabriel P. Cerre & Baptiste
Calican
that setting aside all manner of excuse and delay, he be and appear in proper
person before the Judge of our Circuit Court , forthwith
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 Frederick Laboue is
plaintiff and Pierre Chouteau Jr is
defendant on the part of
defendant and have you then and there this writ.

Witness, Archibald Gamble , Clerk of our said Circuit Court , at the
City of St. Louis , this second day of April
in the year of our Lord one thousand eight hundred and thirty five A Gamble Clerk, C.C.

for Dft

Baptiste CalicanGabriel P Cerre forthwith

Executed this writ by reading it to
Baptiste Calican and Gabriel P Cerre
in the city of St. Louis on the 2nd day
of April 1835

J Brotherton Shff By M Brotherton D Shff Service $ 1.00

County of St. Louis , sct. State of Missouri ,To the Sheriff of St. Louis County-Greeting.

You are hereby commanded to summon Francis Gueran &
Jno B Sarpy
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 Sixth day of
August 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 Frederick Laboue is plaintiff and
Peter Chouteau Jr 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 twelfth day of June
in the year of our Lord one thousand eight hundred and thirty four A Gamble Clerk C.C.

July Term 1834

for

Francis Gueran Jno B Sarpy 6th August for
plaintiff

Executed this writ on John B Sarpy on
the 8th day of July - 1834 by reading it to
him in the county of St. Louis
Francis Geuran not found

John K Walker Sheriff by J E brown DP Service $ .62

We the jurors in the case of F Laboue
vs Piere Chouteau find in favor of the
Plaintiff TwoHundred & Seventy five Dols

H William for
$ 275