northern circuit
territory of missouriThe United StatesUnited States of AmericaAmericaLouis Tayon Maurice Bondeau and Bazile ProulxBazile Proulx their counselors attornies solicitors or agents. Greetings
Whereas it has been represented to our
judges of our Superior CourtSuperior Court of our Territory of
MissouriMissouri in and for the northern
Circuit
sitting as a court of Chancery, on
the part of MichelMichael
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 ProulxBazile 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 MauriceMaurice 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 ProulxProulx
before the said note became
due placed
the same into the hands of the said Louis TayonTayon for
the mere
purpose of collection and where the representation of to
said TayonTayon to said ProulxProulx , 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 TayonTayon or someone for
him over the name of the said ProulxProulx - That a suit was brought on said
note
against the said MauriceMaurice Blondeau in the circuit court of the county of St. LouisSt 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 TayonTayon never paid said ProulxProulx 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 ProulxProulx and
said TayonTayon 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 ProulxProulx or TayonTayon 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
TayonTayon and all and every the previous before
mentioned that you
absolutely desist from proceedings at law in the premises you the said Louis TayonTayon in taking out execution against the
said MauriceMaurice Blondeau for the amount of the said judgment, You the said MauriceMaurice in paying the henceover and you the said BazileBazile in receiving the same or any part or parcel
of the same until the hearing after
cause
by our said Superior CourtSuperior Court sitting as a court of chancery as aforesaid
hundred and seventeen and of our independence the fourty first
J. V. GarnierJ V Garnier atty S. C. N. C.


