Michel Lacroix vs. Louis Tayon, Maurice Blondeau, and Bazile Proulx
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Territory of MissouriMissouri

Northern circuit

In Chancery

The UnitedUnited States StatesUnited States of AmericaAmerica 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 MissouriMissouri 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 TayonTayon and MauriceMaurice Blondeau defendants that they the said MichaelMichael 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 LouisSt Louis, they made a sale of
a part thereof to the aforesaid Bazile ProulxBazile 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 ProulxBazile 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 ProulxBazile Proulx made sale of the said good to you
the said MauriceMaurice 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 ProulxBazile Proulx delivered the
said note to you the said Louis TayonTayon withintention to make collection
of the same by seizing the packs of fur and pelts of said MauriceMaurice upon their arrival at St LouisSt Louis or St. CharlesSt Charles, which the said Louis undertook
to do but represented to the said ProulxProulx that to give him authority
to collect the said amount, it was necessary that the said Bazile ProulxBazile 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 BazileBazile
was placed in Blank on the Back of said note, unaccompanied by any

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Words, importing an assignment of the contracts there of to you the said
TayonTayon , nor was any made or contemplated to the made to you nor any
sum whatever paid or offered to the paid by you said ProulxProulx for said
note that on the arrival of the said Bazile ProulxBazile Proulx at St. CharlesSt 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 HempsteadEdward Hempstead for collection, but
promised to get it back for said BazileBazile and afterwardspretended that you
had actually sent for it but that Mr. HempsteadHempstead was at Misere and that
on his return or at the next court at St. CharlesSt Charles you would get it for
where upon a second demand in presence of said HempsteadHempstead you pretended
and avered that you had bought the same you the said BazileBazile for the
sum of about six hundred dollars. That you the said Blondeau afterwards with the approbation of said ProulxProulx paid to said MichelMichael 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 TayonTayon 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 MauriceMaurice wholly acquitted and discharged therefore in virtue of an arrangement made between the said MauriceMaurice Blondeau an
and the said TayonTayon whereby the said Blondeau to him the said
TayonTayon the said written undertaking by said MichelMichael given to said MauriceMaurice 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 TayonTayon had his since been put in against the said MichelMichael Lacroix in the circuit court of the county of St LouisSt 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 MichelMichael Lacroix until the final hearing of this