humbly complaining showeth unto your honors young orator MichelMichael Lacroix of the town of St. LouisSt Louis that some time in the year eighteen hundred & fifteen he equipped
or furnished to one certain Bazile ProulxBazile 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 ProulxProulx sold the said good to one
MauriceMaurice 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, ProulxProulx
for the mere purposes of collection placed the same with the said Bazille Proulx and MauriceMaurice Blondeau in the hands of one Louis TayonTayon who your orator Prays may be made defendants to this his Bill of
complaint - TayonTayon told ProulxProulx 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 ProulxProulx as your orator
is informed and believes it to be true - and the said Louis
TayonTayon 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
TayonTayon in the circuit court for the county of St LouisSt Louis and
Judgement thereon obtainedat the November term

Eighteen 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 PatrickPatrick Lee entered as the bail of Blondeau and are now liable to be
proceeded against as such by said TayonTayon 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 ProulxProulx was justly coming to him as the equipper of said ProulxProulx and therefore the said aforesaid at common law was defended
by him in said Blondeau's name But the name -
of said ProulxProulx 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 TayonTayon merely to collect and not to transfer the property therein to him and that he never
paid said ProulxProulx 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 ProulxProulx and
TayonTayon 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