John P. Cabanne, Pierre Chouteau, Barthole Benthold, Bernard Pratte, and Michael Smuel vs. Charles Hempstead, Theodore Hunt, and Manuel Lisa
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State of MissouriMissouriin the Chancury Court (Superior) Judicial District March Term 1822

The joint and several answer of Mary LisaMary Lisa executed and
CharlesCharles S Hempstead SCharles S Hempstead . Hermpstead executer of the last will and test amount of
Manual LisaManuel Lisa declared Gro of Dependents, to the Bill of
comptant of John PJohn P . Cabame. Bacholom on Buchold
Pure Chorteau Junior. Bern and halre, and MichalMichael Simell

These Depondants non and at all times someafter saring, and worring
to theme his siverally and uspectively all and all manuo of benefit and
advantage of exception, that can, or may be had to the many error and
unextamtish incefficin is and other imperfection in the said complainants
said Bill of complaint contained, for answer thereto; or unto so much
thereof as then Defendants the advised is matiual and necessary
for them to make arrive unto, and nor sad and say

That thy have from informed, that a partnership was formed
behrssa said complainants and said throdore HuntHunt , and Manual LisaManuel Lisa
declared, at the time, and in the manner stated in said Bill of complaint
and that the exhibited marked No 1 of said complainants as part
of their Bill is a Copy of said articles of association â

That said partners purchased goods â haded the some
until the time stated in said Bill, and thats at that period
a majorily of said partners did sell and abandoner to said ManuelManuel Lisa
LisaManuel Lisa deceased the property mentioned in said articles of agrreeming
and in the manner, on the terms, and for the consideration stated in
said Artecles all which may more fully appears by referer to said
two articles of agreement marked as exhibited No 2 in said complainants
Bill of complaint â

These said Deferdants further ammoring, say, that they are
ignorant of any meaning and intext of said two articles of agreement

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marked exhibit No 2. than as mentioned, expreped, and sit
forth in said articles â to which these Depondants again refer for
thi here meaning, and instant of said constructing ponties â that whether
there is any mistake in oraning the said articles these Depodants cannot
of thin knowledge say â but they must that if any out
mistake occurred, that said complainants shall fully and satisfactorily
prove the same according to the sheet rules of evidence in such cases â
these Defendants know themeselves that said complainants never trutended
to shown in verious comonatems before said C S Hompitrad and own as
of said complainants ulatiri to the articles of agrreming above refused
to, that there was a mistake in oraning up said articles, it was on
the construction of the effect of the said explanatory article that a
defference of opinion existed â These said Dependants expreply thems
the construction of said articles only said complainants inged in then
said Bill of eomplains â and shall insist one the trial of its causes
that said articles be construced by the known and fixed rules in
law and equity, torrect, upon the whole fevor of said anticles and
according to the meaning and intent of said contracting pointies as expreped
therein â

These Depondants further arroring, say, that they have
here informed and beleaved it true, that said Michail Immarll
asin the first day of June 1819 traded at the Rred villago
a quantity of recieved by him from the original company
of Cabanse' & 1. and that in the month of November following
he delivered the provereds of the same to said mamurss LisaLisa declared
bring the same mentioned on said receipts marked exhibit No
3. attached to said complainants Bill â These Depondants forther
state that this have no knowledge of the form petitions of had ed
by said pierre promeaw, but imming that the complainants prove their
said allegation in that behalf â and is it shall hereafter