In the SuperiorSuperior Court court
Northern Circuit
ss:
The United StatesUnited States of AmericaAmerica to LouisLouis Beaudoin
BeaudoinLouis Beaudoin his attornies councellorssolicitors or
Agents and to the
Sheriff of the County of StCounty of St Louis
LouisCounty of St Louis Greetings-
Whereon It hath been represented to our Judge of our
Superior CourtSuperior Court of our Territory
of MissouriMissourisitting as a Court of
Chancery in and for the Northern Circuit
on
the part of JohnJohn P Cabanne PJohn P Cabanne CabanneJohn P Cabanne andAntoineAntoine Chenier ChenierAntoine Chenier complaining against
You the said
LouisLouis Beaudoin BeaudoinLouis Beaudoin Defendant that sometime in the
month of October
of the Year eighteen hundred and fifteen the Said
complainants entered into
a contract with
You the said defendant to go as a clerk or trader
in the Service
of said complainants up the MissouriMissouriRiver
and its tributary
waters
on a trading voyage and delivered to You a
considerable quantity
of merchandise to the value of four
thousand five hundred and thirty eight
dollars twenty Seven cents, and
for your Services on the Said Voyage
agreed to pay You the Sum of three
hundred dollars, You agreeing on
Your part to
trade and barter the said goods with
the Indians on
the MissouriMissouri and
itswaters
and to bestowdue
care, diligence and
attention upon the conducting of the Said
business- That pursuant thereto
you
proceeded up the MissouriMissouri in charge of the Said
goods, but in trading
with the Indians and conducting the businessentrusted to you So grossly
misconducted yourself by being
frequently intoxicated, by quarelling with
and driving away the Indiansprofessing to trade with You by
Sometime
refusing to trade with them, by trading the Said goods at
improper Season
and by Selling to
other traders the articles most in demand among
the Inidans, and
which were necessary to securea market
for
the remainder and by other neglects and
mismanagement that the whole
returns of the Said Voyage amounted to
no more than two thousand
and two dollars,
less than one half of the out fits- That in consequence
of such
mismanagement or malconduct the complainantsconceived
themselves justified in refusing and did
actuallyrefuse
to pay to you
the Said Louis, the wages agreed upon for Your Services as
aforesaid-
that when such refusal You the Said LouisLouis Beaudoin BeaudoinLouis Beaudoin commenced a suit
for the recovery of the Said Wages- That when the trial of the Said Wages
the complainants attempted to defend themselves from the payment of the
Said Wages by showing Your Misconduct and negligence as a failure
to perform Their part of the Said contract but written attempt were
over ruled by the court which decided that as you the Said Louis had in
Some measure performed Your Contract by proceeding on the Voyage
the complainants Could not give in evidence You Negligence and â
unfaithfulness as a defense against Your demand for wages, but
that their only remedy was by an action whom the contract against you
that a Judgement was therefore rendered against them by the Said court
for the Said Sum of three hundred dollars, on which Judgement an
execution has been issued and lodged with the Sheriff of St LouisSt Louis county
who is about proceeding to levy and collect the Same Therefore It was
prayed that they might have an injunction for stay of yours the
defendants proceedings at law, until the hearing of the same- We therefore
in consideration of the promises aforesaid do strictlyenjoin and command you
the Said LouisLouis Beaudoin BeaudoinLouis Beaudoin Your councellorsattorniessolicitors or agents that
You and each of you desist from taking execution against the Said complainants
whom the Judgment aforesaid, So as aforesaidrendered against them
and you the said sheriff if the execution aforesaid be actually lodged with
You, that youdesist from serving or levying or collecting the Same from
the Said complainants until the hearing of this case by our Said
SuperiorSuperior Court court sitting as a court of chancery as aforesaid-
Residing Judge of our Said Court at St LouisSt Louis this
twenty fifth day of September in the year of our Lord one thousand eight hundred and nineteen and
of our Independence the forty fourth
J.VJ V Garnier . GarnierJ V Garnier clk S.C.N.C


