John P. Cabanne and Antoine Chenier, merchants trading under the firm name of Cabanne and Chenier vs. Amable Steine, Executor for the Estate of Louis Beaudoin
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Theanswer of LouisLouis Beaudoin BeaudoinLouis Beaudoin to the Bill of
complaint of JohnJohn P Cabanne P CabanneJohn P Cabanne of AntoineAntoine Chenier ChenierAntoine Chenier
Complainants -

The said Defendant saving & reserving to
himself now and at all times hereafter all of
all manner of benefit and advantage of exception
to the manifold uncertainties and imperfections
in the complainants said bill of complaint
contained for answer thereunto, or
unto somuch thereof as materially concerns
this Defendant to make answer unto he answereth
and saith - that true it is sometime
in the month of October one thousand eight
hundred of fifteen
heentered into a contract
with the said complainants to go for them as
a clerk or trader up the MissouriMissouririver, and
its tributory waters, to trade with the indians
for which the said complainants agreed to
pay him the sum of three hundred dollar
but there was no express agreement as to the
manner in which the said defendant should conduct
himself in the said business - but it was left
to begoverned by the ordinary operations of law
as other agreements of that hired one. This Defendant
can not be supposed to have contracted, for any
very of his clerkship during the
voyage - as hecanneither read nor write - which
was never known to the said complainants
of this defendant consisted in his knowledge
of the Indian tongues, & of the Indians, with
whom he was going to trade. His
his manners, & habits, have been known to the
complainants for this great many years, and
he has acquired no new habits during that voyage

This Defendant was not sent alone on the said
trading voyage - nor was he solelyentrusted with

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the management of the goods, this brother JosephJoseph Beaudoin
BeaudoinJoseph Beaudoin was employed by the said complainants
on the same voyage, and was authorized to trade
a part of the said good with the Indians. The
object of intentionwas, that the said goods should
be taken up the MissouriMissouri to the Indians trading
ground and should then be divided and
sent to different trading ground, as might
them be thought best for the interest of the
employers. This Defendant does not know
the amount of goods which the said complainants
sent on that voyage. This defendant proceeded
up the MissouriMissouriaccording to his agreement
and traded with the Otos of IowaIowa when hetraded
together with his brother for a considerable length
of time. Hethentook part of the said good
& left his brother and went among the PanisPanis
& traded until the trading season was over
when he returned to St. LouisSt Louis with the
avails of his voyage and delivered them up to the
Complainants together with all the papers
relating to the same. The said Complainants
received the petitions & papers from this Defendant
without expressing any dissatisfaction, as this
Defendant knew of at that time. Some time
afterwards when called on for the pay they
began to frame excuses, sometimes of one
kind, some time of another to delay him -
After that they began to claim some reduction
of the wages of this Defendant, on the ground
that some of the goods had been stolen by the
Indians - which were not stolen however from
the inventory of this Defendant - but from the inventory