Bank of Missouri vs. William Clark
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county of St. LouisSt Louis

In the Circuit CourtCircuit Court October term 1823

The president Directors & company of the Bank of MissouriBank of Missouri by
Shother their attorny complain of William ClarkWilliam Clark of a plea of trespass on
the care, For that whereas James KennedyJames Kennerly heretofore to wit on the twelfth day of July in the year eighteen hundred and twenty two at St. LouisSt Louis in the
county aforesaid made his certain note in writing commony called a promissory
note, which is to the court here now shown by which said note he the said
JamesJames then and there promised to pay sixty day after the date thereof to the
said William ClarkWilliam Clark or order the sum of one thousand dollars for value
received without negotiable and payable at the Bank of Misssouri
And the said WilliamWilliam afterwards to wit on the day and year aforesaid at
the County aforsaid endorsed the said note in writing by which said
he the said Willian then and there ordered and appointed the said
sum of money in the said note specified to be paid to the said plaintiff
And the said plaintiff in fact say that afterward when the said note become due and payable court, on the thirteenth day of september in the
aforesaid at the county aforesaid the said note so endorsed as aforesaid
was presented and shown at the said bank of missouri for payment thereof
and payment of the said sum of money therein specified was then
and there duly required accordingly to the tenor and effect of the said
promissory note, but that neither the said JamesJames nor any other person
or persons on behalf of the said JamesJames , did or would at the said time
when the said promissory note was so presented and shown for payment thereof
as aforesaid or at any other time before or afterwards pay the said
sum of money therein specified or any part thereof but wholly neglected
and refused so to do. of all which said several premisis the said WilliamWilliam
afterwards to wit on the day and year case aforesaid at the County
aforesaid had notice, by means whereof the said william then and

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there became liable to pay to the said plaintiff the said sum of Two
note specified when he the said william should be thereunto afterwards requested
and being so liable he the said william in consideration thereof afterwads
to wit on the day and year last aforesaid at the county aforesaid undertook
and then and there faithfully promised the said plaintiff to pay then the
said sum of money when he the said william should be there unto afterwards
requested,

And whereas also the said WilliamWilliam afterwards to wit on the first day of July in the year eighteen hundred and twenty three at the county aforesaid was
indebted to the said plaintiff in the further sum of two thousand dollars
for so much money before that time had and received by the said WilliamWilliam
to and for the use of the said plaintiff; and being so indebted he the
said WilliamWilliam in consideration thereof afterwards to wit on the day and
year last aforesaid, at the county aforesaid undertook and then and
there faithfully promised the said plaintiff to pay then the said last
mentioned sum of money when he the said william should be thereunto
afterwards requested.

never the the said william although often requested has not
paid to the said plaintiff the said several sums of money or other of them
or any part thereof but to pay the same to the said plaintiff has hitherto
wholly neglected and refused and still neglected and refuses so to do,
to the damage of the said plaintiff of two thousand dollars and therefore
they being

Shother atty Plffs