Hezekiah C. Simmons, John Newman vs. Pierre Labeaume
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In the St Louis Circuit CourtCircuit Court
November Term 1830

County of St LouisCounty of St Louis, sct,

HezekiahHezekiah C. Sriumons (who sues to the use of
JohnJohn Newman NewmanJohn Newman William KWilliam K Rule RuleWilliam K Rule Edward Walsh
as TrusteesTrustees of said Sriumons, for the benefit of the creditors
of said Sriumons) complains of PierrePierre A Lebeaume APierre A Lebeaume LebeaumePierre A Lebeaume
in custody of a plea of trespass on the case on
. For that whereas the said Defendants
heretofore to wit on the first day of July in the year Eighteen hundred and thirty, at the county
aforesaid was indebted to the said Plaintiff in the
sum of four thousand dollars lawful money for
divers good wares and merchandize by the said
plaintiff before that time sold and delivered to
the said Defendant, and at his special insistence and
request; and living so indebted he the said Defendant
in consideration there of afterwards, to wit another
day and year last aforesaid, at the county aforesaid
undertook & then and there faithfully for
the said plaintiff to pay him the said sum of money
when he the said defendant should be thereunto
afterwards requested. And whereas also the said
Defendant afterwards to wit, on the day and year
last aforesaid, at the county aforesaid, accounted
with said Plaintiff of and concerning chooses
other sums of money from the said Defendant to
the said Plaintiff before that time due and owing
and there in arrear and unpaid and upon such
accounting the said Defendant was then and there
found to be in arear and indebted to the said
Plaintiff in the further sum of three thousand

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dollars of like lawful money and bring so found
in arrear and indebited he the said Defendant in con
sideration thereof afterwards to wit another day
and year last aforesaid, at the county aforesaid,
undertook and then and there faithfully promised
the said Plaintiff to pay him the said last mentioned
sum of money when he the said Defendants
should be thereunto afterwards requested.

Nevertheless the said Defendants not regarding
his said several promises and undertakings truth
contraversy and fraudulently intending to deceive
and defraud the said Plaintiff in this behalf
hath not as yet paid sum the said several
sums of money or any neither of them or any
part thereof to the said Plaintiff who sues to the
use aforesaid often requested to so do.)
But to the said Defendant to pay him the same
hath hitherto wholly neglected and refused
and still doth neglect and refuse. To the damage
five thousand dollars and therefore of the
said Plaintiff, who sues to the use aforesaid,
of five thousand dollars and therefore he should.

J. Newman ..

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