Depositions of witnesses produced sworn and examined on the sixteenth day of April eighteen hundred and thirty four between the hours of
seven O'clock in the forenoon and six in the afternoon of that day
at the Office of WilsonWilson Primm in St. LouisSt Louis, before me the said
WilsonWilson Primm, a Justice of the peace within and for the CountyCounty of St Louis
of St LouisCounty of St Louis in the state of MissouriMissouri, in a certain cause now
depending in the Circuit CourtCircuit Court of St. Louis County aforesaid,
between FrederickFrederick Laboue LaboueFrederick Laboue plaintiff and Pierre Chouteau JrPierre Chouteau Jr
defendant on the part of the plaintiff.
FrancoisFrancois of lawful age being produced sworn and
examined on the part of the plaintiff deposeth and saith.
About the end of July or beginning of August eighteen hundred and thirty twoFrederick LaboueFrederick Laboue the plaintiff was imprisoned
in the common jail of St Louis County upon a charge of murder.
He sent for me and handed me a letter which he requested
me to hand Peter ChouteauPierre Chouteau Jr the defendant. The letter
was read to me by LaboueLaboue it contained a request to the
defendant to settle his plaintiff's account with me in
the same manner as if he were present and to pay over to
me the amount of wages due him. (The letter was handed
by me to Mr ChouteauChouteau the defendant, who after having
read it answered and told me that he had no settlement
of accounts to make with LaboueLaboue and that he would pay him nothing
to pay Thereupon I asked him if LaboueLaboue was not
hired to him - He answered that LaboueLaboue was still hired
to him - I said that LaboueLaboue was hired to him for two
years yet - he answered the he no longer needed Laboue's
Being cross- examined by defendant, deponent says
Question. When you came with the letter from LaboueLaboue and Several
times thereafter to see me; as you have above Stated, were
me to pay me money?
Answer. I was authorized by Labour to settle his account
with you, and to pay to you either the whole
or part of a demand of Francis A against him,
in your hands.
Question. Although I constantly refused to pay any thing to
LaboueLaboue , did you not come to me a short time before LaboueLaboue
was taken to Jefferson CityJefferson City for trial, and enter into
a formal obligation to pay me four hundred dollars on
account of debt ?
Answer. No, I did not_ I told you that LaboueLaboue ,
after his house should be sold and his necessary debts paid
the residue of the money to be applied to the payment
of his debt of Chardon.
Question. After your return from Jefferson CityJefferson City, did you not
come to me and offer me Laboue's house on condition that
I should pay several debts of which you gave me a schedule
and also extinguish Charson's debt?
Answer. On my return from JeffersonJefferson , finding that I could
not sell Laboue's house, I told you that if you would give
me one thousand dollars for it, I would pay you two hundred
dollars on amount of Laboue's debt to Chardon
Sworn to and subscribed before me
this 16th day of April 1834
WilsonWilson Primm J.P.