Frederick Laboue v. Pierre Chouteau Jr.
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In the Circuit CourtCircuit Court
November term 1832

Saint LouisSt Louis County to wit: Frederick LaboueFrederick Laboue com
plains of Pierre ChouteauPierre Chouteau Junior of a plea of trespass
upon the case upon promises: For that whereas hereto
fore to wit on the fifteenth day of June in the year of our Lord one thousand eight hundred & thirty one, at
the County aforesaid, by a certain instrument in writing
(which the plaintiff cannot produce in court, because
the same is in the possession & power of the defendant)
in consideration that the said plaintiff at the special in-
stance & request of the defendant had then & there
engaged & bound himself to serve the American
Fur CompanyMissouri Fur Company (of which company the said defendant
was & is one, & was &is the agent of the said company,
& director of its business & affairs at St LouisSt Louis for the waters
of the MissouriMissouri) for the term of three years from the
said him as a clerk & trader the said defendant undertook & then &
there faithfully promised the said plaintiff to
pay him, yearly & every year during the said
term, the sum of five hundred dollars, and a
fine suit of clothes. And the said plaintiff says
that in pursance of his said obligation, he did immedi
ately enter into the service of the said company (the
defendant being then & now one of the said company)
and served the said company as a clerk & trader for
one whole year then next following of which the
defendant had one notice, yet the defendant

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has not paid to the plaintiff although often
requested so to do, has not paid to the plaintiff
the said sum of five hundered dollars and a fine
suit of clothes or either or any part thereof but
so to do has hitherto wholly neglected refused
& still does neglect & refuse.

And also for that whereas heretofore to wit
on the fifteenth day of June in the year one thousand eight hundred & thirty one at the County aforesaid, in
consideration that the said plaintiff had then & there, at
the special instance request of the defendant engaged
& bound himself to serve the said defendant as
a clerk & trader, in his commerce with the Indians, for the
term of three years the said defendant undertook &
then & there faithfully promised the said plaintiff to
pay him, from year to year, and at the end of every
year he should serve as aforesaid, the sum of five
Hundred Dollars and also pay & deliver to him a suit
of fine clothes. And the said plaintiff avers that, in
pursuance of his said enagagement, he did then & there
enter into the service of the said defendant, and did
serve him as a clerk & trader in his commerce with
the indians for one whole year, of which the defend
ant had notice; yet the said defendant although
often requested, has not paid to the plaintiff the
said sum of five hundred dollars or any part thereof,
nor paid & delivered to him a suit of fine clothes
or any part thereof, but so to do has hitherto wholly
neglated refused, & still does neglect & refuse

And also for that whereas heretofore to wit on