Frederick Laboue v. Pierre Chouteau Jr.
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Frederick LaboueFrederick Laboue
vs
Pierre ChouteauPierre Chouteau Jr JrPierre Chouteau Jr

And the said Defendant Pierre ChouteauPierre Chouteau Jr
JrPierre Chouteau Jr byGambleArchibald Gamble his Attorney comes and defends the
wrong and injury when & and says he did not
undertake and promise in manner and form as
the said plaintiff hath above thereof complained
against him and of this he puts himself
upon the country

And for further plea in this behalf the
said Defendant says that the said plaintiff ought
not to have and maintain his aforesaid action
against the said defendant because he says
that before and at the time of the commence-
ment of this suit the said plaintiff was
to this defendant and others the partners
of this defendant in the said several supposed
promises and undertakings in the declaration
set forth in the sum of two thousand dollars for
goods wares and merchandise by the said de-
-fendants and his said partners before that time
sold and delivered to the said plaintiff at his spe-
-cial instance and request and also in the further
sum of two thousand dollars for so much money
by the said defendant and his said partners before
that time lent and advanced to and laid
out and expended for the said plaintiff at his said
special instance and request which said sums of
money exceed the damage sustained by the said
plaintiff by reason of the non performance of the said supposed prom
ises and undertakings in the declaration mentioned
and of out of which said sums this defendant is willing
and offers to set off and allow to the said plaintiff the said

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damages which he may have sustained as aforesaid
and this the said defendant is ready to verify wherefore
he prays judgement &

Filed march 23 1833

GambleArchibald Gamble atto


for deft