Bernard G. Farrar by his attorney
Complains of JohnJohn Newman NewmanJohn Newman Administrator administrator
of all and singular the goods and chattels
rights and credits of DanielDaniel McGurrin McGurrinDaniel McGurrin deceased
at the time of his death who died intestate of a plea of trespass on the case for
that whereas the said DanielDaniel in his lifetime to wit
on the first day of May in the year one thousand
eight hundred and thirty at St. LouisSt Louisto wit at
the county aforesaid was indebted to the said plain
tiff in the sum of three hundred dollars for the
work and labor, care and diligence, % attendance
at the said plaintiff by him the said plaintiff
before that time done, performed, and bestowed as
a surgeon and physician for the said DanielDaniel &
at his special instance and request in and about
the healing and curing at the said DanielDaniel of divers
diseases, disorders and curing under which the said
saidDanielDaniel had before then labored and languished
and for divese medicines and other necessary things
before that time found, provided, administered, delivered
and applied by the said plaintiff on those occasions
for the said DanielDaniel and at his like special instance
and request and being so indebted he the said DanielDaniel
dividing his lifetime afterwards towit on the day and year last
aforesaid at the County aforesaid in consideration
thereof undertook and then and there faithfully pro
mised the said plaintiff to pay him the said sum
of five hundred dollars when he the said DanielDaniel
should be thereunto afterwards requested. Nevertheless

the said Dainel in his lifetime and the said John NewmanJohn Newman
Administrator as aforesaid, after the death of the
said DanielDaniel not regarding the said promise and
undertaking of the said DanielDaniel have not nor hath
either of them as yet paid the said sum of three hundred
dollars or any part thereof to the said plaintiff
although after requested so to do but to pay the same or
any part thereof to the said plaintiff, the said DanielDaniel
in his lifetime wholly refused, and the said John NewmanJohn Newman
Administrator as aforesaid hath ever since the
death of said DanielDaniel hitherto wholly refused, and
state refuses so to do. to the damage of said plaintiff
of Three hundred dollars. and therefore he brings
his suit &c.