Thomas L. Smith vs. Pierre Chouteau Jr.
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St. Louis Circuit CourtCircuit CourtFor the March Term 1834

CountyCounty of St Louis of St. LouisCounty of St Louisss: Thomas L. SmithThomas L Smith by John F. DarbyJohn F Darby
his attorney complains of Pierre ChouteauPierre Chouteau Junior of a plea
of trespass on the case upon promises.
For that whereas the said defendant heretofore, to wit: on the first day of March in the year of our Lord one thousand eight hundred and thirty-four at said county was indebted unto said plaintiff in the
same of two thousand dollars
for the work and labor, care and diligence of the said plaintiff by
the said plaintiff before that time done, performed, and bestowed, in and about the business of the said defendant and for
the said defendant and at his special instance and request; and also in the further sum of two thousand
dollars, of like lawful money, for divers
goods, wares and merchandise, by the said plaintiff before that time sold and delivered to the said defendant and at his
like special instance and request; and also in the further sum of two thousand dollars
of like lawful money, for money by the said plaintiff before that time lent and advanced to, and paid, laid out and expended,
for the said defendant and at his like special instance and request; and also in the further sum of two
thousand dollars, of like lawful money,
for other money by the said defendant before that time had and received to and for the use of the said plaintiff; and also
in the further sum of two thousand dollars
for so much money by and from said defendant to
said plaintiff before then due and owing and then in arrear and unpaid for and upon an account stated between them: And
being so indebted, the said defendant in consideration thereof, afterwards, to wit: on the day aforesaid, at the place
aforesaid, undertook, and then and there faithfully promised the said plaintiff to pay him the said several sums of
money, in this count mentioned, when the said defendant should be thereunto afterwards requested: nevertheless the said
defendant not regarding the said promises and undertakings, although often requested so to do, hath not paid to the
said plaintiff the said sums of money of either of them, or any part of either of them. Whereby the said plaintiff
hath sustained damage in the sum of two thousand dollars:
wherefore he brings suit, &c.

DarbyDarby & SpaldingSpalding
plff Attorneys