Thomas L. Smith vs. Pierre Chouteau Jr.
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Depositions of witnesses produced, sworn and examined on the
twenty first day of March eighteen hundred thirty four, between
the hours of eight in the forenoon and five in the afternoon of that
day at the office of WilsonWilson Primm a Justice of the peace in the
City of St LouisSt Louis State of MissouriMissouri before me the said WilsonWilson Primm
in a certain cause now depending in the St Louis Circuit CourtCircuit Court
between ThomasThomas . S Smith plaintiff an Peter ChouteauPierre Chouteau Jr
defendant on the part of the plaintiff.

David.E.JacksonJackson , having against taking
an oath being solemnly affirmed, declares and says:

I am acquainted with Thomas L.Smith the plaintiff and
became acquainted with him, in the spring I think of eighteen hundred and thirty two at Thaos in the Territory of New MexicoMexico, some time
after he and his party were robbed by the Indians. Mr SmithSmith
was then preparing to take another hunting expedition among
the mountains. The departed on that expedition and I did
not see him from that time until eight or nine days since
at this City.

I knew HenryHenry Vandenberg who was formerly in the
employment of the American Fur Compamy. I have Seen
him often in the mountains engaged in trading & trapping
It was a part of his business to buy beaver & furs as well
from the whites as from the Indians, and I know that
he did buy fur from whites as well as indians.

D E JacksonJackson

Sworn to and subscribed before me this 21st March AD. 1834

WilsonWilson Primm Justice of the peace