Thomas L. Smith vs. Pierre Chouteau Jr.
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Depositions of witnesses, produced sworn and examined
on the fifteenth day of March eighteen hundred and thirty four
between the hours of seven 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 Thomas L SmithThomas L Smith
plaintiff and PierrePierre Chouteau ChouteauPierre Chouteau Junior defendant on the
part of the plaintiff.

ManuelManuel Alvarez, of lawful age being produceed sworn and
examined on the part of the plaintiff deposes and says:
in the month of September eighteen hundred and thirty one
I was in the employment of the American Fur CompanyMissouri Fur Company . I was
sent from Yellow Stone River when there was a establishment of
the Company, to the mountains where the Company had
a party of men under the Charge of Mr HenryHenry
vanderburg, for the purpose of serving as Clerk. In
posting up the books I observed that nearly all the men
were indebted, but that Mr SmithSmith the plaintiff had a
credit on the books of fourteen hundred dollars or there
abouts. Thinking that perhaps there might be error, I
inquired of Mr Vanderberg and was informed by him
that the credit was correct, it being for beaver and
other articles which said SmithSmith had sold the Company
and which were at the establishment on the Yellow Stone
SmithSmith left the camp in the mountains in the same
month that I arrived there, with a party of men to go
and hunt for the Company. The amount due Mr SmithSmith

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had not been diminished, and was the same when I left
the party establishment in, the mountains that it was when I
went to it, with the exception of one or two hundred
dollars for which he had received value. The beaver
& other things which SmithSmith sold the company and for which
he had the Credit before mentioned on their books, were
sold by him before he was employed by them and had
been acquired by him when acting for himself. That
beaver was at the Yellow Stone Establishement when I
was there before I went to the mountains, and as all
beaver is sent from there to St LouisSt Louis, the presumption
is that the beaver sold by SmithSmith was also sent to St LouisSt Louis
The books of which I have spoken and in which Mr SmithSmith
was credited as aforesaid, belonged to the American
Fur CompanyMissouri Fur Company of which Peter ChouteauPierre Chouteau Junior was a
partner and agent here at St LouisSt Louis

About a year after the time above mentioned
Vanderberg was killed in The mountains. The books of
which I have spoken were left by me about the second
of last August in the hands of Mr Fontenelle at the
Camp in the mountains. When I went there as before
Stated, Mr SmithSmith was then also. I never saw SmithSmith
after he left the camp for the purpose of hunting as
aforesaid until this winter. Some of the men who
had gone with him came back to camp in December
of the same year, their Expedition having been frustrated
by the Indians who stole their horses. I dont know
that any payment of the amount due SmithSmith was ever
paid made to him Otherwise than as above stated.