Ludwell E. Powell vs. Antoine Lamarche
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St. Louis Circuit CourtCircuit Court For July Term 1835
County of St. LouisCounty of St Louis:

Ludwell E. PowellLudwell E Powell by J SpaldingJ Spalding
his attorney complains of Antoine Lamarche
of a plea of trespass on the case upon promises.

For that whereas the said defendant heretofore, to wit: on the
first day of April in the year of our Lord one thousand eight hundred and thirty-five at said county was indebted unto said plaintiff
in the sum of a 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
a 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 a thousand
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 a 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 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.

And whereas also, said defendant afterards, to wit on the day and
year, and at the county last aforesaid, accounted with said plaintiff of, and concerning divers others sums
of money from the said defendant to the said plaintiff before that time due and owing, and then in arrear
and unpaid, and upon such accounting the said defendant was then and there found to be in arrear and
indebted to said plaintiff in the further sum of a thousand
dollars, like lawful money, and being so found in arrear and
indebted, said defendant in consideration thereof, afterwards, to wit: on the day and year last aforesaid, at
said county, undertook, and then and there promised said plaintiff to pay him said last mentioned
sum of money, when he said defendant should be thereto afterwards requested.

Nevertheless, said defendant, although often requested so to do, has not as yet paid
said several sums of money above mentioned, or either or any part of either of them; but to do so hath
refused and still refuses. To the damage of said plaintiff of a thousand
dollars, and therefore he brings his suit, &c.

JJ Spalding SpaldingJ Spalding atty
for for pltf