Alexander Guianrd vs. Pierre Chouteau Junior
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Depositions of witness produceed sworn and ex
amined on the second day of march eighteen hundred and thirty six, between the hours of eight
in the forenoon and five in the afternoon of that
day, at the office of WilsonWilson Primm in the City ofCity of St Louis
St LouisCity of St Louis, before me wilson Primm, a Justice of the
peace within and for the county of St LouisSt Louis in the
state of missouri in a certain action now depen
ding in the Circuit CourtCircuit Court of St Louis County
aforesaid, wherein AlexanderAlexander Guinard GuinardAlexander Guinard is plain
tiff and Peter ChouteauPierre Chouteau Jr. is defendant, on
the part of the plaintiff, the said deposi
tions being taken pursuant to the annexed
notice.

HenryHenry of lawful age being produceed
sworn and examined on the part of the plaintiff
deposes and says.


AlexanderAlexander Guinard GuinardAlexander Guinard and myself were engaged
by Mr John in behalf of the American FurMissouri Fur Company
CompanyMissouri Fur Company to go up the MissouriMissouri for them as engages
we left St LouisSt Louis on or about the 9th or 10th of April 1834 in the capicity on the steam boat
in which we proceeded as far as the yellow stone
river, from where we proceeded in a keel boat as far
as the Country of the black feet Indians which is
said to be about two hundred and fifty leagues
distant above the yellow stone river we stopped
at the fort de la in the black feet
Country being the point of our desteration The
plaintiff as I understood was engaged by the
company for eighteen months He went up at
the same time that I did was there all the
time that I was and stated them to St LouisSt Louis
as the same time that I did. I arrived at St LouisSt Louis
about the beginning of september last. GuinardGuinard
the plaintiff was left at the noir at
Roubidoun's establishment from which he came

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to St LouisSt Louis some time after me


During the whole time that we were at the
fort in the black feet Country, Guinard the
plaintiff was in the employment of the
American FurMissouri Fur Company CompanyMissouri Fur Company to whom that fort
belongs and served them well and faith fully
during the whole time that he was in their
service


Understanding that the cause of the present
suit is a claim set up by the defendants against
the plaintiff on account of the loss of some horses
of which he in part had the charge, I will
in a concise manner state the occurrence
whilst at the fort in the black feet country
the plaintiff GuinardGuinard myself, Pierre Chotillon
and another engagesince dead, were sent
by Mr one of the clerks at the fort
to a prairie about two or three miles distant
and out of sight of the fort, for the purpose
of guarding some twenty houses sent there to
be pastured we having been sent for fear
that the black feet Indians would steal the
horses, about fifteen or sixteen
indians appeared coming down
a hill at the base of which the prairie was
in which the horses were grazing
and made signs for as to go to them Chotillon
and the young man since dead accordingly went
to them they asked Chotillon for his gun he
gave it to them and one of them discharged it
in the air Chotillon then took the gun
away from them. In the mean time, having
a rope in my hand I caught a horse and made the best of my
way to the fort for the purpose of procuring
assistance. I informed Mr Culherson the Com
mander at the fort who immedeately started