John N. Lavillebeuvre and William D. Walton v. Peter Powell and Joseph Powell
View original image: Page  006
[missing figure]

and For that, whereas, the said defendants heretofore, to wit: on the
first day of october in the year of our Lord one thousand eight hundred and thirty five at said county were indebted unto said plaintiffs in the
sum of three thousand
dollars, for the work and labor, care and diligence of the said plaintiffs by the said plaintiffs before that time done,
performed, and bestowed in and about the business of the said defendants and for the said defendants and at their
special instance and request: And Also, in the further sum of three thousand
dollars, of like lawful money, for divers goods, wares and merchandise, by the said
plaintiffs before that time sold and delivered to the said defendants and at their like special instance and request:
And Also, in the further sum of three thousand
dollars, of like lawful money, for money by the said plaintiffs before that time lent
and advanced to, and paid, laid out and expended, for the said defendants and at their like special instance and
request: And Also, in the further sum of three thousand
dollars, of like lawful money, for other money by the said defendants before that time had and received to and for the use
of the said plaintiffs; and being so indebted, the said defendants, in consideration thereof, afterwards, to-wit: on the
day aforesaid, at the place aforesaid, undertook, and then and there faithfully promised the said plaintiffs to pay them
the said several sums of money, in this count mentioned, when the said defendants should be thereunto afterwards requested.

And whereas, also, said defendant afterwards, to-wit: on the day and year, and at the county last afore-
said, accounted with said plaintiffs of, and concerning divers other sums of money from the said defendants to the said
plaintiffs before that time due and owing, and then in arrear and unpaid, and upon such accounting the said defendants were
then and there found in arrear and indebted to the said plaintiffs in the further sum of three thousand
dollars, like lawful money, and being
so found in arrear and indebted, said defendants in consideration thereof, afterwards, to-wit, on the day and year last
aforesaid, at said county, undertook, and then and there promised said plaintiffs to pay them said last mentioned
sum of money, when they said defendants should be thereto afterwards requested.

Nevertheless, said defendants, although often requested to do so, have not as yet paid said several sums of
money above mentioned, or either or any part of either of them; or kept their said agreements but to do so have refused, and still refuse: to the damage
of said plaintiffs of three thousand
dollars, and therefore they bring their suit &c

J. SpaldingJ Spalding
atty for plffs