Joseph Beaudoin v. John P. Cabanne and Antoine Chenie
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Territory of MissouriMissouri
County of St LouisCounty of St Louis

In the Circuit CourtCircuit Court
October Term 1817

Joseph BeaudoinJoseph Beaudoin complains
of John Cabanne, and AntoineAntoine Chenie
late merchants and traders trading and
doing business under the name title
and firm of CabanneCabanne and Chenie,
of a plea of trespass on the case
for that whereas on the twenty fifth day
of august in the year of our lord one
thousand eight hundred and fifteen
at the town of St LouisSt Louis in the county
of St LouisSt Louis aforesaid and within the [ Juris-dition ] of this court, in consideration
that the said plaintiff at the special
instance and request of them said Defen-
dants would enter their service in the
capacity of their clerk and go into the
MissouriMissouri river and its dependencies, on
a trading voyage and expedition of
them said defendants, there on foot, and
to continue and last from that time
untill the month of June there next
following at which last said time it was
to expire and and for and during
that voyage and trading expedition
take due care of sell trade and
such goods and
as he to his case
to the best advantage and benefit, of them
said Defendants, and obey this lawfull
commands and and attend to there
interests, they said Defendants undertook
and faithfully promised to the said
plaintiff to pay him the sum of three
hundred Dollars in June next follow-
ing to wit at the town and county aforesaid

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and within the jurisdiction aforesaid and
the said plaintiff avows that confiding in
the said promise and undertaking of them
said Defendants did immediately thereafter
enter the service of the said defendants in the
capacity of their Clerk and did go into the
MissouriMissouri river and its dependencies, in their
[ imploy ] for and during the said expidition,
and voyage and untill the expiration,
ending thereof in June following did continue
in their employ as aforesaid and did for
and during that time take due care of bill
dispose and barter, to the best advantage
and benefit of the said defendants such
goods and Merchandizes, as were committed
and entrusted to him for that purpose
and did obey the lawfull commands
and did and attend to the interests of
the said defendants as aforesaid yet the
said defendants not regarding their said
promise and undertaking atthough often
requested so to do have not paid
to him the said plaintiff the said sum
of money or any part thereof but have
wholly neglected and refused, and still
do wholly neglect and refuse do to do so
the damage of the said plaintiff of
five hundred dollars wherefore he sues
and whereas the said defendants on the
first day of august in the year of our lord one thousand eight hundred and sixteen
at the town county and within the Juris-
diction aforesaid were indebted to the
said plaintiffs in the further sum of three hundred
Dollars lawfull money of the united states

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for the work and labour care and dilligence
of the said plaintiff by him before that
time done performed, and bestowed as the
Clerk and agent of the said Defendants
in and about the selling and disposing
of divers, other goods wares and merchandizes,
of the said Defendants, and in and about
the other business of the said defendants
at their special instance and request and
being so indebted they said Defendants
in consideration thereof afterwards to wit
on the day and year last aforesaid
at the place and within the jurisdiction
last aforesaid undertook and faithfully
promised to the said plaintiff to pay him
the said last mentioned sum of money
when they when they the, said defendants should be
thereunto afterwards requested- and whereas
afterwards to wit on the day and year at the
place and within jurisdiction last aforesaid
in consideration that the said plaintiff
at the like, special instance and request of
of the said defendants had before that time
done performed and bestowed his work and labour,
care and dilligence as the clerk and agent
of the said defendants, in and about selling
and disposing of divers other goods wares, and
merchandizes of them said defendants and in
and, about the other business of the said defendants
and for the said defendants at their special
instance and request, they said defendanst
undertook and then and there faithfully promised
the said plaintiff to pay him so money
as he therefore reasonably deserved to have
where they said defendants should be thereunto
afterwards requested and the said plaintiff avows
that he therefore reasonably deserved to have
of the said defendants the further sum of
three hundred dollars of like lawfull money

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to wit at the place and within the jurisdiction aforesaid
whereof the said defendants afterwards to wit on
the day and year last aforesaid there had notice
yet the said defendants although often requested
have not paid the said sum of money on
any of there to said plaintiff untto pay the
same or any of them to him, have hitertoto ever
and yet do refuse, wherefore the said plaintiff
saith he is injured and hath sustained damage
to the value of five hundred Dollars
wherefore he does &c.

Cha LucasLucas
Atto. for Plff

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No. 70-

St Louis County
Circuit CourtCircuit Court
October Term 1817

Joseph BeaudoinJoseph Beaudoin
vs
John C Cabbanne
Antoine Chenie
Declaration in

> Damage $ 5 00-

This is an action of
Issue a
summons, in a plea
of Tresspass on the
case Damage $ 500

Cha LucasLucas
Atto. PP Leduc . Q.

M. P. LeducP Leduc Esq
Clerk &c.

filed sept 13th 1817
(sep 18) A. S. M. GirkM Girk

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Executed this writ within named
Defendants - acknowledging the service
of the
same and informing them of
the contents - in the Town & CountyCounty of Saint Louis
of Saint LouisCounty of Saint Louis. september 13th 1817

A. V. CarrCarr Dshff
for JW ThompsonThompson Shff

2 service $ 1.20
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AntoineAntoine Chenie &
John P. CabanneJohn P Cabanne
ads
Joseph BeaudoinJoseph Beaudoin

And the said AntoineAntoine Chenie & John PJohn P . Caban-
ne the defendants by their attorney come & defend the wrong
& injury when &c. and say that the afterward JosephJoseph Beau-
doin the plaintiff is dead and was dead al & before the
bringing of this suit had, at the county of St LouisSt Louis afore
said & within the jurisdiction, of this court and this
they are ready to verify - wherefore the said Antoine
& John P. the defendants pray judgment of the said
plaintiffs writ and that the same may be quashed &
abated &c.

CarrCarr , atty

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In. C. CabanneCabanne being duly sworn saith that
he is one of the defendants need in this case and
that the plea herein above pleaded is true in
substance & fact

Cabenn H

Sworn to and subscribed
this 18th october 1817

A. P. Mc. Girk DClk for
M. P. LedueM P Ledue Clk

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Chenie & CabanneCabanne
ads
Joseph BeaudoinJoseph Beaudoin
plea

filed october 18th 1817.

M P. LeducP Leduc Clk
By A. P. Mc. Girk

CarrCarr Atty

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Territory of MissouriMissouri
County of St LouisCounty of St Louis
Ss

The united
of AmericaAmerica to the
Sheriff of said County ... Greeting

We command you to summon JohnJohn P Cabbane
P CabbanneJohn P Cabbane and AntoineAntoine Chenie take
merchants and Traders trading and doing
business under the name style and firm
of Cabbanne & Chenie that they be and
appear before our Circuit CourtCircuit Court to be held
at the Town of St LouisSt Louis within and for
the county of St LouisSt Louis before our Judge
thereof on the second monday of october
next then there to answer unto JosephJoseph Beaudoin
BeaudoinJoseph Beaudoin of a plea of trespass on the
case to the damage of the said JosephJoseph
five hundred dollars and have you then,
there this writ

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Witness Mc Psedue Clerk M P LeducP Leduc ,
said court at St LouisSt Louis this thirteenth day of september in the year eighteen hundred and seventeen and of
an Independence the forty
second

Anowf. Mc. Girk Dbft
M. P. LedueM P Ledue Clerk

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