John Campbell v. Thomas Hanly
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County of St LouisCircuit Court
Circuit CourtCircuit Court


Ss

JohnJohn Campbell CampbellJohn Campbell by his attornies com=
plains of ThomasThomas Hanly HanlyThomas Hanly in a plea of trespass on
the case for that whereas the said defendant
on the ninth day of April eighteen hundred & eighteen at the county aforesaid was indebted
to the plaitniff in the sum of Two hundred and
Forty dollars for so much money before that
time had & received to and for the use of the
plaintiff and being so indebtedin considera
=tion therof the said defendant undertook &
then & there faithfully promise to pay the same
to the plaintiff on request

And also for that afterwards towit on the
ninth day of April eighteen hundred & nine teen at the County of St. LouisCounty of St Louis aforesaid he the
said defendant was indebted to the plaintiff
in the sum of One thousand dollars for
large quantities of furs & before that
time sold & delivered by the plaintiff to him said
defendant & at his special instance & request
and also for large quantities of goods
wares & merchandise before that time sold &
delivered to him said defendant & at his like
special instance &request, and also for the
like sum of money before that time paid
laid out & expanded by the plaintiff to &
for his said defendants use & benefit and at
his special instance request and also for
so much money before that time lent and
advanced by the plaintiff to him said
defendant & at his like instance & request
and

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and being so indebted in consideration thereof
the said defendant then & there undertook &
faithfully promised the plaintiff to pay to
him the aforesaid several sums of money
whenever afterwards he should be there
=unto requested

Nevertheless the said defendant
after requested hath not paid the
aforesaid several sums of money to the plain
tiff nor any part thereof but the same to
him to pay hath hitherto wholly refused &
still doth refuse to the damage of the
plaintiff one thousand Dollars &
Therefore he & by

CarrCarr & Harper


plffs atty
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Territory of MissouriMissouri Ss
County of St louis


The United StatesUnited States of AmericaAmerica
To the Sheriff of S LouisS Louis County
Greeting

We command you to summon
ThomasThomas Hanly HanlyThomas Hanly that he be and appear before
the Judge of our Circuit CourtCircuit Court at the next
term thereof to he held at the town of S LouisS Louis
within and for the county of S LouisS Louis on the first
monday in august next then and there to
answer unto John CampbellJohn Campbell of a plea of
trespass on the case to the damage of said
plaintiff of One thousand Dollars, and have
you then there this writ

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Witness Archibald GambleArchibald Gamble Clerk
of our said court at office this
thirteenth day of July Eighteen hundred & nineteen and of our
Independance the forty fourth

Archd. GambleArchibald Gamble Clerk

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And the said defendant comes & defends the wrong
and injury when & c and says that he did not
undertake and promise in manner & form as the
said plaintiff hath above thereof complained against
him and of this he puts himself upon the country & c

GeyerGeyer

for deft
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and the plaintiff doth likewise

The plaintiff will take notice that the above named de
fendant on the trial of this cause will give in
evidence and insist that the said plaintiff at the time
of the commencement of this suit was and still is indebted
to the defendant in the sum of five thousand dollars, for
diverse goods wares and merchandizes by the said defen
dant before that time sold and deliverd to the said de
fendantat his special instance & request and on an
account stated and that the said defendant will set off
and allow to the said plaintiff on the said trial so much
of the said sum of five thousand dollars so due &
owing from the said plaintiff to the said defendant
against any demand of the said plaintiff to be proved
at the said trail as will be sufficient to satisfy and
discharge such demand and claim a judgment for
the residue according to the form of the statute in
such care made & provided Dated 4th augt 1829

GeyerGeyer

for deft
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No 131
aug term 1819
JohnJohn Campbell CampbellJohn Campbell
vs
ThomasThomas Hanly HanlyThomas Hanly

nor
This is an action of
Let a sum=
mons issue damage
$ 1000

CarrCarr & Harper


plffs atty
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Filed July 13th 1819

A GambleArchibald Gamble Clerk


Plea non & notice
of sett off
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Served this writ
on ThomasThomas Hanly HanlyThomas Hanly
by leaving a copy
with his housekeeper
at his house in
the town of St LouisSt Louis
on this 15th July 1817

John K WalkerJohn K Walker


D Shff
Service & 90
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Territory of MissouriMissouri
County of S LouisCounty of S Louis


ss

The United StatesUnited States of america
To any Judge or Justice of
the Peace of the State ofIllinois IllinoisIllinois

We reposing special trust and
confidence in your integrity and circumspec
-tion do require and command you that you
cause to come before you such persons as
shall be named to you by ThomasThomas Hanly HanlyThomas Hanly his
attorney or agent and them examine upon
their corporal oath to be by you administered
touching their knowledge of any thing that
may relate to a certain matter of controver
sy now pending in our Circuit CourtCircuit Court for
the county of S LouisS Louis wherein JohnJohn Campbell CampbellJohn Campbell
is plaintiff and ThomasThomas Hanly HanlyThomas Hanly is
defendant on the part of the said defendant
and having reduced the said depositions so
taken by you as aforesaid into writing you
are required to send the same together with
this commission enclosed under your seal
to our said Circuit CourtCircuit Court with all con-
venient speed.

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Witness Archibald GambleArchibald Gamble Clerk
of the Cirucit Court at S LouisS Louis
this twenty ninth day of December 1819

Archd GambleArchibald Gamble Clerk

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Territory of MissouriMissouri
County of S LouisCounty of S Louis

Circuit CourtCircuit Court
December Term 1819

JohnJohn Campbell CampbellJohn Campbell
vs
ThomasThomas Hanly HanlyThomas Hanly

On motion of the
Attorney for the defendant it is ruled
that a dedimus issue to any Judge or
Justice of the peace of the State ofIllinois IllinoisIllinois
to take the Depositions of Witnesses to be read
on the trial of the above cause on the part
of the Defendant

A true copy of the rule

Archd GambleArchibald Gamble Clerk

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CampbellCampbell
vs
Hanly

Served Dec 29th 1819

CarrCarr & Harper

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To JohnJohn Campbell CampbellJohn Campbell the above plaintiff
Sir Please to take, notice that on monday the third day
of January next between the hours of nine o clock
A.M. and five o clock P.M. of that day at the house
of ThomasThomas Esq in the town of Miton &
County of MadisonMadison StateIllinois of IllinoisIllinois I shall proceed
to take the depositions of witnesses to be read on
the trial of the above cause on the part of the
defendant at which time and place you can
attend if you wish.

Bates & Farris


Attys for Th. Hanly.

St LouisSt LouisDec. 29th 1819.

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Territory of MissouriMissouri, County of St. LouisCounty of St Louis, sct.

The United StatesUnited States of AmericaAmerica, To the Sheriff of St LouisSt Louis county-Greeting.

You are hereby commanded to summon Joseph VJoseph V Garnier .GarnierJoseph V Garnier
that setting aside all manner of excuse and delay he be and appear in proper person before the Judge of our cir-
cuit court on the forthwith at the town of St. LouisSt Louis,
then there to testify
and the truth to say in a certain matter of controversy now pending in our said
court, wherein JohnJohn Campbell
CampbellJohn Campbell is plaintiff and ThomasThomas Hanly
HanlyThomas Hanly defendant on the part of the
Defendant and have you then there this writ.

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Witness, Archibald GambleArchibald Gamble , Clerk of our said circuit court, at the Town of St. LouisSt Louis,
this 8th day of January in the year of our Lord, one thousand eight hundred and Twenty
and of the Independence of the United StatesUnited States the forty forth.

Archibald GambleArchibald Gamble Clerk

, St. LSt Louis. C.C.
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John CampbellJohn Campbell
vs
Thomas HanlyThomas Hanly

Joseph GarnierJoseph Garnier
forthwith
for Deft.
(Aug 1819No 131)

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Executed on Jos. K. Garnier 8th January 1826

John K WalkerJohn K Walker


D Shff
Service & travel 39 cts
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State ofIllinois IllinoisIllinois
MadisonMadison County


ss

Personally appeared before the
undersigned Benjamin Spencer a Justice
of the peace in and for said county in
conformity with dedimus issued out of the
Circuit Court of the County of St LouisCounty of St Louis in the
Territory of MissouriMissouri directed to any Judge or
Justice of the peace in the state of IllinoisIllinois to
take depositions in a certain suit now pending
in said Circuit CourtCircuit Court between JohnJohn Campbell CampbellJohn Campbell
plaintiff and Thomas HanlyThomas Hanly defendant on
behalf of the defendant ThomasThomas Lippin-
cott who being duly affirmed according to law
deposeth and saith That the said deponant
was in the employ of the said defendant as
clerk and book keeper on the twelfth day of September in the year eighteen hundred and eighteen, that on the said twelfth day of Sep-
tember a settlement of accounts between the
said plaintiff and the said defendant was
made in the books of the said defendant
that in the said account settled on the said
twelfth day of September there was and doth
now appear a credit given to the said plain
tiff for the payment of one hundred and
thirty five dollars which said credit or ac-
knowledgement of the receipt of the said sum
is under date of the ninth day of april in the year eighteen hudndred and eighteen afore
said and that in the said settlement of
accounts between the said plaintiff and the

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said defendants the said sum of One hun-
dred and thirty five dollars was allowed
and deducted besides other credits from
the amount charged to the said plain
tiff on the books of the said defendant, and
that the balance due from the said plain-
tiff to the said defendant on the said
twelfth day of September after deducting
the sum of one hundred and thirty five
dollars appears by the said books to have
been four thousand eight hundred and seven
ty seven dollars which said balance was
settled by a certain order on Stoughton Gantt
for sixteen hundred dollars, two other orders
on ThomasThomas Hempstead HempsteadThomas Hempstead together amounting to
the sum of sixteen hundred dollars and
by the note of the said plaintiff payable
as said deponent beleives, to the said de-
fendant for the sum of thirteen hundred
and twenty seven dollars, besides a keel
valued at the sum of three hundred and fifty
dollars which said several sums were
to the credit of the said plaintiff on the
books of the said defendant. Deponant
further states that he verily beleives an ar-
ticle
of dissolution whereby the said plaintiff
and the said defendant mutually agreed to
dissolve the partnership which had subsisted
between them, was entered into at the time
of the said settlement and that the said
settlement was agreed to by the said plain
tiff The said deponent further states that
that at the time said deponent went into
the employ of the said defendant, the notes
of the KentuckyKentucky Insurance Company could

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not be disposed of to the knowledge of the
said deponent for any valuable consideration
and that the notes of the said Company have
not been considered by the said deponant as
worth any valuable consideration from the
said time of entering into the employ of said
defendant which was on or about the fifteenth day of june in the year eighteen hundred and eighteen until the present time and that
the said deponant was not so well acquainted
with the value of said notes before the said
fifteenth day of june and further the deponent
saith not

Thos. Leppincott

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Affirmed and subscribed before me at the
house of Thomas Leppincott in the Town of Milton
County of MadisonMadison aforesaid this third day of January in the year one thousand eight hundred and twenty as Any my hand and seal

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Benjn J.P.

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Filed January 4th 1820

A GambleArchibald Gamble Clk


A GambleArchibald Gamble


Clerk of the CircuitCircuit Court
ofCircuit Court St Louis
County MissouriCircuit Court