for
By due in H E Summons
accept this draft 26th March 1829
at 4 months 500.00

paid 250 00

due 250.00

By due on Accept. 18th Apl. 1829 6 months 233.70

,, Claimd by them for on 200 00

683 70

We Labeaumin & $1570 12

19 apr 1832

the amount of fifteen
Hundred and seventy dollars twelve and half
it being the balance due

H. C. SimmonsSimmons
ME acknowledged

P. Labeaumin

HezekiahHezekiah C. Sriumons (who sues to the use of
JohnJohn Newman NewmanJohn Newman William KWilliam K Rule RuleWilliam K Rule Edward Walsh
as TrusteesTrustees of said Sriumons, for the benefit of the creditors
of said Sriumons) complains of PierrePierre A Lebeaume APierre A Lebeaume LebeaumePierre A Lebeaume
in custody of a plea of trespass on the case on
. For that whereas the said Defendants
heretofore to wit on the first day of July in the year Eighteen hundred and thirty, at the county
aforesaid was indebted to the said Plaintiff in the
sum of four thousand dollars lawful money for
divers good wares and merchandize by the said
plaintiff before that time sold and delivered to
the said Defendant, and at his special insistence and
request; and living so indebted he the said Defendant
in consideration there of afterwards, to wit another
day and year last aforesaid, at the county aforesaid
undertook & then and there faithfully for
the said plaintiff to pay him the said sum of money
when he the said defendant should be thereunto
afterwards requested. And whereas also the said
Defendant afterwards to wit, on the day and year
last aforesaid, at the county aforesaid, accounted
with said Plaintiff of and concerning chooses
other sums of money from the said Defendant to
the said Plaintiff before that time due and owing
and there in arrear and unpaid and upon such
accounting the said Defendant was then and there
found to be in arear and indebted to the said
Plaintiff in the further sum of three thousand

dollars of like lawful money and bring so found
in arrear and indebited he the said Defendant in con
sideration thereof afterwards to wit another day
and year last aforesaid, at the county aforesaid,
undertook and then and there faithfully promised
the said Plaintiff to pay him the said last mentioned
sum of money when he the said Defendants
should be thereunto afterwards requested.

Nevertheless the said Defendants not regarding
his said several promises and undertakings truth
contraversy and fraudulently intending to deceive
and defraud the said Plaintiff in this behalf
hath not as yet paid sum the said several
sums of money or any neither of them or any
part thereof to the said Plaintiff who sues to the
use aforesaid often requested to so do.)
But to the said Defendant to pay him the same
hath hitherto wholly neglected and refused
and still doth neglect and refuse. To the damage
five thousand dollars and therefore of the
said Plaintiff, who sues to the use aforesaid,
of five thousand dollars and therefore he should.

This day John NewmanJohn Newman personally appeared
before me Archibald GambleArchibald Gamble clerk of the circuit court for the
county of St. LouisSt Louis and being by me first duly sworn, upon his
oath deposeth and Saith, that HezekiahHezekiah C. SimmonsSimmons the plaintiffs
in the foregoing declaration, hath now a real,
and un satisfied cause of action against Pierre APierre A Lebeaume
LebeaumePierre A Lebeaume the defendant in said declaration, which
is the same cause of action set in the above
declaration and amounts to the sum of two
thousand dollars, and upwards and this affiant further says that
he is informed and verily believes that the said Defendant
Lbeaume, is now engaged in disposing of all of his property
in the State of MissouriMissouri, and is now preparing to secretly
leave the State of MissouriMissouri, in a few days. And this affiant
further says that he virely believes that the said plaintiff
will be in danger of losing his said debt unless the said
Defendant Lebeaume be held to bail

this affidavit it is ordered that
a issued and the defendant PierrePierre A Lebeaume
APierre A Lebeaume LebeaumePierre A Lebeaume he held to bail in the sum
of two thousand five hundred dollars

Executed this writ on Pierre A LabeaumePierre A Labeaume on the 25th day of September 1830 in
the county of St. LouisSt Louis by giving to him the writ and declaration to read
and taking the body of the said Pierre A. Lebeaume in to custody he the
said LabeaumeLabeaume being afterwards discharged on the same day by MaryMary
P Le due a justice of the county court for the county of St. LouisSt Louis under
the Laws of this State. The said LabeaumeLabeaume being at the
time in custody under an execution in favor of ThomasThomas
to the use of Scott & Rule against Pierre A LabeaumePierre A Labeaume & Charles D.
St. Vrain the warrant of said here with Returned

Service. $1.00

HezekiahHezekiah C. SimmonsSimmons &
vs Declaration
Pierre A LabeaumePierre A Labeaume

filed Septr 24th 1830.
A GambleArchibald Gamble Clk

This is an action of trespass on the
case on promises. $5000
On the written affidavit
a

We command you to take Peirre
A Labeaume if he may be found in your County
and him safe by so that you may have his
body before the judge of our Circuit CourtCircuit Court at
the next term thereof to be held at the city of
St. LouisSt Louiswithin and for the County of St. LouisCounty of St Louis
on the fourth Monday of November next then
and there to answerunto Hezekiah A Simmons
of a plea of (who sues to the use of JohnJohn Newman NewmanJohn Newman
William Rule & Edward Walsh as TrusteesTrustees of said
Summons for the of his creditors of a
file of trespass on the case upon promises to the
damage of said plaintiff of five Thousand
dollars and how you then there this writ

And now at this
day comes the said Peirre A Labeaume by
BentBent his attorney and says he did not under
take and promise in manner and form as the
said SimmonsSimmons , the plaintiff, hath above thereof
in declaring alledged and of this he puts himself
duly upon our County &c

BentBent
for dft

Submission and judgment for $1870 12 Book 6 page 315

HezekiahHezekiah C SimmonsSimmons to writ
vs
Peirre A Labeaume
ads Plea
H C SimmonsSimmons trespass

You are hereby commanded to summon Louis BompartLouis Bompart and Richard Atkinson
that setting aside all manner of excuse and delay, they be and appear in proper person before the
Judge of our Circuit CourtCircuit Court , on the 29th day of Marchnext at the
City of St. LouisCity of St Louis, then and there to testify and the truth to say in a certain matter of controversy now
pending in our said Court, wherein HezekiahHezekiah C SimmonsSimmons to use of is
plaintiff, and PierrePierre A Labeaume A LabeaumePierre A Labeaume is defendant,
on the part of the plaintiff; and have you then there this writ.

Served this
writ an LouisLouis Bompart
BompartLouis Bompart on the
29 July 1832
R Atkinson in wrt
are found in
my County

Walker Shff

50.5

12 1/2

$ 62 1/2

H.C SimmonsSimmons to
vs
PierrePierre A Labeaume A LabeaumePierre A Labeaume

for
Louis BompartLouis Bompart
Richard Atkinson