St LouisSaint Louis County to wit, HughHugh RichardRichard by his attorney complains of Benjamin O'FallonBenjamin Benjamin O'FallonO Benjamin O'FallonFallen of a plea of trespass on the case upon promises, To no the said Benjamin O'FallonBenjamin O Fallen heretofore towit, on the first day of august in the year of our Lord one thousand eight hundred and sixteen at the County aforesaid, in consideration that the said HughHugh RichardRichard at the special instance and request of him the said Benjamin O'FallonBenjamin O Fallen would engage himself to and go along with the said Benjamin O'FallonBenjamin O Fallen in the capacity of clerk on a certain trading voyage which the said BenjaminBenjamin, then starting on up the river MississippiMississippi, and its tributary, streams and that the said HughHugh during the said voyage would perform the duties of a clerk to and under, the said BenjaminBenjamin, to the said Benjanium O Fallen undertook and faithfully promised the said HughHugh RichardsRichards to allow and pay the said HughHugh for his service in the aforesaid capacity during the said voyage at the rate and proportion of four hundred dollars a year And the said HughHugh RichardRichard in fact saith that confiding, in the aforesaid promise and undertaking of the said BenjaminBenjamin, he did engage himself to and go along with

the said Benjamin O. Fallen in the capacity of clerk on the said trading voyage which the said BenjaminBenjamin was then starting on up the river, MississippiMississippi, and its tributary streams to wit all the aforesaid and the said HughHugh that he did during the said voyage perform the duties of clerk to and under the said Benjamin O'FallonBenjamin O Benjamin O'FallonFallen and the said HughHugh further in fact saith that he was in the service of the said BenjaminBenjamin, on the said voyage for a long time towit for ten months Nevertheless, the said Benjamin O'FallonBenjamin Benjamin O'FallonO Fallen not regarding his aforesaid promise and undertaking did not and has not allowed and payed the said HughHugh RichardRichard for his services in the capacity aforesaid during the time that the said HughHugh was in the service of the said BenjaminBenjamin as aforesaid at the rate and proportion of four hundred dollars a year nor hath the said BenjaminBenjamin, as yet paid the said HughHugh any thing for his aforesaid services Bat so to do the often requested hath hitherto, wholly refused and still doth refuse

And for that whereas also the said Benjamin O'FallonBenjamin O Fallen afterward towit on the day an d year aforesaid at the county aforesaid in consideration that the said HughHugh RichardRichard at the like special instance and request of the said BenjaminBenjamin would go along with and serve him the said BenjaminBenjamin in the capacity of clerk on certain trading voyage up the river MississippiMississippi, and its tributary, streams he the said Benjamin O'FallonBenjamin O Fallen undertook and then and there faithfully promised the said HughHugh

to allow and pay him for the time that he should serve him the said BenjaminBenjamin as last aforesaid at the rate and proportion of four hundred dollars a year and the said HughHugh RichardsRichards in fact saith that confiding in the said last mentioned, promise and undertaking of him the said Benjanium he did go a long with and serve the said Benjamin O'FallonBenjamin Benjamin O'FallonO Fallon in the capacity of clerk on certain trading voyages up the river MississippiMississippi and its tributary streams for a long time towit for nine months towit at the county aforesaid the said Benjamin O'FallonBenjamin, Benjamin O'FallonO, Benjamin O'FallonFallon not regarding his said last men tioned promise and undertaking would not and did not allow and pay to the said HughHugh RichardsRichards for the time he was, in the service of the said BenjaminBenjamin, as last aforesaid at the rate and propostion of four hundred dollars a year nor hath the said BenjaminBenjamin as yet paid the said HughHugh any thing, therefor But so to do although often requested hath hitherto wholly refused and still doth refuse

And for that whereas also the said Benjamin O'FallonBenjamin, Benjamin O'FallonO Fallen afterwards towit on the day and year last aforesaid at the county aforesaid in consideration that the said HughHugh RichardRichard at the like special instance and request of the said Benjanium would serve the said Benjamin O'FallonBenjamin, Benjamin O'FallonO Fallen in the capacity of clerk during and until the completion of a certain trading voyage which the said BenjaminBenjamin was then about making up the river MississippiMississippi, and

its tributary, streams he the said Benjamin O'FallonBenjamin O Fallon undertook and then and there faithfully promised that said HughHugh to pay him therefor four hundred dollars And the said HughHugh RichardRichard in fact saith that confiding in the said last mentioned promise and undertaking of the said BenjaminBenjamin he did serve the said BenjaminBenjamin in the capacity, of clerk during and until the completion of the said last mentioned voyage towit at the county aforesaid Nevertheless, the said Benjamin O'FallonBenjamin O Fallen not regarding his said last promise and undertaking hath not as yet paid the said HughHugh the said sum of four hundred dollars or any past thereof But the same to pay hath hitherto, wholly refused and still doth refuse

And for that whereas also afterward towit on the first day of august in the year of our Lord one thousand eight hundred and seven teen at the county aforesaid the said Benjamin O FallonO Fallon was, indebted to the said HughHugh RichardRichard in the sum of other four hundred dollars for the work and labor care and diligence, of the said HughHugh before that time done and promised, to and for the said BenjaminBenjamin and at his like special instance and request, and being so indebted he the said BenjaminBenjamin, in consideration, thereof afterward towit on the day and year last aforesaid at the county aforesaid undertook and faithfully

promised the said HughHugh to pay him the said last mentioned sum of money when he the said BenjaminBenjamin should be thereto afterwards requested Nevertheless, the said Benjamin O'FallonBenjamin Benjamin O'FallonO Fallen not regarding his last mentioned promise and undertaking hath not as yet paid the said HughHugh RichardsRichards the said last mentioned sum of money or any part thereof but the same to pay hath hitherto, wholly neglected and refused and still doth neglect and refuse to the damage of the said HughHugh RichardRichard four hundred dollars and therefore he brings his and suit,

This summons was excuted on the 12th day of Augt 1817 by reading to Benjamin O'FallonBenjamin O Fallon in the Town of S LouisS Louis

This is an action of Damage $ 400 let a

we command you to summon Benjamin O'FallonBenjamin, Benjamin O'FallonO Fallon if he may be found, within your bailiwick, that he be and appear before the judge of our Circuit CourtCircuit Court to be held at the Court house in the Town of St LouisSt Louis within and for the county of St LouisSt Louis on the second monday of October next then, there to any unto HughHugh RichardRichard of a plea of trespass, the upon promises, to the damages of the said hundred Dollars, and have you then

You are hereby commanded to summon TheodoreTheodore Haut, that setting aside all manner of execuse and delay he be and appear in proper person before the Judge of our Circuit court on the 14th day of February 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 HughHugh RichardsRichards, is plaintiff, and Benjamin O'FallonBenjamin O Fallen, defendant, on the part of the plaintiff and have you then there this writ.

75251820

174148

Executed

333380331.79

St Louis County for TheodoreTheodore Haut, February 14th 1818

You are hereby commanded to summon Thomas Handly, that setting aside all manner of excuse and delay he be and appear in proper person before the judge of our Circuit court on the 18th day of Febry 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 HughHugh RichardsRichards, is plaintiff, and BenjaminBenj O FallonO Fallon, defendant, on the part of the Defendant and have you then there this writ.

sub

Executed

You are hereby commanded to summon Lilburn, W Boggs, that setting aside all manner of excuse and delay he be and appear in proper person before the judge of our Circuit court on the 18th day of Febry 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 HughHugh RichardsRichards, is plaintiff, and BenjaminBenj. O FallonO Fallon, defendant, on the part of the Defdt and have you then there this writ.

Executed

sub