& Joseph Smith Jr (the of said having returned not found as to against whom process was also issued in this cause) for that whereas the said defendants and the said at in said on the first day of October A. D. 1837 were partners in trade under the name and firm of Rigdon Smith & Cowdery and so being partners as aforesaid on the day and year aforesaid at aforesaid were indebted to the in the sum of one thousand dollars for the labor work care diligence and attention of him the said by him the said before that time done performed and bestowed in and about the business of the said defendants and the said and at their special instance and request— and also in the further sum of one thousand dollars for divers goods wares and merchandize before that time sold and delivered to said defendants and the said and at their like special instance and request;— and also in the further sum of one thousand dollars for so much money before that time lent and advanced to and paid laid out and expended for said defendants and said and at their like special instance and request; and also in the further sum of one thousand dollars for other money by said defendants and the said before then had and received to and for the use of the said — and being so indebted they the said defendant and the said partners as aforesaid on the day and year last aforesaid at aforesaid undertook and then and there faithfully promised the to pay to him the said several sums of money in this declaration mentioned. Yet the said defendants and the said their said promises and undertakings in no wise regarding have not as yet paid the said several sums of money in this declaration mentioned or any or either of them or any part thereof to the said although often requested and demanded but the said defendant and the said to pay the same have hitherto wholly neglected and refused, to the damage of the fifteen hundred dollars and therefore he sues &c