and , nor any or either of them, paid the said sum of money mentioned in said note or any part thereof to said Plaintiffs— But the said and the said Joseph Smith Junior, and have hitherto wholly neglected and refused so to do, and also for that whereas the said heretofore, to wit, on the first day of September A. D. 1837 at in said County of and State of , was indebted to said plaintiffs in the sum of twelve hundred dollars for the work, labor labour care, diligence and attention of them the Plaintiffs by them the said Plaintiffs before that time, done, performed and bestowed, in and about the business of said and for the said and at his special instance and request; and also in the further sum of twelve hundred dollars for divers goods, wares, and merchandise, and other personal property, before th[e]m by said plaintiffs sold and delivered to said and at the like special instance and request of said ; And also in the further sum of twelve hundred dollars for so much money, before then, by said plaintiffs lent, and advanced to, and paid, laid out and expended for said and at his like special–instance and request; And also in the further sum of twelve hundred dollars for others moneys before then by said had and received to and for the use of said plaintiffs; And being so indebted [t]he said , in consideration thereof, afterwards, to wit on the same day and year last aforesaid at aforesaid, undertook and then and there faithfully promised the said plaintiffs to pay them, the said several sums of money in this count mentioned, when he the said should be thereunto afterwards requested; and whereas, also afterwards, to wit, on the first day of October A. D. 1837 at , in said , the said accounted with the said plaintiffs of and concerning divers other Sums of money for the said to the said plaintiffs before that time due and owing and then in arrear and unpaid, and upon Such accounting the said was then and then found, to be in arrear and indebted to said plaintiffs in the further sum of twelve hundred dollars and being so found in arrear and indebted he the said in consideration thereof afterwards to wit, on the same day and year last aforesaid at aforesaid undertook and then and there faithfully promised the said plaintiffs to pay them the said further sum of twelve hundred dollars in this count mentioned where he the said should be thereunto afterwards requested. Yet the said his said several promises and undertakings in no wise regarding but contriving &c. has 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 plaintiffs (although often requested &c.:) But the said to pay the said plaintiffs the same has hitherto wholly neglected and refused and still does neglect and refuse to the damage of the said plaintiffs of twelve hundred dollars, and therefore they sue &c.