Three Rivers
Hudson~Mohawk~Schoharie
History From America's Most Famous Valleys
1830 Complaint Adam W. Walradt, Defendant
Montgomery County Clerk
Of the term of June in the year of our Lord one thousand eight hundred and thirty 1830)
Montgomery County and Daniel Smith the plaintiff in this suit complains of Adam W. Walradt the defendant in the same.
For that whereas the said plaintiff is a good true and honest citizen of the State of New York and never was guilty of any of the crimes hereinafter laid to his charge. Never the less the said defendant well knowing the premises but containing and maliciously intending to misuse and defame and slander the said plaintiff in his good name to wit on the first day of January in the year of our Lord one thousand eight hundred and thirty at the town of Oppenheim in the County of Montgomery in a certain discourse which the said defendant then and there had with diverse good and worthy citizens of this state of and concerning the said plaintiff and of and concerning an order for the payment of money which he the said defandant alleged had been forged by the said plaintiff. These false scandalous and malicious words did openly speak utter publish and disclose to wit: “he (the said plaintiff meaning) has forged an order, he (the said plaintiff again meaning) has forged an order and put William Aldridges name to an order and Christian Klock and I'll (said defandant meaning) have the little fellow (meaning the said plaintiff) in Auburn for it”. Meaning thereby that the said plaintiff has been guilty of forging an order for the payment of money and that he intended to have the said plaintiff idicted and sent to Auburn to the State Prison for it and that he was a dangerous citizen and unworthy to be trusted and of a malicious disposition. And whereas the said defendant of his further malice towards the said plaintiff afterwards to wit on the said first day January in the year and at the place aforesaid in a certain other discourse which the said defendant then and there with diverse good people of and concerning the said plaintiff and of and concerning an order for the payment of money which he the said defendant alleged had been forged by the said plaintiff did falsely and maliciously and openly and publicly speak utter publish and in the presence and hearing of those people these other false and scandalous words to wit: “he (the said plaintiff meaning) has forged an order and I'll (the said defandant meaning) have the little fellow (meaning the said plaintiff) in Auburn for it”. Meaning thereby that the said plaintiff has been guilty of forgery and was a dangerous person and unworthy to be trusted and of a bad disposition and that he the said defendant would have him indicted and convicted and sent to State's Prison for it And whereas the said defendant of his further malice towards the said plaintiff afterwards to wit on the said first day January in the year and at the place aforesaid in a certain other discourse which the said defendant then and there with diverse good people of and concerning the said plaintiff and of and concerning an order for the payment of money which he the said plaintiff did falsely and maliciously and openly and publicly speak utter publish and disclose in the presence and hearing of those people, these other false and scandalous words to wit: “he (the said plaintiff meaning) has forged an order and put William Aldridges name to an order and Christian Klock and I'll (the said defendant meaning) have the little fellow (meaning the said plaintiff) in Auburn for it “. Meaning thereby that the said plaintiff had been guilty of forgery and that he the said defendant would have him the said plaintiff in State's Prison at Auburn for it and was a dangerous person and unworthy to be trusted and of a bad disposition. By reason of speaking, publishing, and uttering of which said false scandalous and malicious words the said plaintiff is prejudiced in his good name, fame, credit and reputation. Wherefore the said plaintiff says that he is injured and hath sustained to one thousand dollars ($1000.00) and therefore he brings suit.
W.I. Dodge, Attorney
Transcribed from the original by Jerry L. Walrath, July 4, 1975
The original is in the possession of Hester Armstrong Hyde,
Portland, Oregon.