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Avis
Audrey Inez Middlebrooks & Thomas Jefferson Massey
(January
24, 1926; Limestone Co. Alabama)
L.C.
Massey & Mary Lou Campbell
(October
16, 1892; Giles Co. Tennessee)
Min Book No. 4, Page 315
Divorce Decree of L.C. &
Mary Lou Massey
-original is too light in
type, thus I've only added a transcription
Comes the complainant, L.C.
Massey, and submits this his bill of complaint against Mary Lou Massey
and respectfully represents and shows unto the Court as follows:
Par. 1. That the complainant is
over the age of 21 years and resides in Limestone County, Alabama and
has resided in said state for more than three years before filing this
suit. That the defendant is over the age of 21 years and her place of
residence, is Athens, Alabama in Limestone County.
Par. 2. The complainant would
show unto the Court that he and the defendant are husband and wife,
having been lawfully married in Giles County, Tennessee about the
first of 1895 and that separated in Giles County, Tenn. about December
28, 1920 and that they have not lived together since that time.
Par. 3. The complainant would
show unto the Court that on or about Dec. 28, 1920, the defendant
without just cause or excuse abandoned him and that said abandonment
took place more than two years ago and still continues without fault
on his part;
THESE PREMISES? CONSIDERED, the
complainant prays that the defendant be, by due process of law, made a
party defendant to this suit; that she be required to plead, answer or
demur to the bill of complaint filed in this case within the time
allowed by law or else decree to conf---? may be entered against her
and that upon final hearing of this cause, the complainant is granted
an absolute divorce from the defendant with right to remarry and that
all such other relief be granted unto the complainant as the Court may
deem proper.
Irby Scott,
Solicitor for Complainant.
Note:
The defendant is required to answer all the allegations and statements
contained in said bill of complaint from Par. 1 to 3, all inclusive,
but without oath, as oath thereto is hereby expressly waived.
Irby Scott,
Solicitor of Complainant.
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State of Alabama, )
) In the Circuit Court, in Equity
Limestone County )
L.C. Massey, Complainant
VS
Mary Lou Massey, Defendant.
Comes the defendant in her own
proper person and for answer to the bill of complaint filed in this
case __?___.
1st. She admits the allegations
contained in Par. 1 and 2 of said bill of complaint, but denies all of
the allegations contained in Par. 3, and demands strict proof thereof.
The defendant hereby accepts
notice of teh filing of theis suit and waives notice by the Sheriff
and agrees that the testimony in said case may be taken at any time
and at any place without further notice to her and that this cause may
be submitted for final decree at any time and place without further
notice to her, all of such further notices of the proceedings in this
case are hereby expressly waived.
Mary Lue Massey,
Defendant in her own proper person.
Witness:
T.D. Massey.
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State of Alabama, )
) In the Circuit Court, In Equity
Limestone County )
L.C. Massey, Complainant
V S
Mary Lou Massey, Defendant.
In the above styled cause the
complainant being called offers the following testimony:
1st, The original bill and
exhibits thereto.
2nd, Answerand agreement of Defendant.
3rd, Testimony of complainant and Thomas Massey.
And the defendant being called offers the following testimony:
1st. Answer and agreement,
I hereby certify that the above note of testimony is correct. This the
8th day of December, 1933.
W. Van Gilbert,
Register
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