Source: TSL&A Microfilm # A-5062
Sumner County Probate Records (County or Chancery)
Loose Records 3444- 3513
Transcribed by Jan J.
Loose Record # 3448
To the Hon. Jo. C. Stark Judge of the 10th Judicial Circuit presiding at Gallatin Sumner County Tennessee
The bill of complaint or petition of Matt Bracken a citizen of Sumner County against Emma Bracken a citizen of Sumner County.
Petitioner would respectfully represent & show your Honor that he and the defendant intermarried in Sumner County about the year 1879 or 80 and lived together as man & wife until 2 years ago at which time the defendant willfully & maliciously & without cause or provocation deserted & abandoned your petitioner, taking with her their two infant children. Petitioner at all times and under all circumstances treated her as a kind and dutiful husband should treat his wife, and has respectfully entreated and _____ to get her to return & live with him, this he did more on account of his children, as he wanted to be with & assist in raising & caring for them.
Petitioner would further represent & show your Honor that since said
abandonment & desertion by defendant that she the deft. has been guilty
upon various and divers occasions of Adultery, when the deft. first left
she went off with one William Ray with whom she lived in adultery for a month
or more she also was guilty of adultery upon several occasions with one Jim
Rogan. She has also been guilty of the same acts with a number of other
men too numerous to mention. The previous considered, petitioner ask
leave to file this petition in your Honor'b Court that the defendant mentioned
in the caption be made such to this petition, that process issue for her
to answer and upon the final hearing petitioner asks that the bonds of matrimony
heretofore subsisting between petitioner & defendant be dissolved and
that he be by decree of this Court restored to all the rights & privileges
of a single man.
W. C. Dismukes
Atty. for Plff.
State of Tennessee
Sumner County Personally appeared before me Wm. Hall D. C. Clk of Sumner Co., Matt Bracken who makes oath that the matters & facts set forth in the foregoing petition are true, and that said complaint is not made out of levity or by collusion with the deft. but in sincerity & truth for the causes therein mentioned and that he is justly entitled to the redress sought.
Matt (his mark) Bracken
Sworn to and subscribed before me
Oct. 24th 1885
Wm Hall D. C.
I Matt Bracken (Col) do solemnly swear that owing to my poverty I am not able to bear the expense of the action which I am about to commence & that I am justly entitled to the redress sought to the best of my belief. This Oct. 24th 1885.
Matt (his mark) Bracken