Loose records: #4151
Transcribed by Jan J.
To the Hon. J. W. Stout Chancellor holding the Chancery Court for Sumner Co., at Gallatin, Tenn.
Mrs. D. F. Dickens, a citizen of Sumner County, Tennessee,
Davis Dickens, a citizen of Sumner County, Tennessee, Defendant.
Complainant would respectfully show to the Court:
That she and the defendant, Davis Dickens were married in Sumner County, Tennessee, on the 20th day of January, 1909 and lived together as man and wife until the (left blank) day of August, 1910 when the defendant willfully and maliciously deserted your complainant and has been absent for more than two whole years next preceeding the filing of this bill. And that said desertion was without any reasonable cause or any cause whatever. She would further show the defendant has failed, neglected and refused to provide for her, and that he has, since he deserted her been guilty of such conduct and to amount of cruelty and inhumanity.
Complainant would further show that she made the defendant a good dutiful and obedient wife and did not in any way whatever, give him any cause or just excuse for deserting her.
Premises considered complainant prays: -
That process issue and be served upon the defendant, that he be required to appear and answer this bill his answer upon oath being waived; That at the hearing of this cause, she be granted an absolute divorce, and restored to all the rights of an un-married woman.
Grant complainant such other, further and general relief as the nature of the case may require, as in duty bound she will ever pray.
J. T. Durham
Mrs. D. F. Dickens, makes oath in due form of law that the facts stated in her foregoing bill are true to the best of her knowledge and belief, and that her complaint is not made out of levity or by collusion, but in sincerity and truth for the causes mentioned in the bill. And she further makes oath that owing to her poverty, she is unable to bear the expense of this action, and that she is justly entitled to the redress sought to the best of her knowledge and belief.
Mrs. D. F. Dickens
Subscribed and Sworn to before me, this
November the 9th, 1913.
A. D. Moore, J. P.
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