Source: TSL&A Microfilm # A-5162
Sumner County Probate Records (County or Chancery)
Loose Records 3444 - 3513
Transcribed by Jan J.
Barnes and Marie Johnson
Loose Record # 3468
To the Honorable Jo. C. Stark Judge of the Circuit Court at Gallatin
Your petitioner Mira Durham a citizen of Sumner County would show your Honor that she and James Morgan now residing in Sumner County Tennessee were married in this County some years ago and they lived together in this County until some three years ago when he willfully, maliciously & without cause drove her away from home and deserted her and has remained away from her ever since. During all this time he has entirely failed & refused to provide for her in any way whatsoever. She has been dependent alone upon her own exertions for food and clothes. He threatened during their cohabitation to strike & whip her. He has frequently abused her in different ways. She charges that deft. since his willful & malicious desertion often has been guilty of unlawful and illicit intercourse with Lucy Miller and is now cohabitating with her.
Premises considered she prays that process issue for deft. that he answer this petition and that on a final hearing the bonds of matrimony subsisting between them be dissolved and that she be granted such further general and special relief as she may be entitled to and as in duty bound will ever pray.
Charles R. & Lee Head
State of Tennessee
Personally appeared before me Mira Durham & made oath that the facts & statements herein made of her own knowledge are true & those stated upon information she believes to be true & that the foregoing complaint is not made out of levity or by collusion with the defendant but in sincerity and truth for the cause assigned and that owning to her poverty she is unable to bear the expenses of this case and that she is justly entitled to the relief sought.
Mira (her mark) Durham Morgan
Sworn to and subscribed before me July 7th 1879
Thos. H. King Clk
The Sumner County Marriage Index has the marriage of James Morgan and Lucy Miller - 6 June 1879