Source: TSL&A Microfilm # A-5062
Sumner County Probate Records (County or Chancery)
Loose Records 3444- 3513
Transcribed by Jan J.
Loose Record # 3446
To the Hon. A. H. Munford, Judge etc. holding the circuit court at Gallatin,
for Sumner County, Tennessee.
The bill of complaint of Adaline Edwards a citizen of said county and state against Scott Edwards also a citizen of said county & state.
Petitioner would state to this Honorable court that she and deft. were intermarried in the county some seventeen years ago and have lived most of the time since in this county as man and wife. They lived in perfect peace and happiness until about Christmas of 1888 when petitioner went to Nashville Tenn. to cook for a family that she had previously known in this county. The deft. consented & agreed that she could go and cook for said family as the wages were better than could be obtained at home.
Upon the return home of your petitioner from Nashville some six weeks after Christmas, on account of ill health, petitioner found that one Henrietta Patterson had succeeded her in the affections of deft., and that he no longer cherished for her that tender love and affection, that is so beautiful and delightful between man & wife and which should characterize all of the marital relations. Since then the deft has upon various and repeated occasions had adulterous intercourse with the said Henrietta Patterson.
Petitioner has at all times been a faithful and dutiful wife to the deft. and has never been deflowered of her virtue, and has never taken any man but the deft. to her embraces.
Petitioner condoned the offense to her rights upon one or two occasions on the account of the great love she bore deft., hoping thereby to again win the erring love of deft. as she loved him truly and had lived with him so long that she could not bear the idea of separation. But matters did not improve as she hoped for, upon the other hand deft. payed more attention to the said Henrietta Patterson than ever. The "sirens" song grew sweeter & sweeter than ever to deft., and he grew more and more indifferent to her and became quarrelsome & cross towards petitioner, which culminated into violence on Sunday night Oct. 20, 1889, when he knocked her down with a large stick & said he would kill her. She has not condoned his recent acts of adultery with said woman nor does she intend to, as she can no longer live with him under such treatment as he inflicts upon her, which is so cruel and inhuman that it is not safe for her to cohabit with him as his wife & to be under his dominion & control.
During their married life they together have accumulated a little house, and a little property which she helped him by her own exertion to gather together. They have no children. They have a house and lot worth about $200.00 which is situated in the 9 civil district of Sumner Co. & bounded as follows: North Bailey Stratton; on the south by the children of Bud Balar, East Mae Balar; West by Alex Garrison, containing about one acre & a half. They have 12 head of hogs & 8 pigs, one cow and calf, Household and kitchen furniture consisting of 2 bedsteads, 3 feather beds and bed clothes for the same with pillows, one stove, one safe, one bureau, 5 chairs, 20 plates, 7 glasses, 6 cups, 6 saucers, 6 knives & 6 forks, one looking glass, one churn, 2 wash tubs, one washboard, 2 kettles, about fifteen jars of canned fruit, 6 or 7 bottles of wine, & two acres of Indian corn on the farm of Mrs. Ike Baker, one large & one small table & 1 chick box, 15 chickens & 6 turkeys all of which property she believes deft. is about fraudently to dispose of to defeat petitioners alimony.
The previous considered petition, asks above to file this writ in open
court, that process issue to the party named in the caption as such to the
end that he be made to answer the petition. Let writs of attachment
issue to the end that the property mentioned be attached, to await the decision
of this cause, set a writ of injunction issue restraining the deft from in
any way disjoining of or interfering with said property until this cause
is finally settled. This being the first application for writs of
injunction & attachment in this cause upon the final hearing grant petitioner
suitable alimony out of said property and give her a divorce a vinculo matrimoni
& restore her to all the rights of a single woman. Grant her all
other relief such as she may be entitled to and in duty bound will ever
R. K. Gillespie
Attr. for Petitioner
State of Tennessee
Personally appeared before me Wm. Hall Clerk of the Circuit Court of Sumner County, Adaline Edwards, who makes oath in due form of law that the matters & facts stated in the foregoing petitions stated upon her own knowledge are true and those stated upon information derived from others she believes to be true, and that owing to her poverty she is unable to bear the expenses of this suit, and that she is justly entitled to the redress sought and that said suit is not brought out of levity or collusion with the deft, but for the purpose therein contained.
Adeline (her mark) Edwards
Sworn & subscribed to
before me Oct. 21st 1889
Wm Hall, Clerk
To the Clerk of the Circuit Court for Sumner County Tennessee
Petitioner having taken the paupers oath issue the writs of attachment and injunction as prayed for in the foregoing petition of Adeline Edwards vs. Scott Edwards. This Oct. 21st 1889.
A. H. Munford Judge 10th Circuit of Tennessee
Sumner County Marriage Index - Scott Edwards and Adeline Baker, March 4, 1878.