Loose records: #8600
TSL&A Microfilm # A5107
Transcribed by Erick
Petition for A Divorce
Filed 23rd Novr. 1854
To the Hon Nathaniel Baxter judge presiding at Gallatin Sumner County Tennessee.
The Bill of complaint of Hannah Thomas a citizen of Sumner County Tennessee against Daniel Thomas a non resident.
Your oratrix would respectfully shew unto your Honor that she and the
defendant were married on the 29th of February eighteen hundred and thirty-nine
in Phillips County State of Arkansas and that they lived there for some time
and afterwards removed to Mississippi
until September eighteen hundred
and fifty two when the defendant left her and she has not heard
from him since, and the complainant removed from the State of Mississippi
to this county some time in March eighteen hundred and fifty three, and has
ever since been a permanent citizen and resident of this county.
Your oratrix would further shew unto your Honor that the defendant and your oratrix got along together tolerably well untill about eighteen hundred forty five or six and that then he commenced drinking to great excess and that he became very abusive to her both in language and conduct. Your oratrix would futher shew unto your Honor that his drinking was more and more excessive from the time he commenced, up to the time he left in September eighteen hundred and fifty two, since which time she has not seen him or heard from him and that his conduct towards her was more intolerable up to the time he left. Your oratrix would further shew unto your Honor that at various times before they parted that he cursed her and abused her in language too vulgar to be here repeated and ?fferce her various indignities which were improper and not to be borne by any woman and she would further shew unto your Honor that he upon three or four occasions before the separation, struck her with his fist and otherwise maltreated her, thus destroying her happiness and rendering her condition miserable and not to be borne. Your oratrix would further shew your Honor that most of the time in the year eighteen hundred and fifty two he drank so much that he was perfectly wild and deranged at times and at other times was a perfect maniac or madman trying to __sty or bully every thing or person in his presence and during this time he wholly neglected and failed to attend to his family or their wants or desires and left your complainant to provide for herself and family as but she could. The defendant being very poor and there was nothing to go on except what your complainant would provide for. Your oratrix would further shew unto your Honor that sometime in September eighteen hundred and fifty two he was drinking and wild as before mentioned and that he finally left your oratrix at that time and that since then she has made diligent search and inquiry for him but that she has not seen him and has totally failed to hear of or from him, and thinks it probable he is dead and has so learned he having willfully and maliciously disserted her for so long a time and not having been heard of since said time. Your oratrix would further shew unto your Honor that they have some four children by their marriage viz Nancy Catherine Mary Elizabeth and Monty Gwin who are now living with her and Martha who is in Mississippi she supposes.
The premius considered your oratrix prays that she be divorced from the bonds of matrimony "a vineule it matrimoni" from the said defendant and be vestored to all the rights of a femme sole and the marriage between them be annulled. She prays that he be made party defendant to this bill and let him answer its allegations in full and particularly and let process issue and grant such other and further relief as the Miretum of the case may demand and to your honor may seem meet and as in duty bonna will ever prey.
Head & Turner
I Hannah Thomas do solemnly swear that the facts contained in this Bill are true to the best of my knowledge and belief and that the said complainant is not made out of livety or by collusion with the defendant but in sincerity and truth for the causes mentioned in said Bill.
This 23rd day of November 1854.
Sworn to and subscribed before me }
Paschal Head clk }
I acknowledge myself the security of Hannah Thomas for cost of suit in this case Novr. 23rd 1854