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Rachel Lauderdale
Berry Lauderdale, 1920

Source:  TSL&A Microfilm A 5078
Loose Record #4971

Transcribed by Jan J. Barnes

© 2004

To the Honorable J. W. Stout,Chancellor holding the Chancery Court at Gallatin for Sumner County, Tennessee:

The bill of complaint of Rachel Lauderdale, colored, a resident of Sumner County, Tennessee,
Berry Lauderdale, colored, also a resident of Sumner County, Tennessee.

Complainant would respectfully show to the Court:
that she and the defendant were married in Sumner County, Tennessee, in May, 1911, and that they have since resided and still reside in Sumner County, Tennessee.
That in the fall of 1912 the defendant willfully and maliciously deserted the complainant without any reasonable cause and they have not lived together since said date, and that on said date defendant abandoned complainant and refused and neglected and still refuses and neglects to provide for her.
That defendant's wilful and malicious desertion of her and his failure to provide for her, as aforesaid, was without any fault upon her part and without any reasonable cause or excuse.
The premises seen and considered, complainant asks leave to file this bill in this Honorable Court and prays:
1st.  That process issue and be served upon the defendant, requiring him to answer this bill, but not under oath, that being waived.
2nd.  That upon the hearing she be granted an absolute divorce from the defendant and that she be restored to her maiden name of Rachel Gleaves.
3rd.  Grant to complainant such other and further relief as she may be entitled to upon the hearing and as the justice of her cause may demand.
Baskerville & McGlothlin
Solicitors for Complainant
State of Tennessee
Sumner County
Rachel Lauderdale makes oath in due form of law that the matters and things 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 with the defendant, but in sincerity and truth for the causes mentioned in the bill.

She further makes oath that on account of her poverty she is unable to bear the expenses of this suit, and that she is entitled to the redress sought to the best of her knowledge and belief.
Rachel Lauderdale
Sworn to and subscribed before me, this the 1st day of March, 1920.
Elizabeth Doubleday
Notary Public

Rachel Lauderdale, Colored,
Berry Lauderdale, Colored.
This cause came on to be heard before the Honorable J. W. Stout, Chancellor, on the 12th day of May, 1920, upon the bill of the complainant, Rachel Lauderdale, the pro confesso heretofore taken and entered against the defendant, Berry Lauderdale, and the oral testimony of witnesses examined in open court.
And it satisfactorily appeared to the court from the proof that the facts charged in the bill are true, that the defendant, in the fall of 1912, wilfully and maliciously deserted the complainant without a reasonable cause and that he has not lived with her since, as charged in the bill, and that on said date he abandoned complainant and refused and neglected and still refuses and neglects to provide for her, and that the complainant gave the defendant no just cause or excuse for his said misconduct.
It is, therefore, ordered, adjudged and decreed by the court that the bonds of matrimony heretofore subsisting between the complainant and the defendant be and the same are hereby absolutely and forever dissolved and the complainant is vested with all the rights of an unmarried woman, and she is restored to her maiden name of Rachel Gleaves.
It is further ordered and decreed that the defendant pay all the costs of this cause, for which execution will issue as at law.

Sumner County Marriage Index - Berry Lauderdale & Rachel Gleaves, 1 June 1909.

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