Source: TSL&A Microfilm A 5078
Loose Record #4936
Transcribed by Jan J. Barnes
To the Honorable W. L. Cook, Judge, etc. of the Ninth Judicial Circuit,
holding Circuit Court at Gallatin for Sumner County, Tennessee:
The petition of Lucy Barr, a resident of Sumner County, Tennessee
Henry Barr, also a resident of Sumner County, Tennessee, but temporarily working in Nashville, Tennessee.
Petitioner would respectfully show to the Court:
That she and the defendant were married in Sumner County, Tennessee, in November, 1913; and that they had as a result of said marriage one child, a boy, Will Henry Barr, who is now five years old.
That in about a month after their marriage, or in December, 1913, the defendant wilfully and maliciously deserted the petitioner without any reasonable cause whatever and they have not lived together since said time; that the defendant thus abandoned petitioner and refused and neglected to provide for her and still refuses and neglects to provide for her, or their little boy; that petitioner gave defendant no excuse whatever for his said wilful desertion, but same was without any fault upon her part.
The premises seen and considered, the petitioner asks leave to file this petition in this Honorable Court and prays;
1st. That process issue and be served on the defendant requiring him to answer this peition, 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 given the sole and exclusive custody of their little boy, Will Henry Barr.
3rd. That the defendant pay all the costs of this cause, including a reasonable fee for her attorneys.
4th. Grant to petitioner such other further relief as she may be entitled to upon the hearing and as the justice of her cause may demand.
Baskerville & McGlothlin
Attorneys for Petitioner
State of Tennessee
Lucy Barr, the petitioner, being duly sworn, makes oath that the facts stated in her foregoing petition 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 petition.
She further solemnly swears that on account of her poverty she is not able to bear the expenses of this suit, and that she is entitled to the redress sought to the best of her knowledge and belief.
Sworn to and subscribed before me, this the 3rd day of January, 1920.
Sumner County Marriage Index - Henry Barr & Lucy Carey, 20 November 1913
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