Source: TSL&A Microfilm A 5078
Loose Record #4980
Transcribed by Jan J. Barnes
To the Hon. W. L. Cook, Judge etc., holding the Circuit Court for Sumner County, Tennessee, at Gallatin, Tennessee.
A. F. Mitchener, a citizen of Sumner county, Tennessee, Complainant.
Mrs. Lillie Mitchener, a citizen and resident of Sumner County, Tennessee, Defendant.
Complainant would respectfully show to the Court: -
That he and the defendant were married in Sumner County, Tennessee, in June, 1911, and lived together as man and wife, until the (left blank) day of November, 1914, when the defendant willfully and malicious deserted your complainant and has been absent without a reasonable cause for two whole years next preceeding the filing of this bill.
Defendant upon several occasions, before she deserted complainant, stated to complainant that she expected to leave him, as soon as she could sell or dispose of her turkeys; and the day before she left, stated to complainant that she expected to sell her turkeys the next day and go to her fathers to live, and that she never wanted complainant to speak to her again, complainant remonstrated with her about leaving him, and she said that she was going to leave, if she had to walk, whereupon complainant made arrangements for a division of property with her.
Complainant would further show that one child, Walter Mitchener, was born unto them, said child is now in the possession of defendant, and your complainant is willing that she have the care and custody of said child if she so desires.
Your complainant made the defendant a good, kind and provident husband, and did not in any way whatever, give her any cause for her said desertion.
Premises considered, complainant prays:
That process issue and be served upon the defendant, that she be required to appear and answer this bill, her answer upon oath being waived; That at the hearing of this cause, he be granted an absolute divorce, and restored to all the privileges of an unmarried man.
Grant complainant, such other, further and general relief, as the nature
of the case may require, as in duty bound complainant will ever pray.
J. Durham, Atty
A. F. Mitchener, makes oath in due form of law, that the facts stated
in his foregoing bill, are true to the best of his knowledge and belief,
and that his complaint is not made out of levity or by collusion with the
defendant, but in sincerity and truth for the cause mentioned in the bill.
A. F. Mitchener
Subscribed and Sworn to before me,
This the 26th day of April, 1917.
J. W. Hill Clerk
We acknowledge our-selves sureties for the cost of this cause.
This April the 27th 1917.
A. F. Mitchener
H. C. Mitchener
Sumner County Marriage Index - Andrew F. "Mitchimen"
& Lillie Scott, 17 June 1911
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