Source: TSL&A Microfilm A 5078
Loose Record #4925
Transcribed by Jan J. Barnes
To the Honorable W. L. Cook, Judge, presiding and holding the Circuit
Court at Gallatin, Tennessee.
Willie G. Scurlock, Complainant, a resident of Sumner County, Tennessee.
Blanche Bradley Scurlock, Defendant, a resident of the State of Kentucky.
Complainant would respectfully show unto your honor:
That he and defendant were married in Sumner County Tennessee, on September 9th 1916, and lived together as man and wife in Sumner County Tennessee, until on or about October 1st 1917.
Complainant would respectfully show unto the Court that during the Summer and Fall of 1917 that one J. C. Robertson, was operating a rock and lime pulverizer in Sumner County, Tennessee, and employed your complainant to help and operate same. Said Mr. Robertson being a married man with a wife and children living in Indiana, and having no home and few acquaintance, where he was operating said machine, that he made a contract with complainant to board with him, and complainant took him into his said home for board and lodging believing him to be an honorable gentleman. And kept said Robertson in his home for several months. And during said time that said Robertson boarded and lodged with complainant, he having full confidence in his wife, Blanch Bradley Scurlock, he never suspected any illicit or immoral conduct between Mr. Robertson and his wife, until one day about October 1st, 1917 complainant had business away from home. And when he returned to his home, to his great surprise, found his wife and said Robertson embracing and hugging and kissing each other. And upon complainant inquiring about what it meant and why there was such conduct between them, Defendant Blanch Bradley Scurlock admitted having had on several occasions immoral relations with said Robertson. Whereupon, defendant requested complainant to take her to her mother's home in Simpson County, Kentucky, where he did.
Complainant charges that defendant is guilty of adultery with the said Robertson, and that she had illicit and immoral relations with said Robertson to the prostitution of their own home and that complainant knew nothing of the immoral relations between defendant and said Robertson. Nor did he suspect any such immoral relationship between them until he returned home on the occasion referred to and to his great surprise and humiliation, he saw them embracing and hugging and kissing each other. The defendant admitting such relationship to him, Complainant did not condone such relationship and conduct between them and immediately ridded himself of her, and that she now lives and has lived ever since with her mother in Simpson County Kentucky. Complainant is informed and believes that she is still having immoral relations with said Robertson. And said Robertson still visits her and "hangs round" her and her mother's home. And that he has continuously visited her since their separation.
Complainant could not account for her misconduct, as he always tried to
trust her & provide her with a good home as a poor man could do.
Premises seen and considered complaint prays: -
First: - That proper publication be made requiring the defendant to appear and answer this bill, but her oath to her answer is waived.
Second: - That at the hearing grant complainant an absolute divorce forever dissolving the bonds of matrimony subsisting between complainant and defendant, And that he be given all the rights and privileges of an unmarried person.
Grant Complainant all such other general and special relief that he may be entitled to at the hearing of this cause.
W. L. McKinney
Solicitor for Complainant
State of Tennessee
County of Sumner
Willie C. Scurlock, being duly sworn, makes oath that the facts stated in his foregoing bill are true to the best of his knowledge and belief and that the complaint is not made out of levity or by collusion with the defendant, but in sincerity and in truth for the causes mentioned in the bill.
Willie C. Scurlock
Subscribed and sworn to before me,
this July 7th, 1919
Lois McKinney N. P.
We go security for cost of this cause.
W. C. Scurlock
W. L. McKinney