Source: TSL&A Microfilm A 5078
Loose Record #4983
Transcribed by Jan J. Barnes
To the Hon. W. L. Cook, Judge etc., holding the Circuit Court for Sumner County, Tennessee, at Gallatin, Tennessee.
Mrs. Ella Searcy, a citizen and resident of Sumner County, Tennessee,
R. T. Searcy, a citizen and resident of Sumner County, Tennessee, defendant.
Complainant would respectfully show to the Court: -
That she and the defendant were married in Sumner County, Tennessee, on October, the 15th, 1907, and lived together until the 15th day of August 1915, when the defendant abandoned her and has failed neglected and refused to provide for her since said date. Complainant and defendant were living at complainants home, and defendant on said date, August the 15th, 1915, without cause, on complainants part, removed to the home of one of his children, and has not returned to nor offered to return to complainant since said date. She would further show that defendant, deserted her some three times pryor to August the 15th, 1915. Complainants gave defendant no cause or just excuse for deserting or abandoning her.
Both complainant and defendant are citizens of Sumner County, Tennessee, and have been for a number of years.
Premises considered, complainant prays:
That process issue and be served upon the defendant, that he be required to appear and answer this bill, his answer upon oath being waived; That at the hearing of this cause, complainant be granted an absolute divorce, and restored to all the rights and privileges of an unmarried woman.
Grant complainant, such other, further and general relief, as the nature
of the case may require, as in duty bound she will ever pray.
State of Tennessee, Sumner County
Personally appeared before me, Mrs. Ella Searcy, the petitioner in the foregoing cause, who makes oath in due form of law, that the facts stated in her foregoing bill are true to the best of her knowledge and belief, and that her complainant is not made out of levity or by collusion with the defendant, but in sincerity and truth for the causes mentioned in the bill.
Subscribed and sworn to before me,
This July the 12th, 1916
G. W. Mitchell
R. T. Searcy and Ella Strothers applied for a license in Sumner County on 12 October 1907 (Sumner County Marriage Index)
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