Source: TSL&A Microfilm A 5078
Loose Record #4979
Transcribed by Jan J. Barnes
To the Hon. W. L. Cook, Judge etc., holding the Circuit Court for Sumner County, Tennessee, at Gallatin, Tennessee.
Mattie May Webb, a citizen of Sumner County, Tennessee Complainant.
Brode Webb, a citizen of the state of Texas, and a non resident of the state of Tennessee, Defendant.
Complainant would respectfully show to the Court: -
That she and the defendant were married in Sumner County, Tennessee, on the 11th day of August, 1916, and lived together until the 12th day of September, 1916, when the defendant turned her out of doors, and has failed, and refused to provide for her. They were living near White House, and the defendant told her to leave, and go to her father, that he did not expect to live with her any longer, He left the next day, and went to Nashville, some two months then after that, he was passing her home and she tried to get him to live with her, and he refused to do so and said that he never expected to live with her again.
Your complainant made the defendant a good and kind wife, and did not in any way whatever, give him any just cause or excuse for his conduct. She is now living with her father, who is supporting and caring for her.
Premises considered, complainant prays:
That non resident publication be made for 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, she be granted an absolute divorce, and restored to all the rights and privileges of an un-married 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.
J. Durham, Atty
Mattie May Webb, 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 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.
Affiant further makes oath that owing to her poverty, she is unable to bear the expense of this action, and that she is justly entitled to the redress sought to the best of her knowledge and belief.
Subscribed and Sworn to before me,
This April the 14th, 1917.
T. A. Jenkins (Notary Public)
Sumner County Marriage Index - Brode Webb & Mattie Hunt, 11 August 1916.
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