Source: TSL&A Microfilm A 5078
Loose Record #4982
Transcribed by Jan J. Barnes
To the Honorable W. L. Cook, Judge, etc. holding the Circuit Court for Sumner County, Tennessee, at Gallatin.
Tabitha May Young, col., a citizen and resident of Sumner County, Tennessee,
Andrew Young, col. a non-resident of the State of Tennessee, Defendant
Petitioner would respectfully state and show to the Court, That she and defendant were married in Sumner County on the 13th day of March, 1915, where they lived together as man and wife until the 1st day of July, 1915, when defendant without cause maliciously made a deadly assault upon petitioner with sticks and rocks and inflicted upon her grievous and painful wounds, thereby seriously attempting her life; and defendant then and there turned her out of doors and to the present day has continuously refused to provide for her.
Petitioner would further show, That while they lived together defendant was guilty of habitual drunkenness, he having contracted that habit after their marriage.
The residence of the parties are as mentioned in the caption.
Premises seen and considered Petitioner prays that publication, as provided
by law, be made for defendant requiring him to appear and answer this bill,
but not on oath, his oath being waived, That on the hearing petitioner be
granted an absolute divorce from defendant and be restored to all the rights
of an unmarried woman, that petitioner have restored to her her maiden name,
Tabitha May Denning, and that defendant be required to pay the cost of this
suit. Grant petitioner such other general and special relief as she
may appear to be entitled.
Murray & Denning
Attys for Petitioner
State of Tennessee
Petitioner, Tabitha May Young, makes oath in due form of law that the facts and things stated in her foregoing bill are true, to the best of her knowledge and belief, that her complaint is not made out of levity, or by collusion with the defendant, but in sincerity and truth for the causes mentioned int he bill; and she further solemnly swears that owing to her poverty she is unable to bear the expenses of the suit she is about to begin, but that she is justly entitled to the redress sought to the best of her knowledge and belief.
Tabitha Mai Young
Subscribed to and sworn before me,
this the 16th day of December, 1916
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