James M. Talbert and complains of Anna Talbert and for cause of complaint says
that he and defendant were duly married on the 22nd day of February, 1905,
and lived together as husband and wife until the 16th day of June, 1906, on
which day they separated and have not lived or cohabited together since, and are
not now living and cohabiting together as husband and wife; said plaintiff says
that said defendant before the said separation, was guilty of cruel and inhuman
treatment of this plaintiff in this, that she charged him privately and publicly
with not being true to his martial vows, that he was not true to her but
associated with women of bad character for chastity and called him a whoremaster
frequently, all of which charges were false and all of which charges the
defendant knew to be false. That at the time of said separation and for seven
months prior thereto this plaintiff and defendant lived at the home of this
plaintiffs’ mother, who is 64 years of age, and that this plaintiff tilled her
land and managed her farm and that during said time the defendant repeatedly
complained to this plaintiff of his mother and said that his mother stole eggs,
that she was deceitful, that she was a liar, and that this plaintiff’s mother
was prejudiced against defendant and was trying to separate this plaintiff and
defendant all of which she, the defendant knew to be false.
That since said separation said defendant lived at the City of Indianapolis, that she drank intoxicating liquor with men and became intoxicated. That the defendant received letters from some one and when plaintiff asked her from whom she received letters she refused to tell him.
Wherefore plaintiff sues and asks the Court that the bond of matrimony heretofore existing between plaintiff and defendant be dissolved and for all other proper relief.