Jeremiah  B. Williams
Zella  Ann  Williams

Box 71
Filed September 8, 1863
                  A. Blair Clerk

Issued Hancock Oct 9, 1863 
                      Ray Davis Atty Pltf

Complaint  for  Divorce

State of Indiana In the Circuit Court October Term AD 1863
Shelby County

            Jeremiah B. Williams  would respectfully represent to the Honorable Court that heretofore towit; on or about the __ day of __ 1840 he was united in wedlock with one  Zella Ann Williams  at the County of Fayette in the State of Indiana where they continued to reside and live together as husband and wife for the space of ten years or more, at which time they removed to the county of Shelby in said State where they again continued to live together as husband and wife, until the time and date herein after specified. That during all of the time they so lived together as husband and wife the business and occupation of your petitioner was that of a farmer; that at the time of then said manage your petitioner was possessed of but little or no property whatever—but depended upon his industry for the support of himself and wife and family during the time they lived together. That your petitioner was ever affectionate and kind to his said wife and always indulged her in luxuries far beyond the pecuniary ability of your petitioner to provide. That your petitioner provided for his said wife and family all the necessary comforts of life, suitable to his and their pecuniary ability, all of which consumed the fruits of his industry during the said time they lived together, the wife of your petitioner became and was wantonly extravagant and wasteful of such necessaries and provisions as was made by your petitioner for himself and family and failed and refused to contribute any labor for the support of her family or herself, and repeatedly and on numerous occasions immediately before their separation, failed and refused to Cook for your petitioner or allow the plaintiffs children to provide your petitioners meals, and also to provide meals and attend and would upon the table at such times as your petitioner was compelled to have, and did have hands and servants in his employ—And particularly during the last year and one half, before their separation his said wife was unkind, cruel and malignant to your petitioner and would give away and destroy such provisions as your petitioner had made, and would during the abuse of your petitioner at his labor take from his house such articles as was absolute necessary for their comfort and sell and vend them unbeknown to your petitioner, and that during the last year they resided together she failed and refused to cohabit and sleep with your petitioner and often declared she had no affections for him, and that she never would cohabit with your petitioner again, And for the reasons herein stated your petitioner was compelled to abandon his home, from the cruelties and grievances aforesaid, which had then become intolerable, and insufferable. That she resides in Hancock County Indiana. That they have nine children who are yet minors the youngest being a male of the age of six years—five males and four females—That the male children are with your petitioner their father, and the females with their mother. Wherefore your petitioner asks that the marriage bonds Wherefore your petitioner asks that a divorce be granted him and that the marital bonds existing between them be severed, and that he have the custody of the Male children and for other proper relief. 
                                                    Ray & Davis Attys

Cross  Complaint

Filed in Open Court October 9, 1863
A. Blair Clerk

            The Defendant by way of cross complaint says that the parties to this suit was married as in the Plaintiffs Complaint alledged and she further says that during all the which time elapsed from the time of their marriage up to the time of their final separation as hereinafter set forth she al all times conducted herself towards her said husband in a prudent and proper manner and at all times discharged each and every duty required of a wife and to her said Husband was kind and affectionate up to and until such times as the conduct of her husband compelled her to withhold to some extent her affections for him that for more than five years past the Plaintiff has been and still is a habitual drunk and that during his periods of intoxication he rendered harsh cruel and unkind often abuses her that about ___ the day of 1861 he abandoned her and her family of children without any Just cause whatever and Since that time has made no provision for her or her children left with her. She further says that the Plaintiff is a man of Idle and dissolute and lascivious habits and practices and for that reason abandoned his said wife and family that he might have greater scope for his lascivious practices. She says by said marriage they have had sixteen children and that the following named children are still under age and was left with her that is to say  Caroline aged 18 years  Rebecca aged 16 years,  George aged 14 years  Anna aged 13 years  Perry aged 12 years  Andrew aged 11 years  Jeremiah aged 9 years  Zella Ann aged 8 years  Ozro aged 5 years. She therefore demands Judgment that the Marital tie heretofore & now existing between then be dissolved set aside and held for naught and that she have the care control and custody of the two last named children towit Zella Ann and Ozro and the personal property owned by them at the time of the abandonment and such sum for her alimony as to the Court may seem Just right and proper and other proper relief.
Zella Williams By Davis Wright & Green     Her Attys


Filed in Open court October 9, 1863
A. Blair Clerk

            The Defendant says for answer to Plaintiffs Complaint that she specifically denies each and every allegation thereof. 
                                                                                  Davis Wright & Green   Attys


State of Indiana Shelby County Sct

            You are hereby commanded to summon  Richard Roan,  Christopher Roan,  Harrison Amos,  Elizabeth Amos,  David Johnson,  Hester Johnson,  Sarah Ferris,  Louisa Higgenbothom,  Lurinda Chambers,  Caroline Williams,  Joseph Higgenbothom  Caroline Higginbothom  to appear before the Judge of Shelby Circuit Court on the 3rd day of the present term, now holding at the Court House in the City of Shelbyville, to testify in an action wherein  Jeremiah B. Williams  is Plaintiff and  Zella Ann Williams  is Defendant, on behalf of the defendant and return this summons.
            WITNESS,  The Clerk of said Court this 7th day of October 1863
Alonzo Blair Clk


Jeremiah B. Williams  VS   Zella Ann Williams
Answer  to  Cross  Complaint

Filed in Open Court
A. Blair Clk

            Now at this time comes the Plaintiff and for answer to the pleas Deft Cross Bill says that he specifically denies each and every Material allegation contained in said plaintiffs complaint.
Ray & Davis Attys


State of Indiana, Shelby County Sct

            You are hereby commanded to summon  Adam Cobble,  George Williams,  Wm. Amos,  John Chambers,  Ralph Alexander,  James Fry  to appear before the Judge of the Shelby Circuit C Court Instant at the present Term, now holding at the Court House in the City of Shelbyville, to testify in an action wherein Jeremiah B. Williams is Plaintiff, and Zella Ann Williams is Defendant, on behalf of the Plaintiff and return this summons.
            WITNESS, The Clerk of said Court, this 7th day of October 1863
Alonzo Blair Clk

Transcribed by Barb Huff

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