Be it remembered that on the twentieth day of July in the year of our Lord
one thousand eight hundred and forty six in the above named Complaint filed in
the office of the Clerk of the Shelby Circuit Court his bill of complaint
against said defendant which reads in these words and figures following to wit—
To the Hon. Judges of the Shelby Circuit Court in Chancery sitting—Your
Complainant Joseph Wood of the County of Shelby and state of Indiana
respectfully sheweth unto your Honors, that on or about the __ day of __ in the
year 1832 your complainant was joined in marriage to Sarah Wood
his present wife
formerly Sarah Wright in the County of Green in the State of Pennsylvania that
very shortly thereafter your complainant removed to the State of Indiana, and
has since the year 1833 been a bona fide citizen of the State of Indiana &
still is a citizen thereof—That at the time of their said intermarriage until
the commission of the adultery herein after mentioned your said complainant and
his said wife lived agreeably together—that your complainant treated his said
wife with great kindness—and your complainant further sheweth that on the
twenty fifth day of November in the year eighteen hundred and forty two, at the
county of Shelby and State of Indiana your said complainants wife Sarah was then
and there guilty of adultery by then and there having sexual intercourse with
one Christopher C. Green of which your complainant was afterwards informed—but
upon the promises of said Sarah that she would be thereof no further guilty your
complainant continued to live and cohabit with his said wife Sarah—and your
complainant further sheweth that afterwards, whilst your complainant and his
wife lived and cohabited together as aforesaid to wit, on the first day of
January in the year eighteen hundred and forty five at said county of Shelby she
the said Sarah was again guilty of adultery by then and there indulging in
sexual intercourse with the said Christopher C. Green of said county of Shelby
and by then and there permitting said Christopher C. Green to have sexual
intercourse with her the said Sarah, of which your complainant was ignorant
until after the said Sarah abandoned your complainant as herein after mentioned
and your complainant further sheweth that the said Sarah afterwards, guilty of
adultery by afterwards to wit—on the first day of March in the year eighteen
hundred and forty five and on divers other days and times between that day and
the time of the abandonment complainant by his said wife Sarah, at the said
county of Shelby the said Christopher C. Green to have sexual intercourse with
and to cause to know her the said Sarah, of which your complainant was and
remained wholly ignorant until after the said Sarah abandoned him hereinafter
stated
And your complainant further sheweth that on or about the first day of
February in the year 1846 She the said Sarah did abandon the complainant, and
from that time until the filing of this bill she has remained away from your
complainant and absent from his house and has remained and resided in the County
of Decatur in the state of Indiana
And your complainant further sheweth that he and his said wife Sarah have
five children to wit Elizabeth Ann, aged fourteen years, Thomas J., Mahala,
Rachel and Eliza, aged five years. In consideration of the premises will your
Honors grant unto your complainant a writ of subpoena commanding said Sarah Wood
wife of your complainant be and appear before your Honors at the next term of
your Court be and be holden on the 8th Monday of August 1846 then and there
to answer this Bill of complaint and to abide by any order and decree which your
Honors may make in the premises and will your Honors decree a dissolution of the
bands of matrimony here and now subsisting between your complaint and the said
Sarah and that the same be annulled and held for nought and your Honors grant
such other and further relief as to your Honors shall seem meet on the premises
and your complainant will every pray.
Ray and Hendricks Att for Compt
And afterwards towit on the sixth judicial day of the term of Court aforesaid
begun and held as aforesaid before the Honorable the Judges aforesaid to wit on
Saturday the twenty second day of August in the year first aforesaid—
Now at this day come the parties and their attorneys the complainant by Ray
& Hendricks, and the Defendant by Abraham A. Hammond, and this cause being
submitted to the court upon the bill and evidence now adduced by the parties and
the allegations and proofs being heard and the Court being sufficiently advised
of the premises, do order adjudge and decree that the said Joseph Wood be and he
is hereby divorced and the marital tie heretofore and now subsisting between him
and the said Sarah Wood and that the same be set aside voided and forever held
for nought as fully and entirely as if they the said Joseph Wood and Sarah Wood
had never been married.
And it is further ordered and decreed by the Court that said Complainant pay
the costs herein accrued.
Transcribed by Barb Huff for Laurie Huey
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