Shelby County, Indiana
Leona A. Faulkner
George W. Faulkner
Complaint Divorce, Custody of Child, Restraining Order
Shelby Circuit Court
Filed March 16, 1907
State of Indiana Shelby County
Circuit Court December Term 1906
Leona A. Faulkner complains of George W. Faulkner and says that plaintiff and defendant were married on the 2nd day of November 1903. That he abandoned plaintiff on the last day of March 1906, and has ever since lived separate and apart from her.
That she is entitled to a divorce from defendant on the following grounds towit:
1st That defendant is an habitual drunkard.
2nd That for more than two years last past defendant has failed neglected and refused to make reasonable provisions for the support of plaintiff and their child.
3rd That on divers occasions since said marriage the defendant in a rude insolent and angry manner and with his fists, a knife and beer bottles, struck cut beat and bruised this plaintiff all without cause, and on several of such occasions he was made to pay fines therefore and on one of such occasions he served a work-house sentence of 30 days for beating this plaintiff. That he continuously during their said married life cursed plaintiff, and called her vile and improper names. That he has done plaintiff personal violence and has threatened her with such violence and she fears that if not restrained by the court he will carry said threats unto execution. She avers that there is one child of plaintiff and defendant named Russell, now in plaintiffs custody and who is being clothed and maintained by plaintiff. That the defendant has threatened to take and carry said child away from plaintiff & she believes he will undertake to carry out said threat unless restrained by the court.
Wherefore plaintiff sues and demands a judgment for an absolute divorce, and she prays the court to decree that she is the legal custodian of said child & she prays for a temporary restraining order, preventing defendant from threatening or doing her personal violence, and from interfering with her custody of said child and she also prays for all proper relief.
Hord & Adams Attys for Plaintiff
State of Indiana
Shelby County SS
Said Leona A. Faulkner being sworn says that she has resided in the state of Indiana for 22 years. That during the whole of the last two years she has resided in the City of Indianapolis, Indiana except that during all of the last ten months she has resided in the City of Shelbyville in Addison Township in Shelby County, Indiana and that her occupation is that of a housekeeper & she says the foregoing complaint is true in substance and in fact.
Mrs. Leona Ives Faulkner
Subscribed and sworn to before me this 2nd day of January 1907
Ed K. Adams Notary Public
Commissioned to June 12” 1909
Contributed by from Barb Huff
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