State of Indiana Shelby County
In the Shelby Circuit Court
The Complaint of Isabel Lemar against Robert Lemar her Husband shows that she is now and has been for many years a Resident of Shelby County, Indiana, that she and the said Robert were intermarried about 19 years ago by who she has six children, the youngest of whom is 2 years old and the oldest of whom is 18 years old; that the said Robert is now and has been an(sic) habitual Drunkard for more than 2 years last frost[?], and that on numerous occasions within that time the said Robert had cruelly beaten her without cause, and on such eval(sic) occasions had driven her and children cruelly from home without shelter or support, and that on this day the said Husband, drove her and her children from home with violence and anger without any cause whatever, with the express purpose of not ever allowing her to return. She says that she thinks that his habits are so disgusting and brutal that she never can live with him again, that he is the owner of one house and lot in the town of Marrietta in the County of Shelby of the value of three Hundred Dollars, of 100 bushels of wheat in sheaf, and 15 to 20 Bushels acres of corn in the field and two or three Hundred dollars worth of personal goods in addition thereto; and she also says that she believes that he is totally unfit to have the custody of the said children. Wherefore she prays for a final Divorce from the said Robert and for suitable alimony and for that custody of their children and the other proper relief.