In Circuit Court
Complaint for Divorce
Mary Ann Lewis
Thomas B. Lewis
Filed Nov 21” 1865
A. Blair Clerk
April 10 1866
Ben F. Davis Atty
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State of Indiana
|| In The Circuit Court
---- Term A.D. 1865
Mary Ann Lewis
complains of Thomas B. Lewis and says that heretofore towit on the 25th day of May 1862, the said plaintiff and defendant were at said County and State duly and lawfully united in wedlock and that immediately after their said marriage and at said county they moved afterwards and commenced Housekeeping and so continued until on or about the __ day of November 1865 at which time they separated as hereinafter stated.
And the plff avers that at the time of their said Marriage the plff was possed of but little Estate,
And that shortly after the marriage the plffs father gave to this plaintiff a certain tract of Land which she and her husband subsequently sold and conveyed for the sum of $800,
And that One Hundred Dollars of said money she gave to her husband and that the remaining $700 she has upon interest that her father also gave at Her Housekeeping Most of which profits property personal the Plff has sold and disposed of by her said Husband and she further shows to the Court that the said deft.
Has for the past two years become a habitual drunkard and has for the past year become so far lost to all Morality as to neglect his family and his infant child when prostrate with serious illness and remain intoxicated day after day and that for the past year when her said husband is and was intoxicated he would abuse strike beat and use other personal violence upon this person of said plff- and often threaten and once attempt to take the life of your petitioner.
(viz injury Nov 18, 1865) That feeling that to longer live with the said Deft as his wife would greatly imperil her personal safety, and feeling that it was impossible for to redeem her said husband from his habits of drunkenness and cruelty to the plff she was compelled to abandon him, taking with her their only child,
Lucian B. Lewis, aged 18 months. And she shows that it is impossible to live in safety and peace with her said husband.
That from his dessolute character he is not a suitable person to have the care and custody of the said child. She shows that she has always demurred herself towards her said husband and as a kind and affectionate wife.
That she is a Lady of good repute among her neighbors and of good character in all rights.
And she asks a divorce from her said Husband for the custody of her said child, and for such Alimony as may be Just and reasonable.
And for such further relief as the Court of law can may demand.
Ben F. Davis Atty.
Contributed by Barb Huff for Bob McKenzie