Complaint for Divorce
Mary A. Lewis
Filed Sep 21” 1867
A. Blair Clerk
Hinkle & Hord Plfs Attys
Oct 12, 1867
~ ~ ~ ~ ~ ~ ~
The deft in the above cause is hereby enjoined & restrained from selling or removing or otherwise disposing of any & all articles of personal property of Plff or of which she has possession until the final termination of said cause or until the further order of said Court.
Given under my hand Sep 19th 1867
O.J. Glessner, July 8th Clerk Dist Judicial
Mary A. Lewis
State of Indiana
|| Circuit Court
|| October Term 1867
Mary A. Lewis
plaintiff complains of Aaron Lewis defendant and says that on the 10th day of August 1842 she was married to the defendant and that she has been an active resident of the County of Shelby and State of Indiana nearly twenty years since that time and lived happily with the deft as his wife up to two years since, when the said defendant sold a valuable farm and moved to the City of Shelbyville where for the past two years said defendant has led a most reckless, dissipated and licentious life.
Having in the said time made as his associates and common companions the most base and abandoned women Making their house his place of general resort Taking his meals with them and spending most of his time under their roof.
That in the past two years aforesaid said defendant has squandered more than fifteen Thousand ($15,000) dollars in the association with said women and left his family entirely destitute so that the plaintiff was compelled to support herself and children by the plaintiff Defendant by her own labor So That the Defendant has contributed nothing in the past year to the support of this plaintiff and her said children nor has he lived with this plaintiff during that time as her husband.
That she the said Plaintiff has at all times demurred herself as a kind and affectionate wife to the defendant and that nothing she has done is the cause of the bad conduct of defendant.
That they have three children by their said Marriage Florence
aged fourteen years Josephine aged twelve years and Charles
aged ten years and that the defendant is not a proper person to have the custody of said children.
Wherefore she asks the custody of said children And that she has personal property of her own separate and apart from her husband
Also a house and lot in the City of Shelbyville Said personal property consisting of household and kitchen furniture beds bedding carpets &c And that the Defendant has sold threatened to take sell and give away more of said personal goods to some of the female associates of bad character that have been his constant companions.
Wherefore plaintiff asks for a Divorce and a restraining order upon said defendant to prevent him from taking and disposing of any of said property until the disposition of this petition, for which she will ever pray.
Plaintiff says the foregoing statements are true in matter and in fact and she asks the Court for Judgment as aforesaid and all other proper relief.
Mary A. Lewis her X mark
Subscribed and sworn to before me this 7” day of September 1867
Geo. W. Gadd Notary Public
Contributed by Barb Huff for Bob McKenzie