Shelby County, Indiana
Complaint for Divorce and Custody of Child
Filed May 28, 1906
|State of Indiana ||In The Shelby Circuit Court
|County of Shelby||June Term 1906|
Plaintiff complains of the defendant and says that heretofore to-wit: on the 18” day of October, 1900, plaintiff and defendant were married to each other in the city of Shelbyville, State of Indiana, and lived together as husband and wife until on the _____ day of November, 1901, at which time, defendant without any cause on the part of the plaintiff, abandoned said plaintiff, and they have ever since said date lived separate and apart and are now living separate and apart at the time of the filing of this complaint.
That during all of said marriage said defendant wholly failed, neglected and refused to make any reasonable provisions for the support and maintenance of this plaintiff, though he was an able bodied man and amply able so to do.
That as the fruits of said marriage one child was born to plaintiff and defendant, to-wit: Louis Neville Jr. a boy, now four years old, now in the custody of this plaintiff.
That by reason of the above and foregoing it will be impossible for plaintiff and defendant to ever again live together as husband and wife.
WHEREFORE, Plaintiff prays the Court for a divorce from defendant and for the custody of said child, and for all other proper relief.
Tindall & Tindall
Attys. For Plff.
State of Indiana
County of Shelby SS
Comes now Avie Neville who being duly sworn upon her oath says that she is now and has been for more than ten years last past continually a bona-fide resident of the State of Indiana, and for more than four years last past continuously a bona-fide resident of Shelby County, residing for more than four years in the city of Shelbyville, said county and State.
That her occupation is that of housekeeping
Subscribed and sworn to before me, this 18” day April, 1906
Chas. H. Tindall
My Com. Expires Sept. 24, 1906
Clerk will issue summons for deft. to Sheriff of Marion Co. Ind. returnable June 12, 1906 same being the 14th Judicial day of May Term, Shelby Cir. Court
Tindall & Tindall Attys
Recd $4.00 Deposit M.O. Sullivan Clerk
Contributed by from Barb Huff
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