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NO. 309

2. (If wife be plaintiff, add:) That a reasonable provision for the support of the plaintiff and her said children be made out of the property of the defendant;

3. And for such other and further relief agreeable to equity, and for the resumption of her

name.

Attorney for Plaintiff.

(Business address.)

(Verification, see form No. 283.)

No. 309. Bill for Divorce for Desertion.

(Title of Court and Canse.)

The plaintiff complains of the defendant, and alleges:
First (Allegation of marriage between parties.)
Second (Allegation of residence.)

or about

19...., the deThird-That on fendant, disregarding the solemnity of his marriage vow wil fully and without cause deserted and abandoned the plaintiff, and ever since has and still continues so to wilfully and without cause desert and abandon the said plaintiff, and to live separate and apart from her, without any sufficient cause or any reason, and against her will, and without her consent. Fourth (Demand of judgment.)

Attorney for Plaintiff.

(Verification, see form No. 283.)

No. 310. Bill for Divorce for Extreme Cruelty.

(Title of Court and Cause.)

The plaintiff complains of the defendant, and alleges:
First (Allegation of marriage between parties.)
Second (Allegation of residence.)

Third-That since said marriage, the defendant has treated 19...., at her in a cruel and inhuman manner, and in particular, as follows:

day of

On the
... the defendant (here set out specific acts).
Fourth-(Demand of judgment.)

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No. 311. Bill for Divorce on Conviction for Felony. (Title of Court and Cause.)

The plaintiff says:

First (Allegation of marriage between parties.)
Second (Allegation of residence.)

Third-That at the..

in and for the county of

. term of the court of... . .

State of....

and

and duly sentenced

before this action, the defendant was duly convicted of a felony, to wit, of the crime of ... by said court to confinement in the for the term of ...

....

.. of said State .... years, and in pursuance of the said sentence the defendant is now confined in said (Demand of Judgment.)

Attorney for Plaintiff.

(Verification, see form No. 283.)

No. 312. Bill for Divorce for Habitual Drunkenness.

(Title of Court and Cause.)

The plaintiff complains of the defendant, and alleges:
First (Allegation of marriage of parties.)

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Second (Allegation of residence.)

Third-That the defendant, disregarding his duties as a a husband towards the plaintiff, has been guilty of habitual drunkenness for more than

Fourth-(Demand of judgment.)

Attorney for Plaintiff.

(Verification, see form No. 283.)

No. 313. Bill for Divorce for Non-Support.

(Title of Court and Cause.)

years last past.

The plaintiff complains of the defendant, and alleges:
First-(Allegation of marriage.)

Second (Allegation of residence.)

Third-That the said defendant for more than

years last past has wilfully neglected to provide plaintiff with the common necessaries of life, although having the ability so to do, being worth, as this plaintiff is informed and believes, about the sum of dollars, and being in the con

NO. 314

stant receipt of wages sufficient for their joint support from dollars per month. his daily labor, to wit; about

...

(Or, Third-That said defendant for more than

years last past has failed to provide plaintiff with the common necessaries of life because of his idleness, profligacy, and dissipation.)

Fourth-(Demand of judgment.)

Attorney for Plaintiff.

(Verification, see form No. 283.)

No. 314. Bill for Divorce for Impotency.

(Title of Court and Cause.)

The plaintiff complains of the defendant, and alleges:
First (Allegation of marriage.)

Second (Allegation of residence.)

Third-That soon after said marriage was celebrated the plaintiff discovered that the defendant at the time of her (his) marriage with the plaintiff as aforesaid, was physically incapable of entering into a marriage state by reason of certain personal defects in that (here set out the nature of the incapacity).

Fourth-That said physical incapacity of the defendant as aforesaid was well known to said defendant at the time of contracting said marriage, but was wholly unknown to the plaintiff.

Fifth-That the plaintiff has been informed and believes that said physical incapacity of the defendant still exists and is incurable, and so charges the fact to be.

Sixth-(Demand of judgment.)

Attorney for Plaintiff.

(Verification, see form No. 283.)

No. 315. Bill to Declare Marriage Void.

(Title of Court and Cause.)

The plaintiff complains of the defendant, and alleges:

First (Allegation of residence.)

Second-That on the ...

at ........

in the State of

day of

19.....

., a marriage between

the plaintiff and defendant was duly solemnized by

who was duly authorized by the laws of said State to solemnize marriages, and the certificate of such solemnization has been duly recorded as required by law.

Third

(Set out any cause which, under the statute, renders the marriage void.)

Fourth-Wherefore, the plaintiff prays that said marriage may be, by the decree of this court, declared to be void for the reason above set forth, and for other proper relief.

Attorney for Plaintiff.

(Business address.)

(Verification, see form No. 283.)

No. 316. Petition for Alimony and Expenses.

The Circuit Court for the County of

A. B., Plaintiff,

V.

C. D., Defendant.

To Said Court:

In Chancery.

1. The petition of C. D., of, etc., the above named defendant, respectfully represents that the plaintiff, A. B., has lately filed his bill in this court, against your petitioner, to obtain a decree dissolving the marriage between him and your petitioner, charging your petitioner with the crime of adultery (or whatever the charge may be); That your petitioner has put in her answer to the said bill of complaint denying such charge.

2. That she is wholly destitute of the means of supporting herself during the pendency of this suit, and of carrying on the defense, and defraying the costs and expenses attending the same.

3. That the plaintiff is the owner of the following property (here describe fully the property of complainant, and its value); and that the annual income of said plaintiff amounts to the sum of dollars.

...

Fourth-Wherefore petitioner prays:

That the plaintiff may, by an order of this court, be required to pay to petitioner a reasonable sum for her support and maintenance during the pendency of this suit;

2. And such sum or sums of money as may be necessary to enable her to carry on her defense, to pay attorney fees, and to defray the other necessary costs and expenses thereof;

3. And for such other and further relief in the premises as may seem meet.

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To....

Attorney for Plaintiff. Sir: You will take notice, that upon

the

at the opening A. D. 19... .... ..day of of court on said day, or as soon thereafter as counsel can be heard, I shall move the court for alimony and expenses in the above entitled cause, in conformity with the prayer of a petiThat said motion is based tion now on file in said cause. upon the files and records of said cause, and upon the petition of the defendant, C. D., (and the affidavit of S. K.,) the annexed being the true cop.... of said petition (and affidavit). Dated at

A. D. 19...

the

day of

Attorney for Petitioner.

Dower of Insane Wife.

No. 318.

C. L. '15 (12725).

Petition to Bar Dower.

In Chancery.

The Circuit Court for the County of

(Title of Cause.)

To Said Court:

1. The petition of A. B., of, etc., says, that on, etc., he was lawfully married to one C. D., now C. B., who is a resident of, etc., in said county and State, and that the said C. B. is years of age; and plaintiff is now now about

about

years.

A. D2. That on or about the month of 19...., his said wife, C. B. became afflicted with cerebral impairment, causing her to become insane, in which unfortunate condition she has continued ever since, being now over two years last past; and by reason of such insanity, has been unable to join her husband, this plaintiff, in the conveyance of rea 1

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