Julia Ann Lewis
Petition for Divorce
Contributed by Betsy L.
Strader
Barren Co., KY Circuit Court
Filed 13 Nov. 1871
Julia Ann Lewis vs. John Lewis
The plaintiff Julia Ann Lewis states that she was intermarried with the deft. John
Lewis on the ___ day of ____ 1847 in the state of Virginia, and removed to Barren County
about twenty years ago and that they have lived together as man and wife in Barren County
ever since, where the matters herein after complained of occurred within five years-
The plaintiff further states that she has demeaned and hehaved herself towards the
deft. during the whole of the time they lived together as man and wife as a virtuous and
industrious wife, striving to assist deft in raising and educating their children-
She states that she is the mother of nine children- eight of whom are under the age of
twenty one years- and their names are as follows: David, William, Lewis, Jeremiah, Emily,
Mike, Duffy, Ann and Louisa-
She states that the defendant John Lewis has confirmed habits of drunkeness of not less
than one year's duration, accompanied with a wasting of his estate, and without making any
suitable provision for the maintenance of his family-
She further states that the deft has habitually behaved towards her for not less than
six months in such cruel and inhuman manner as to indicate a settled aversion to her and
to destroy permanently her peace and happiness-
She further states that the defendant has an outrageous and ungovernable temper and
that he has attempted to injure pltff and that there is danger to her life
________________.
The plaintiff states that the deft is desolute and reckless and dissipated in his
habits and makes no provisions for the maintenance of his family and that the pltff and
her children are the owners of a tract of land of about 100 acres in Barren County, KY on
which they reside and she states that she has by the exertion of herself and her children
accumulated the following personal property viz: 13 head of sheep- two horses- one cow and
calf- about 12 or 13 head of hogs and there is on the farm a crop of corn and some oats.
She states that the deft claims one horse and __________ the 12 or 13 hogs-
She states that the deft. will fraudulently sell, convey or conceal his property or
remove out of the state to prevent the pltff from getting the necessary maintenance for
herself and children- Wherefore she prays for a divorce from the said John Lewis and that
she be restored to all the rights and privileges of an unmarried woman- and that the deft
be restrained from selling and disposing of the 13 head of sheep- one gray horse- one cow
and calf and the corn and oats until the final trial of this cause and she prays that an
attachment issues to afsd respt for the black horse and the 13 head of hogs and that they
are delivered to pltff to assist to supporting defts family- She prays that she ______
adjudged the care and custody of her minor children- and she prays for all proper relief-
Bohannon and Porter Atty for plaintiff |
