New-York daily tribune. [volume] (New-York [N.Y.]) 1842-1866, 1854-11-28
Law LVZkLLIG ENCE.
SuIT For DIVORCE.
CIRCUIT COCRT-Befooe Judge ROOSEVELT
MosDAY, Nov. 81, 1854.

Frances Child. bv Li,ssek " Simpson, Jr her friend
Solomon Chiios
Plaintiff alleges that abe was united to defend
according 70 the rites urages of the jews by the
Rev. J. J. LyoD a priest Ut that denomination, on
xOtb March 1850, Of the residence of the f,ther Of
plsinth, iii ,sio city. sbe being named Frances l..
Simpson, Of tho age Ut 10 years.
That said plaintiff and tho said defendant, at the
time of sao marriage until the abandonment Of said
plaintiff bereaiir mentioned were actual residents
sbo Inhabitants OF SAID city, and cohsbited together
there a. husban' ind wife, aud that the defendant,
at The comssion IT the several acts hereafter named
was aD actual hhabitant of the same.
That salo defendant, on or about October, 1850,
left laipti tho said city with the design, as he
stated 10 procte 10 the Cliy of Cincinnati for Ous
bess purposes aud with the intention Of returning
tbe,eiTom
Tiat ssid defendant instead Of returning to the
snid plaintiff as be promised, a6soi iteiy abandoned
h,r siuce the period OF his said departure, and
has rtnaiued abs.nt from The State of New York.
leaving the raid plaintiff 9i'bout any provision for
Ltr pabebapce, Dhd depeLdent upon her parents Tor
ler eupl or, with whom she now resides 10 the SAID
/ City OF New York.
That rh- issue Of the said marriage has been one
chic, bon l4th J.De, 1881, named Heary Washing
ton Cbids living wlh said plaintiff, al the resi-
srnce OF her parents Aforesaid.
int said defendant alter having so deserted SAID
plaintiff Aforesaid devoted himself to pr1higate
%. aoueToUs course Of life at said City OF Cmcin-
ost said defendant disregardipg the solemnity Of
ttry this plar,in states upon Information ana De-
hef with owes of lewd ADD dissolute char4c-
Ter, ut 'br house herein set oih slso, that he c)m
med adultery With a prostitute Sonsn whose name
IN unkpowo TO the paii TIFF at house of i'll fame IN
Wet rnrow, in .aid City of Cincinnati, kept oy
Bell Forrest; also with others III October ana NO
ytmber 1850, and February, March. Aprh, May,
JpDe July apo August ls52-of which she has 10
special knowledge Information SO as TO SET tor.u
more definitely uIso, with lesd women IN Jay 10
December 1852 at a house Of prostitution, No. 40
Eln-st CipcnI att kept by Ann Rlcbnood' oat tne
MINES Of raid women are uukDo sn to palutfi also,
NTH diner. Ut women at house OF prostitution kept
by Haoam Crosse III Fifth st. CDclbnatii also, at q
.milar bouse kept BY Jos~pbine Bates al e1Sern-
row aforesaid also, az sin'iar mouse hep. py L, .
Bori emnn il SIKH st., Cincinnati; also. ~ one KEPT
n, Mar, Hamilton in Vine st., near SJuth, Cinc'n,
nat-I6e lanes Of said wouen unknown to said
plaintiff. ,, .;.o ,ho co,,ni,
sion of sold sdu. intercourse, ana sue mas nor
Inhabited ith said plaintiff since she discovered sao
ac,a of noulter, bad been committed and they were
con nit ed without the consent, eohhi'a nce' Pi""'
or procurement OF sald plaintiff -.
that shiu defendant is POSSESSED OF properly n,oi1
than adeaunie Ia the proper support OF hiihSs enu
the ,aic p.intf and her child, according 10 'her ''a
ton IN life. -. hor
ard dtf,DdaDt be dissolved, aud tnat Tue sa'd t'y
ut provide suitable allowance 10 SAID Pitiutth
for her support and the support and eauoanoh VI N0'
clild &c ,o.-
Il l.
for ,l.i,iifl. aud Mts.rs. Henry II. Morange and A.
l.. JurcsL for defense ,...s
In Defense the marriage, az set iorta Is sllhl.eu
but def, sd.It ctLes thai at any hme ne aoshoous1
llaittf or that he became an actual rvs'eh' VI
n btbla1t of New York, but that he mas actusiy
rssioed sud did at tho time of tbs marriage re'iue
at ne City Of CincinI al. ;.
He also denies IN Il plsntlt, o. tue ,iihe " 'uo :N
wss an actual ,, sid.nt of the City also denies taa
be IT her in this City, or that he ever eit her VIII"
out any provision for her mHin,enauco -, IL
H. aiso den les all all the chsrges SET io'ln an t
con plant rs to the vaJious acts OF adauery oua5e
Ne forth.T says, that he has no kno sislse VI ~
mai ion ufcitLi 10 form belief aud c.n therefore,
neither aonnt nor deny as to whether tuere
Issue Of he aid marriage or whether, on the I''io
Jue, 1851 oBo Henry Washington 0hiius 10 III"
hNi1g with SAID plaintiff. -.
BE deDits that he ever at any time, devoted hin.
teh to pohigate sdulerous course OF me- tna'
Nc ever committed adultery IN regard TO the "on'H
charged, or any women.
BE further AYERS that his residence and place OF
bus Dess long before, aud since the said marriage,
wss and is at the City OF Cincinnati that the plain
uh sDi taid d.ieLcspt remained hare about Two
months after said marriage aad thea proceeded to-
eeher a. the CITY OF Ci0ciBnai for the purpose oil
there ptrmsnepty residing.
Thai said defendant occasionally visited New.York
City for the purposes Of business and there NAMED
thort time for that purpose aud did for that par
pcee on or about September, 1850, come to NeE-
York That said defendant eutreated and begged
the said defendant 10 permit her TO accompany him
10 New-Iwk; TO which ealo Defendant c'nssn'ed'
u,op The n iral understanding and agree nent how
ever that the sad plaintiff should return 10 the City
Of New York With ,aio delendsot
That having remained here s'out fourteen dsys'
hpo having COP cuded his business operations ne re-
uuerec The said plaintiff To return win SAID defendant
% Cpci. Dati but the said plaintiff absolutely re-
Ius.d 10 do 81, aud declined 10 accompany inc sslo
eeft rdapt to Cincinnati -, ,.;..;s |
He further states that the fsther Of said PNailn
promised and agreed with the sad dsicaasos
hat he tbould brsg said plaintiff " me SAL "
Cincinnati about iaeath thereafter ana 'ne sau u''