, 1860-04-18

10 the Honorable Gs0rgs Adnniere. Juags OF
tie Circait Court ef Cool County in Gdaa.
CRY, sitting:
Humbly complaining showcth unto your
Honor, your orator, Isaac Il. Durch, of the sity
of Chicago, County of Cook and State of Illi-
nois, and now the husband Of Mary #. Burcb,
that On or about the e5th day Of May in the
year one Thousand eight hundred and forty.
eight, 4. D. 1S43, your orator intcrmarried with
the said Mafy W. Dnret in the city and county
Of Albany in the State of Sew York, and l,a.
continued to i've with the said Mary W luscl,
from such period until shortly before the pres
eut time Ms her husband.
That immediately after suctl intcrmarriace
the said Mary ". removed 10 Chicago. aud that
from the time Of such removal your orator and
the said Mary " has been, and ut the time and
times Of the commission Of the ndu1terv berein-
after set forth they we're and no. are inllabi-
tants of and residents in this state, And your
orator further slows that during his iuter1nar-
rage with tie said Mary W., she l1as had two
children By your orator, both Of whom arc now
liring, riz: Mary " Burcb, who is Of the arc
Of ten years md ten months, and Harriet Cor.
ming Burch. who is Of the age If one wear and
eight months. Ard your orator further shows
that be is informed and believes and charges
the truth to be that the snid Mary ", dsrczard.
ing the solemnity Of the marriage VOW has Since
the marriage Of your orator with her committed
adultery at divers places; and especially that
the safd Mary ". on or about the fourteenth
day Of October, in the year eighteen hundred
and fifty.seren "A. D., 1851 in the city uf Chi.
cago in the county Of Cook, and State Of Illinois
d'd commit adultery, and have caruat connec-
tion one David Stuart; and your orator BY way
Of amendment further shows that he is inform
ed and believes. and be charges the truth 10 be
that the said Mary ". on some dar or days
during tho moHta1of February, March, April,
Asy and June, in the year last aforesaid, but
Oh what day Or days in particular your orator
is ignorant, did commit adultery aud hare car
nal conne1ion with the said David Stuart at
the city Of Chicsgo in the county Of Cook afore.
said.
Aud your orator By way Of further amend.
ment shows that be is informed and believes
and charges the truth to be that about t,le
twenty-fourth day of December IN the wear
last "a ~. .aforesa'd: at the ctr Of Chicago,
carnal connection with the said David Stuart,
aud that the said Mary ". did at various other
times dunug the months Of September, October
November and December in such year, commit
adultery and hare carnal connection with The
said DaEld Stuart at the city Of Chicago in tue
county of Cook aforesaid.
And your orator, by way Of further amend.
ment, upon his belief further charges. that The
said Mary ", on some day or days during The
month Of November, in the year eighteen hun.
dred and fffy-eight, but on what Gay or days in
particular your orator is Ignorant at the CITY of
Chicago in the county Of Cook aforesaid, did
commit adultery and hare carnal couucction
with the said David Stuart, and that the said
Nary ". did at various other times during The
year eighteen hundred and tfly-eight, and at
various other times during the year eighteen
hundred and fiay-nine, aud since that time,
commit adultery aud hare carnai connection
With the suid Darid Stuart, at the said citv OF
Chicago in the county ofCook aforesaid.
lonr crater, upon his belief, further charges,
thct the snid Mary ", between the fourteenth
1ay Of October, A. D. 1857, and the scsontecpth
day Of January, 4. D. 1860, did commit adut-
teEr aod have carual connexion with divers 9th.
er persons whose names are unknown to your
orator.
And your orator, br war Of furtl,e. amend
men. .,upon his belief further charges that the
said Mary W.. on some day OF days during the
month OF August, in the year eighteen hundred
and htty -nine, but On what day or DAYS in par-
tlcular your orator is unable to state, in the
Town of Guil!ord in the County Of New Haven.
in the State Of Connecticut, committed atlnl.
tery and had carnal connexion with person or
With persons whose names avc unknown to
Vour orator.
And your orator further shows that he has been
gnorant Of the commission Of the aforesaid
said acts Of adultery or either Of them, or any
,ther acts Of adultery Of said Mary II, until {
he l7th day Of January, A: D. 1st9, aud thas |
1e has not voluntarily cohabised rith the said |
dary ". since the discovery thereof and thut |
uch adultery Vas committed without the con-
'ent, connisAnee, privity or procurement Of
eour orator- -
In consideration wher& II and to the end tb,t
be said Mary v: may full, true md perfect |
nswer make to al and angular the premises,
nd that The marriage between your orator and |
be said Mary W. may be dissolved aud a di.
orce decrecd according to the statute in such
use provided and that your orator NAV haze
uch further relief in the premises as shall be
may i please your Honor to grant
INTO Jour orator the People's Writ Of Summons,
.sning out Of and under the seal Of hi. Honor
lie Court, directed to the said Mary ". i}u1ch.
hereby commanding her, at certain day and
nder certain penalty therein to be expressed.
. be aud appear before your Honor in this
honorable Court, then and there to answer The
remises and to stand to abide such order and
ecree therein, as to your Honor shall seem meet
nd agreeable to equity, and your orator viii
ray, &c, Isaac Il. Drncu.
HixAx L. Lz~m. Complainant. ol;e.,or,
uotxE & MILLER and WAlkKpkF FAS ARxax t,oon.a1 |