The New York herald. [volume] (New York [N.Y.]) 1840-1920, 1861-10-31
The Petition OF Adah Isaacs Mcnkin
for Divorce from John G.. Hcenan.
MHENRY COUNTY GLLINoIs) CIRCUIT COURT, OcTO.
Der TERM, A. d. 1861.

IN CTANtERY.
To the Hon A. C. Fuller Judge OF said Court In hancery
Humbly complaining unto your Honor, your orarrix,
aforesaid showeth that the Sd day Of September A. D.
1859 your oratx intemarred with John G. Heenan,
whom your orarix prays may be made party defendant
hereto, and from thence hitherto has been true and
faithful wife TO her said husband
And your orarix further shows unto your Honor that
at the time Of her marriage with said defendant az aore
sad she was possessed OF considerable money and means
and that upon the marriage she placed the whole amount
OF the same at the disposal Of said defendant and that he
has squandered the whole amount thereof. and all that
your oratrx could earn unti the time OF their separation
as hereinafter stately since, in dissipation and gaming
and other improper and immoral practices
That, soon after the said marriage to wit about
the 5h day of January 1860 the said defendant depart
ed this country and went TO England leaving your ora
aforesaid she sent to the said defendant all the money
she could earn in her profession actress save only
enough for the economical support and maintenance Of
herself and child the child being the only issue OF
said marriage, and since deceased.
And your orarix further shows your Honor that
since tho Of the said defendant from England
some time IN the month Of August 1850, he has utterly
and entirely abandoned and neglected your orarjx and
has neglected and refused 70 provide or assist to pro-
vide for her maintenance and support that in fact the
said defendant since his ge with your oratrX as
aforesaid has never contributed to the support of your
oratrx but on the contrary has used and the
means Of your oratrx and has manifested feelings OF at
tachment and regard for her only long she could
supply him with money for the purposes Of dissipation
and when she had no more to give has treated her with
the utmost contempt, neglect and disregard.
And your oratrx further shows unto your Honor upon
Information and belief that since the return Of the said
defendant to this country, aforesaid he has lived in
open and notorious adultery with some woman to your
oratrx unknown, and continues to live that the said
defendant is person Of VIGOROUSLY profigate and aban-
doncd character, and is, as arc hia companions and
friends utterly unit for the society and copanionship OF
your oratrix; and that her connection with him is
Of constant dsrespect and insult to your oratrx
and constant obstacle in the way Of her success in her
profession, upon which she depends for support.
And your oratrx upon information and belief further
soweth unto your Honor and expressly charges fact
10 be, that como time In the month Of November Last TO
wit, on the 10Th day Of November, $780, and on divers
other days immediately preceding and subsequent there
10, the said defendant did commit adultery with one
Harriet Martin, In the city Of Chicago and State OF I'LL
nos. All which actngs and dongs Of the said defendant
are contrary TO equity and good conscience tend TO
the manifest wrong injury, disgrace and oppression Of
your oratrix.
In consideration whereof and forasmuch as your ora
trix s remcdi'ess in the premises at common law aud
can only have relief in tho Court Of Equity.
To the end therefore, that tho said John c. Heenan
may full true and perfect make to all and sng
lar the matters and things herein charged without oath
the same being hereby expressly waived, according 70
the STATUTE and that the said marriage between yorr
oratrx and the said defendant, John c. Heenan be an
Of this honorable court and that your oratrx NAV have
such other and further relief in the premises as the ma
turo Of her shall require and to your Honor shall
meet:
May u please your Honor TO grant unto vour oratrx
the writ and summons, 70 be issued Of ma under The
seal OF the court, to be directed the said John @ Hoo
commanding him to be and appear before this honor
able court. according to the practice thereof and 10 an
swer AL and singular the premises and to stand TO- abide