The New York herald. [volume] (New York [N.Y.]) 1840-1920, 1865-11-25
THE STRONG DIVORCE CASE.
The Preliminary Pleadings HAd
Issues.
OPENING OF THE CASE FOR TIKI. PLAINTIFF.
address Of the ccAnsei for the
Husband.
THE HISTORY oE THE CASE REVIEWED,
The Time, Places and Circumstances. OF the
Alleged Criniinalitles.
Ne. lie. &e.
Superior Cours-Triai Term.


Superior C0urr-Trial Term.
Before Judge Garvin.
Tho ralcf the divorce suit Of Strong Strong com
nenced in this court yesterday forenoon The SESSION OF
the day was entirely occupied in the opening address Oh
Mr. Cram one Of the attorneys for the plaintiff
THE HISTORY OF THE CASE
7he promises 10 be Of the Interesting charac
ssr nes only IRON the circumstances upon which the
applications for divorce founded but from the re-
spcctabty and well known social standing OF the parties
connected with IL The suit is what Is sometimes iamil-
ariy called .scross suttha Is both parties sue for
of divorce and the custody the children Of the
marriage From the following pleadngs and issues, the
ntatory steps 70 trial. well from the opening
remarks Of the plaintiff attorney the reader will obtain
. ssccinci history Of the case.
THE ORIGINAL COMPLAINT.
spPERoR COURT, THE cry or NEW YORK.
o~s-Peter Strong, the paintin in this action com
plains Of Mary Strong the defendant herein, and
20 ay Of NAV @ he se sa ID on
duly and lawfully married to the said defendant Mary E.
Strong Mary f. stevens That at the time Of such
marriage tho SAID plaintiff and said defendant wore, and
ever since have been and Inhabitants and
residents Of the State Of New York, and
such marriage and until the discovery Of tho an
terry Of the defendant hereinafter mentioned the said
plaintiff and defendant cohabited together and
WIFE, and had issue Of the said marriage three children,
viz one born in the month OF AprA in the year 1854
another born in August 1859 both female children, and
living the third born October IS, 1860, and who
died the second day Of January, 1862 That tho said
defendant disregarding the soemnity Of her marriage
vows hath, at various times and places the
rage Of the plaintiff with her. aforesaid committed
adultery with Edward N Strong and especially that
9th day Of April in the year 1860 and various
ether days in the said month Of April aud also on seve
raj days in the respective months OF May, June, July
and August OF the said wear 1880 the said defendant did
commit adultery with the said Edward ~ Strong and they
had frequent carnal connection ether but what par
ticuar days Of such months respectively, other than
~..A III xtrf Arrfl nffnt A,srtpv thn
months respectively such adultery committed this
plaintiff Is ignorant and fully particularly
state That such adultery committed at and within
the of Newtown in the county OF Queens and State
Of New York, where the said plaintiff and the said de-
PENDANT and the said Edward N. then resided That
and during the months OF January, February May and
June and the first twenty days Of October in the year
1851, and divers and several days in each of such
months the said defendant did commit adultery with the
said Edward N and that they had frequent carnal
nection with each other but Of the particular days in
such months, in either OF them which such adul-
terry committed the plaintiff is ignorant, and cannot
moro fully or particularly specify the same And that
Newtown aforesaid That from and the 10th day Of
October 1884, and until about tho 14h day Of December
in SAID year. and also from and about the oath day Of
December until the 10th day OF said month, in
said year. and on one more days OF each
month comprised in said periods she said de-
PENDANT did commit adultery with the ~ Edward N,
and they had carnal connection together but Of the par
tcular days during said periods which such adultery
committed the plaintiff is ignorant and cannot
fully specify the same; but that such adultery
mtted at house situated Twenty first street, In the
city OF New York, and known n No. 90 East Twenty
Ast street in said city That al sometime in the month
Of July August in the year 1862 the said defendant
did commit adultery with the said Edward NJ and that
they the said defendant and said Edward NJ had carnal
connection together at house in the city Of New York.
the State OF New York, known No. So Blocker
% month Of 0a. or on Of s d su q
terry was committed the said plaintiff is igno-
rant and cannot more particularly specify the
That the plaintiff was wholly ignorant Of the commits
by the defendant OF the aforesaid OF adultery
or Of either Of hem until the 9TH day Of January 1882
NJ bnya mt hQ fho
fact that such adultery had been committed by said de-
fcndant that he has not cohabed with said defendant
nce the discovery thereof that the said aduteres have
not has either Of them been forgiven by the said
plaintiff and that the and each Of them
scni connirsncs ne nriv,v ar nrocn%ement ' and
the plaintiff further says that Eve years have not
discovered by him, and that this plaintiff
has not himself been guilty Of adultery Wherefore the
plaintiff demands Judgment that the marriage between
divorce may adjudged according 70 the statute in
such made and provded that the and custody
aid Judgment awarded TO the said plaintiff and that
he may have such other further relief in the premises
- 70 the court shall seem juse and equitable.
THE DEFENDANTS ArswgR
The defendant admits the allegations In the complaint
- this action respecting the marriage and residence Of
The parties and the birth and death Of the children
son in shs complaint For further and separate de-
fence the defendant saith that the plaintiff ought mot
q sSs same because sSs sys sS.s 4. Inc allegations
b the compliant were true hs PLAINTIFF With full know
: e sns ss aSa sssIs the same
IA DEFENDANTS SUPPLEMENTAL ANswRn. :,
7he supplemental answer q the above named defend.
ant 70 the complains In this acton BY Noyes Tracys
ID 70 the masters and facts By her heretofore alleged
and stated her former answer 70 hid complaint fur
Ika-Thai At the respective times u tho oommssiou
e she several acts q sdusy y the plaintiff herein.
sler mentioned both the plaintiff and defendant were
ant At the time Of the commencement OF this action,
actual inhaDant Of this state; and that at the
made she ignorant Of the adulteres hereinafter al
leged, and Of every Of them.
and in the months Of October November and december
1851, and January, February March and April and mp
70 and including the LIST day Of May 1852 but upon what
now accurately specify the plaintiff, at the house No
iol waverley place in the city Of New York, and at
divers other places in said city, which the defendant IL
not able particularly TO state committed adul
tory with one Eecta NJ Potter.
NwtA-That between the frs, day OF May, 1892 and
June, July, August September, October November and
December 1854 and several times in each and all Of the
sasd months IN the said year but what particular
days the defendant is not now able TO state; and
IN tho moaths Of January, February, March,
Ocsober November and December In the wear Iss3'
and several times In each and all Of the said months n
the said year. and nj times during months Of
January, February March and April, 1884 but on what
particular days the defendant is now unable par
fcuInrly state, the plantn, In the house No. f24
waverley place, In said city, and ut various hotels and
divers other places in said city, which the defendant
not now able more particulary TO specify, committed
adultery repeatedly with the said Electa N. Potter.
Fyfh-That between the first day Of May, 1894. and
ths hereof At the house $50 Sixth avenue In the
c Of New York. and divers other places In sad city
which the defendant unable more particularly TO
state and various times and various days which
The defendant cannot hero more particularly mention
the plaintiff agnn and repeatedly committed adultery
with the said Electa N Potter
sevent-That the adulterss herein above alleged 70
have been by the plaintiff committed were by him 40
committed without the consent connivancA pr witty or
procurement Of this DEFENDANT that i've years have not
elapsed since the defendant discovered the fact Of such
ndultees, any Of Them that the defendant has not
voluntarily cohabited with the plaintiff since such
Giscovery Wherefore the defendant AYERS the fore
going facts In bar Of this action and Of the
demand for relief therein contained and ~ .