The Wichita daily eagle. [volume] (Wichita, Kan.) 1890-1906, 1895-06-27
defendant has been guilty Of extreme
cruelty towards plaintiff.
THIRD CAUSE OF ACTION.

defendant has been guilty of extreme
cruelty towards plaintiff.
THIRD CAUSE OF ACTION.
Plaintiff makes ali and singular the al
! legations of her first cause OF action so
far as il relates to residence and marri-
age, a part of this her third cause OF
action, as fully as if set out herein al
leges that the same are true, and
states:
That for more than one year last past
the said defendant has been. and now is.
is, an habitual drunkard. and during
said time has been guilty OF habitual
drunkenness.
Plaintiff further states that during
the martial relations of the said par
ties. there have been accumulated as the
result Of the joint efforts and labors
Of said parties large and valuable
tracts of real estate in the county of
I Sedgwick and other counties in the
stae of Kansas. among which are the
following described parcels or tracts:
The east half of the southeast quar-
ter of section thirty-four go township
twenty-eight (2Sl. range two 90 east.
The west half of the southwest quar-
ter of section 80, township Is, range
east.
Lot 10 and fifteen feet off the west
side OF lot Il on Douglass avenue. in
English's addition 10 the City Of Wich-
ita.
Lots 12e and 1871 on Douglas avenue in
| Grieffenstein's addition 10 the City Of
Wichita.
Also a large number Of tracts Of valu-
able real estate in Smiths additions 10
the City of Wichita.
Also valuable real estate on Water
street in the City Of Wichita. all Of the
above being situated in SedswiCk coun-
~. Kansas.
Also valuable real estate IN the coun-
" of Finney and state Of Kansas.
All of the aggregate value OF ;owit.
Twenty-Five thousand dollars S25. o00l
That at the time OF the purchase Of
said lot y. and fifteen feet off the west
side Of lot y. on Douglas avenue in
EnShsh's addition - the City Of Wich-
ita. the deed therefor. by the consent.
/ arrangement and understanding be-
tween the granto- named therein and
the parties 70 this action. was made 20
the SAID plaintiff. naming her as the
grantee therein. with the agreement and
uuderSta ndirg that The said property
was 10 be the individual property OF the
said plaintiff.
That by he fraud ami wrongful act
Of somebody 70 this plaintiff unknown.
the said deed after Il had been left for
record was changed and altered by
/ erasiuC the word Rosa in the name ~
the granite. and inserting the word
Emil 50 as n make the name % the
grantee in said deed appear as Emil
Werner when the name was n fact and
should have appeared Rosa Werner
and that the - ne VS. done in fraud -
the rights Of this plaintiff. that said
property II. and OF right ought n ~
the separate and individual property
% Plaintiff.
That The said defendant also holds
under the name % the Wichita Hard
ware company but that the same i -
ally the personal property ~ SAID de-
PENDANT. a large and valuable stock n
hardware. IN the store nom OF lots 90
and f3f On Douglas aVe-N as aforesaid
which this plaintiff believes - be worth
and Of the fair market value - Ten thou
sand dollars isl0-efN and tazr tns sad
defendsn; i worth n fjs own name and
right from twenty-five In tRirty-tiye
Thousand dollars
That the plaintiff = the owner IN her
own name and right % The following