The Salt Lake herald. [volume] (Salt Lake City [Utah]) 1870-1909, 1897-11-20
THE COMPLAINT.


In the unity court in and for the
county of Salt Lake, state OF Utah,
Ebenezer Shocks, plaintiff, VS.. Lazar-
ina Shocks. defendant.
Comes now the plaintiff and for cause
of action alleges:
1. That on April Fools day, in the
year of our Lord one thousand eight
hundred and ninety, and the 18th year
Of George Swan, the mower, the plain
tiff and defendant, III = drinking of
Dixey wine. were duly married at st.
George, Utah.
>. That ever since said time the plain
tiff and defendant have lived together
in that peace and harmony usually eX-
pressed by the phrase, monkey and
parrot time.
g. That the defendant, without plain
tiff's solicitation or request, has much
abused the plaintiff, frequently throw
ing him out of the second story WIN
dow of their home, using him as foot
ball, compelling him to eat cold lunches
and refused to provide for him Lroper
( food and raiment in harmony With his
social standing. thus causing him great
bodily harm and mental distress.
1. That the defendant not only ut
terry refuses TO provide for plaintiff,
but has often called him vile and OD-
probious names, such as pin headed
4ft3llC9. anu OIt6u Jun GO EJldllILtll "
stay at home and rock babies and wash
dishes, while the defendant, in disre-
gard of her duty, would stay out at
nights and endeavor to make the plain
tiff believe that she was attending po-
litical meetings.
The plaintiff further alleges, upon in
formation and belief. that there are
no children as the result of said mar
riage except 16.
Therefore the plaintiff prays that the
! bonds OF matrimony between himself
and the defendant be cut in two with a
meat ak; that the blanket be split, and
that he be forever set free from all OBJ
legations to the ACKNOWLEDGEMENT.
+ Plaintiff also prays that said 16 chill
, dren be presented to some orphans
home for ornamental purposes.
/ SCHROEDER & WESTERFELT,
Attorneys for Plaintiff.
THE ANSWER.
In the Unity court, in and for the
county of Salt Lake, state of Utah.
/ Ebenezer Shocks, plaintiff, VS.. Lazar-
! ina Shocks, defendant.
! Comes now the defendant, and in
prayerful humility submits this her
answer to the plaintiffs complaint
/ herein, and alleges:
Hirst-That it is true that she was
married to the defendant, but denies
/ that said marriage was of any force
or effect, for the reason that the de-
/ PENDANT herein was at the time of. un-
! sound mind and incompetent to con-
tract marriage, all of which is conclu-
! sively proved by the fact that she
would consent to marry such a per
son as the plaintiff.
Second-The defendant further al
! leges that if she has failed to provide
! the common necessarieS of life for the
plaintiff, that her failure is wholly due
| to the plaintiffs conduct, because the
defendant would have been elected to
the office of city auditor of Salt Lake
City had it not been for the fact that
the plaintiff made some campaign
/ speeches on behalf of the defendant
which brought about defendants de-
feat at the polls
Third-The defendant further charges
that the marriage between plaintiff
and defendant, referred to in PLAINTIFF
complaint, was procured by fraud or
the part of the plaintiff, in this, thai
the plaintiff, at the time of said mar
riage. represented himself to be full
grown and to have reached his major.
ity, when, in fact said plaintiff a.
that time wa.s q mere child. and has
been growing ever since, and acquired
such unwieldy proportions that his
presence inspired fear and trembling
to the defendant
Wherefore, The defendant prays tina
the plaintiff be kicked out OF court
that the marriage between the plaintiff
and defendant be annuiled upon thu
ground of defendants insanity anc
plaintiffs incompetency to contrac
marriage, and that the plaintiff be re
CURED by order of this court to bu,
a basket of champagne to be disposed
of by the court and it's officers
MRS. SHOCKS,
By Cherry & Fisher, attorneys 70
defendant.