The Wichita daily eagle., 1897-04-07
Benjamin Jackson.
Maria Snowder. also known as Maria
Jackson
PETITION.

Now comes Renjamin Jackson. plain
tif, in the above entitled cause, and for
his cause Of action alleges:
F!rst--That he is now and for more
than fifteen years past has been a bona
fi1e resident of the state of Kansas. and
now resides al Wichita. in the county of
Sedgwick
Seocnd-That prior to the civil war he
ana The defendant herein were slaves in
J the state Of Missouri and were according
! 10 the custom OF slaves az that time in
, said state of Missouri. married in De-
cember, 1858, and were under said laws
governing the marriage of slaves known
and recognized as husband and wife un-
| Ill the summer Of 1859. when defendant
! herein was sold by her master and own
er and taken cut OF the state OF Missouri.
and this plaintiff and defendant and
| plaintiff herein were separated and no
| longer known and recognized as husband
and witt.
Third-That eaid slave laws and ac-
cording to aforesaid custom this plaintiff
and one Nancy Bates were married in
1860. enl were then and there and for
three years thereafter known and recog-
niz=d as Benjamin Jackson and his wife
Nancy Jackson, until 1865. when this
plaintiff entered the federal army and
was with MS command taken south into
the STATE OF Louisiana and served his
country we'll and faithfully until 1855.
when ne returned to the state OF Ms
souri, and was reunited in marriage tn
said Nancy Bates as this plaintiff sup
posed according 20 me old slave laws
aforesaid. but in truth and reality were
legally wed and married as made and
provided in the statutes OF Missouri.
Fourth-That his plaintiff and Nancy
Bates were duly and legally made hus-
band and wife on the 18th day Of Au-
gust, 1866. ana said Nancy Bates and
Benjamin Jackson have been recognized
ever since as husband and wife and are
now husband and wife.
Fit;h-That plaintiff and Nancy jack
son (nea Nancy Bates lived and resided
together as husband ans wife. en- njoying all
the martial relations o. the family and
comforts OF home. where husband and
wife. fathermother. husband and child
ren dwell around the sacred altar OF the
family circle from the 2sth day of Au-
gus 1879. s4i4 Al- N49c- % TIE year 1876.
Six:h-That IL vas about the close 90
the year 1877 that his plaintiffs first and
early love. the defendant herein and BY
her wiles and cunning ways. induces this
plaintiff 20 leave his happy home and
family and take VI rs abode with he-,
and hey lived together from ISIS. til
Octoher 1895
Ssvsnth-That n September. 1855. de-
teaiani induced plaintiff :nasmuch a.
they were residing in Ire state 81 Kan
sas. that We should oe wed5=1 and mar.
red according to the laws of said state.
Eigh:h-That said plain.iH and DEFEND
ant procured marriage license from Ire
PROBATE judge ot Treso county. ard xere
BY him married on ,hs i9;h day OF Sep
tsnbe-. 1898
Ninth-That it i tsct that a. n.
tine OF such marriage szi1 plaintiff had
a former wife Twins ard plaintiffs mar
rage 70 said former wife was On the i7th
dsy % September, 1ssS. n faG farce ard
efTscs. ana that marriage on TIE :7tn
day ot September. isss. Is auI sad va.
Wherefore. piasatiH prsys judSnez:
and decree Of anaullnent. sad sscs otasr
rslies as shall be tosI and equitable
Defendant Mara SaoTden. zfso
kno~n as Mara Jackson alleges ia.
shs denies such allegzisoas each ard ssT-
s.slly. except ths toI.3Eszg:
Sae was married 70 Mr. Jackso1 In