The Wichita daily eagle. [volume] (Wichita, Kan.) 1890-1906, 1904-02-13
PETITION.

last past a DDlld noe ana actual ftSltleill
of Sedgwick county, Kansas. and that
she is now Il resident in good faith of
sale county and state.
The plaintiff alleges that she and the
defendant were. on the 10Th day OF Feb
ruary. A D.. 1885, in the city Of Indian
apolis, Ind, duly joined in marriage, and
that the relation of husband and wife
now exists between them.
THAT there has been born to them as
the fruit of said marriage the following
named children: Marguerite Bain, 10
years of age; Frank Balm. II years of
age, and Ruby Balm, : years Of age.
THE plaintiff says that for more than
one year past the defendant has been
and now is an habitual drunkard. and
has been guilty Of habituaI drunkenness.
For a further and second cause of
action, the plaintiff makes all of the ale
cations as TO her residence and her mar
rage with the defendant part of this,
her second cause of action. and says that
the defendant has during the last six
months at divers times and sundry places
fn the city of Wichita, the exact time
and place of which are unknown to this
plaintiff, been guilty of adultery with
women. the names of whom are to the
plaintiff unknown.
And the plaintiff further says that on
the 18th day of February. \. D. 1894
in the city of Wichita, the defendant
was guilty of adultery.
III.
THE plaintiff. for a further and third
cause of action against the defendant,
makes all the allegations contained in
her first cause of action as to her resi-
dence and marriage with the defendant,
a part of this. her third cause of action.
and says that on the 18th day of Feb
ruary. \. d. 1904, in the city of Wichita.
Kan, and at the Santa Fe hotel in said
city said defendant was guilty of ex-
treme cruelty toward this plaintiff, and
that he did then and there hit, beat and
bruise this plaintiff with his fist.
".
THE plaintiff alleges that the defend
ant is the owner Of six unimproved lots
on the corner Of Harry street and Meade
avenue in the city Of Wichita. the value
of which the plaintiff is not advised;
that he is also the owner of certain per-
sonal property. goods. wares, merchan-
disc household goods and hotel fixtures.
situated in the Santa Fe hotel in said
CITY. of about the value of five thousand
dollars.
The plaintiff further says that he has
about fourteen hundred dollars in cash
deposited with the Fourth National bank
Of the city of Wichita.
V
'"The plaintiff alleges that she has no
the defendant is not a lit and proper per
son TO have the custody of their children
hereinbefore mentioned.
''Plainuff further says that the defend
ant will sduander, dissipate, secrete ard
dispose Of the personal property and
money hereinbefore mentioned. unless re-
strained by an order of this court
That the plaintiff is without means
of support without means 20 employ
counsel and defray expenses of this
cause. and without means TO support
and maintain her said children.
The plaintiff says that she is in peril
from great bodily harm at the hands Of
the defendant; that he IS under the in
fuence Of liquor most of the time. and
as such times is dangerous. and the plain
.lnf fears that he viii iutiict upon her
and their children bodily harm unless
restrained from going upon the prem
ises occupied by plaintiff, and about her
Wherefore. the plaintiff asks judg-
ment against the defendant for perma-
neut alimony in the sum of ten thousand
dollars and that she be decreed and given
all of said property above mentioned
and that she have the custody of their
said children; and she further asks that
the said defendant be required 10. pay
for temporary alimony in such sum as
to the court may seem just and proper
Tor her support ana maintenance. and
such sum for attorneys fees and eN-
pcnses Of the preparation of this cause
as may seem proper; and that on the
final trial she may have all such other
and further relief as may be deemed just
THOMAS Il. WALL,
ADRIAN :. HOUCk.
Rf,E ~-fs