The Rathdrum tribune. (Rathdrum, Idaho) 1903-1963, 1906-11-30
Alias Summons.

IN THE DISTRICT COURT, First judicial
district Of the State Of idaho, In and for
the County Of Kootenai.
Josephine Unger, Plaintiff, Alias Alias
VS.. sum
oscar Henry Unger. Defendant mons
THE STATE Of IDAHO,
To Henry Oscar Unger, the above named
Defendant:
~you are hereby notified. that there Is now
I on file In the office OF the Clerk q the DIS
trict Court Of the First Judicial District OF
said State In Rathdrum. County OF h ,I
mai the complaint OF the above named ram
til, wherein it Is sought to dissolve the mar.
rage between Plaintiff and Defendant and
divorce decreed according to the statute III
custody. control and possession OF the minor
child. issue OF said marriage, t0wit; Mabel
Frances Unger be adjudsed to the PiaintiH.
That since said marriage the Defendant
has treated the Plaintiff In cruel and In
human manner ana In particular as follows:
That during the time the Plaintiff ana De-
PENDANT lived with each other after their
LIQUOR or saloon business at Riverside, in the
County of Woodbury., State OF Iowa, ana
that during said marriage, particularly our
ing the years 1903 and 1904, Plaintiff was com
PEELED by the Defendant. against her will
ana her earnest protest To work In the De
fendant's said saloon at Riverside, and TO
sell intoxicating liquor from behind the bar
OF his saloon as Il bar maid, and was thereby
compelled to come in contact with pr0fane
and drunken men and women Tho frequent
cd and putronized the Defendants saloon
business, That Defendant also kept in his
said saloon u number OF vile and lewd
women as habitants ana frequenterS or the
Defendants said saloon and the Plaintiff
against her will and over her earnest and
| indignant protest, was compelled by the De-
PENDANT, during the time hereinDefOre mem
toned, to come in contact with and associ-
ate with said abandoned women Plaintiff
, also was compelled to keep with her in said
| saloon her little girl, who also came In con
tact with vile men and women. That by
reason OF said cruel and inhun.an treatment
on the part OF the Defendant, Plaintiff was
compelled to leave and did leave the De-
| PENDANT. and has not lived with OF cOhabited
with him since Plaintiff left him, on or
about tho month OF October. 1904, and Plain
| till has resided separate and apart from DE
PENDANT ever since that time. That said
cruel and inhuman treatment inflicted upon
Plaintiff not only grievOuS mental suffering;
but caused her physical health to suffer to
such xtent as to infiict upon her grievous
bodily injury That during all the time
rs man and wife, Plaintiff endeavored to do
her full duty rs wife 10 the Defendant and
was willing and anxious to make their mar
| and that none OF the conditions which made
| their married life intolerable were brought
about or caused, either directly or Indirect
/ ily, BY any act or fault on the part of the
Plaintiff. That the Defendant is not a fit
! person to have the care, custody and control
OF the infant child the issue of said marriage
That the Plaintiff since she has been living
separate and apart from the Defendant. has
! been compelled to support herself and her
little child by her own labor. and that she
has received no support or financial assist
ance OF any Kind from the Defendant since
Plaintiff and Defendant separated. All Of
which facts are more fully set forth inPlatn-
tif's verified complaint on file herein a Ger.
tiled copy of which IL attached hereto and
made part hereof. to which reference is
hereby made.
And you are also Notified That unless YOU
appear and answer to said complaint within
ten days after the service hereof, IL served
within kOOtenai County and within twenty
days, II served out of said county but with
In the said Judicial District and within
forty days, II served out of said District.
Exclusive OF the day OF service), the Plain
TIL will apply to the Court for the relief de-
manded In said complaint.
Given under my hand and the seal of the
District Court Of the First Judicial District
Of the State of Idaho in and for the
:(0EAI \COunty OF Kootenai this 18th day
NIX )Of November, A. d. 1906
7. l.. QUARLES, Clerk.
by James A. Foster, Deputy.
CHAs, L. HEITMAN ATTIC rney for Plaintiff.
Residence and Post Office Address:
Rathdrum, Idaho. navl6 decel