The Rathdrum tribune. (Rathdrum, Idaho) 1903-1963, 1906-12-21
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
VS.. Sum-

District of the State of Idaho, in and for
the County of Kootenai.
Josephine Unger, Plaintiff, Alias
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
l on file in the Office of the Clerk of the Dis
trict Court of the First Judicial District of
said State in Rathdrum. County of Koote-
nai,the complaint of the above named Plain
tiH wherein 1T Is sought to dissolve the mar
riage between Plaintiff and Defendant and a
divorce decreed according to the statute In
such case made and provided and that the
custody. control and Possession of the minor
enid, issue of said marriage. towt Mabel
Frances Ungef, be adJudsed TO the Plaintiff.
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 and De-
PENDANT lived with each other after their
said marriage, Defendant engaged in the
liquor or SALOON business at Riverside, in the
County Of Woodbury., State OF Iowa and
| that during said marriage, particularly dur
ing the years 1903 and 1904, Plaintiff was com
PEELED by the Defendant against her will
ana her earnest protest tn work in the De-
| tendants said saloon at Riverside, and to
| sell intoxicating liquor from behind the bar
of his saloon as IA bar maid, and was thereby
Compelled to come IN contact with prOfane
and drunken men and women who frequent
| ed and patronized the Defendants saloon
| business That Defendant also kept in his
| said saloon number of vile aud lewd
women AS llabltants and frequenters of 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 hereinbefore men,
| 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 lutte girl who also came in con-
tact with vile men and women. That by
reason of said cruel and nhun.an treatment
on the part of the Defendant Plaintiff was
compelled to leave and did leave the De-
PENDANT and has not lived with or cohabited
| with him since Plaintiff left him, on or
about the month Of October. 1904, and Plain
| tiff has resided separate and apart from De-
| PENDANT ever since that time. That said
cruel and inhuman treatment inflicted upon
| PLAINTIFF not only grieyous mental suffering;
| but caused her physical health to suffer to
such extent as to intiict upon her grievous
bod y, injury That during all the time
! as man and wife, Plaintiff endeavored to do
her full duty as Il wife 10 the Defendant and
was willing and anxious to make their mar
RED life c"ngenial and their home happy,
and that none of the conditions which made
| their married life intolerable were brought
about or caused, either directly or Indirect
, ly, by any act or fault on the part of the
Plaintiff That the Defendant Is not 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 inPlain-
| titf's verified complaint on file herein, d Ger
tilted copy of which is 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, If served out of said county, but with
in the said Judicial District, and within
forty days. If served out of said District,
exclusive of the day of service), the Plain
tiff 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
seal County of Kootenai this 18th day
- ~ I. H. QUARLES. Clerk
by James A. Foster, Deputy.
CHAs. L. HEITMAN, Attorney for Plaintiff.
Residence and Post Office Address:
Rathdrum, Idaho nav16 dec2l