The Fairmont West Virginian. (Fairmont, W. Va.) 1904-1914, 1906-06-29
IN init, q short time beofre she married

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of his HABITS except what saescoul1
see OF him, OF the occasions when he
called on her. and at such times. the
defendent, took every precaut:on, to
pass for an excellent gentleman, and
that While Others. knew OF his faults.
they. as a mater Of courtesy, failed
TO disclose them to her, but that she
has learned since that the defendant
prior TO her marriage with him. was
notorious:y Hcentious person dis
solute IN his habits. and prodiSa1s to
all the decent and respectable ways to
society. but Notwithstanding all this
he ha1 superficial smoothness. cal
was not familiar with his blandish-
ments. and captivating in his manners,
on short acquaintance, and by reason
OF all these superficial claims this
plainuiss was induced to Nary him
Kat this plain''t and said defend
ant last lived and coa,,nitetl in Ma
ZION county. Yves: Virginia: that
1,..;ia,r: gave her sail husband 10
cause fo- his wilfu,'- abandoning and
desertinS her ard their family and
that said abandonment and jesertion
of he- and their family was wilfui
on his part and the same has contin-
ued to be wilful on his part 10 this
time. that he has declared his inten-
lions of never lining with this pain
tiff again
Plaintiff expressly AYERS that the de-
PENDANT is not a fl person to have the
care, custody and rearing OF their
three children. one of whom is girl.
nor has he any Bone or family to take
them TO. that they need the care AID
protection or q mother. and that the
defendant. would only ruin their lives
II they were 1ef, to his charge, since
they would more than likely partake
of his way Of tivins, and his habits
would die
That this plaintiff is a strong able
bodied woman, and has 4 good home
now. and she IS young. and will be
able to keep a Sool home for her CHI
dre1, that she is only willing to work
hard, thai. her children may be raised.
cared Tor AID educated. and placed In
the class of sccie:y. TO which they are
entitled. that this plaintiff IS a5sclnts
lrly temperate n al her habits. IL
dastrious. AID anxious to have sossie
dea. u.,cs. around whom her youAlS
and active energies may en:w1ne
Themselves. and that norh;nS VII so
please her, as 70 lsvote her who're
Ijce ;,.lJ attention 20, the raising u her
dear little children. \, i
Plaintiff turtle. aye-s and cha-ses.
:aat her husband the defendant dur-
ing tie t1:..e she 90 lived and coa2oiied
with him. was guilty Of adultery. with |
Iewd. ana .lascivious woiaen
and that while she IS not informed as
20 the names CT said women AID as 10
the dates Of such adultery. YET. SIC |
AYERS tra1 said adultery was commit
ted by !l.r;. II and about Sistersvllc. !
Q. house boats and other. places. also
n and around Huntington. AID di-
vers other places. TO this plaintiff IN
known. but that the., adultery. com |
2.alneu of was committed wishin .n"c
wears next before the bringing Of this
suit {; -. !
That said adultery was not cox
mitted by the procurement or .conn'- /
vance Of this plaintiff, that knowledge
did not cone TO this plaintiff of the
defendant being guilty of said ad"--
te-v until after he deserted her- and
This NiqIH-j
III should not now desire to longer
live and colah:t with him: that his
plaintiff has not Voluntarily or other
wise cohibited with said defendant |
since knowledge came to her OF the
fact of his having committed adu.-
terry. That 1ais plaintiff has nevei,
in any way ccndoned said offences 50
committed by her husband
That this plaintiff is entitled TO
come into your Hopor'S court and nae |
decreed her a divorce from the bonds
Of nat-izooy from the bonds OF mat
ri.nonv from her said husband for tho |
causes aforesaid, and to have decreE6 |
and entrusted. to her, the custody. care. I
control education and maintenance of
their children
Plaintiff be;z-S remeiilesS in the
premises. except in a court of equity
where matters of this kind are alone
and properly coS2izable. and wherein,
all grievances. Of like nature, are
Justly and eGuitabiy adjusted; there
fore prays that said James L. Coad |
be made defendant to this bill, ant:
he required to answer the same in