The Rathdrum tribune. (Rathdrum, Idaho) 1903-1963, 1906-12-07
Alias Summons.
IN THE DISTRICT COURT, First judicial
District of the State of idaho, III ana Tor
the County Of kuotenai.

~
District of the state OF idaho, III ana ior
the County of kuotenai.
Josephine Unger. Plaintiff, Alias
VS. Sum
Oscar Henry Unger, Defendant.i 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 of the Dis.
trict Court of the First Judicial District OF
sand State in Rathdrum. County OF koote-
mai. the complaint of the above named RAIN
tiff, wherein it is sought to dissolve the mar
riage between Plaintiff and Defendant ana
divorce decreed according to the statute III
such case made ana provided, ana That tue
custody, control and possession OF the minor
child issue Of said marriage, towit: Mabel
Frances Unger be adJudged TO the PlaintiH.
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 OF saloon business at riverside IN me
County of Woodbury., State of Iowa. ana
that during said marriage particularly dur
ing the years 1903 and 1904 Plaintiff was coul-
PEELED by the Defendant. against her wlll
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 III contact with prOfane
and drunken men aud women who frequent
ed and palrOnlZed the Defendants saloon
business, That Defendant also kept in his
said saloon a number of vile and lewd
women as habitants and frequenters of the
Defendants said saloon, and the Plaintiif.
against her Will and over her earnest and
indignant protest, was compelled by the De-
PENDANT. during the time herelnbetore men,
toned, to come in contact with and associ-
ate with said abandoned women PIaintiif
also was compelled To keep with ner in said
saloon her little girl, who .-lso 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 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 grievous mental suffering;
but caused her physical health to suffer to
such extent as to iniiict upon her ,grievous
bodily injury That during all the time
that Plaintiff and Defendant lived together
! as man and wife, PlainIitf endeavored to DO
her full duty as wife To 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 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 ofany kind from the Defendant since
Plaintiff and Defendant separated. All of
which facts are more fully set forth In Z LATIN
titf's verified complaint on file herein, a 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, If served
within kootenai County, and within twenty
days, il served out of said county, but with
in the said Judicial District, and within
forty days. If served out of said District,
feXclusive of the day of servce), 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
X Jof November, A. d. 1906
- ~ L. l.. QUARLES, Clerk
by James A. Foster. Deputy.
CHAs l.. HEITMAN. After ney for Plaintiff
Residence and Post Office Address:
Rathdrum, Idaho. nayl6 deco1