The record. [volume] (St. Maries, Idaho) 1913-1918, 1913-09-02

at Occur d'Alene. Idaho, by the
above named plaintiff against you
the said defendant
The said action is brought against
you for the purpose Of obtaining an
absolute decree OF divorce from you;
for the purpose Of settling the prop
erty rights of The parties TO said &C
ton; for the purpose OF restoring to
tie plaintiff her maiden name Of Sa
die b. Baldwin; aud for alimony, at
torney fees and costs Of suit aud for
such other and further relief as the
plaintiff may be in law aud justice
entitled TO.
The complaint alleges that you and
the plaintiff we're intermarried at
Moore's Greek, Kentucky, on Ooto
Der sth, 1908, aud ever since have
been and now are husband and wife !;
that the plaintiff has been a resident
aud citizen Of Idaho foI more than
six months last past aud has resided
continuously at st. Maries, Idaho,
for a period Of four years Immediate
ly preceding the commencement Of
this action; that since the said mar
riage, and for a period of time ex
ceeding one year Immediately proceed
ing the commencement of this action
You have refused, neglected and fail
ed to provide the plaintiff with the
common necessities Of life, because
Of your idleness, prohgaoy, and
dissipation, and have. for said period
of time contributed nothing to the
support Of this plaintiff.
And for a second aud further cause
of action against you the complaint
alleges that dlsregsrding your duties
as a husband toward the said plant
if, you have been guilty of habitual
intemperanoe for more than one veal
last past, to-wit That you have useC
Intoxicating liquors for more thar
Que year last past to such an extern
as to disoualify you greater part o.
the time from properly attending t.
business.
That there are two children the is
sue of the said marriage, Olaud, boy,
age five; Floy, girl, age six.
The complaint further alleges that
you are not a proper or fit person tC
have the care, custody, or raising OF
children, because of your evil habits,
drunkenness and dissipation.
You are further notified that the
complaint asks aud demands judg'
ment as follows:
That the bonds Of matrimony ex'
listing between yourself and defend
ant be dissolved.
That the plaintiffs maiden name be
restored TO her, Sadie e. Baldwin.
That the care, custody and control
of said minor children be awarded to
the plaintiff.
And for such other and further re-
lief rs the plaintiff may Ia law and
Justice be entitled to
All of which facts aud prayer will
! WUle luli9 ulbcnt rum tHo vein
complaint now on Gle 10 sal cause
at the Court House at Occur d'Alene.
Idaho, In the office Of the Clerk Of
the said District Court; ga d com
plant is hereby referred TO and b
incorporate herein and made a par
hereof.
You are hereby dir eted to appeal
and answer the said complaint within
twenty days after service hereof. H.
served within the Eighth judicial
District Of ths State of idaho. and
within forty days if served elseNhes
exclusive of the day of service).
Aud you are further notified tina
unless you so appear and answer Tho
complaint, as above directed, thu
plaintiff will apply to the court fo
the relief demanded In the complaint
Given under my hand aud seal o
the District Court of the Eighth Ju
diciul District of the State of Idaho
IN aud for Kootenal County, this 2stl
day OF July, 1918.
d. E. DANDY,
(SeaD Clerk.
WIN. d. KeetUn, attorney for I'll
plaintiff. Address and residence, st
Marjes. Idaho. a1-s5