The record. [volume] (St. Maries, Idaho) 1913-1918, 1913-08-29

Of idaho. IN and for Kootenai County
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
tion; for the purpose OF restoring to
tee plaintiff her maiden name Of Sa-
die r. Baldwin; and for allmony, at
torney fees and costs Of suit aud for
such other and further relief as the
plaintiff may be in Law and justice
entitled to.
The complaint alleges that you and
the plaintiff we're lntermarried a.
hloore's Greek, Kentucky, on Ooto
Der sth, 1908. aud ever since have
} cen and now are husband and wife;
that the plaintiff has been a resident
aud citizen Of Idaho fui more than
elk months last past aud has resided
continuously at St. Maries, Idaho,
for period of four years Immediate
ly preceding the commencement Of
this action; that since the said mar
risRe, and for a period of time ex
ceeding one year Immediately preceds
ing the commencement of this action
yo1 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 and further cause
of action against you the complaint
alleges that dIsregarding your duties
as husband toward the said plant
If. you have been guilty of habitual
intemperanoe for more than one year
last past, to-wlt; That you have used
Intoxicating liquors for more than
one year last past to such an extent
as to disqualify you a greater part of
the time from properly attending to
business.
That there are two children the is
sue of the said marriage, Olaud. boy,
age five; Floy, girl, age six.
The complaint further alsel es that
you are not a proper or ft person to
have the care, custody, or raising Of
children, because of your evil habits.
drunkenness and dissipation.
You are further notified that the
complaint asks and 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 as the plalntig 2nay IN law and
Justice be entisied
All Of W bich facts and prayer will
more fully appear from the verified
complaint SsZ-eh file In said cause
at the Court House at Occur d'Alene.
Idaho, IN the Office of the CLERK OF
the said District Court; said com
plant is hereby referred to and is
Incorporated herein and made a part
hereof ~
You are hereby dir eted to a pear
and answer the said complaint Within
twenty days after service hereof. II
served within the Eighth judicial
District of the State of Idaho. and
within forty days il served elsewhere,
exclusive of the day of service).
Aud you are further notified that
unless you so appear and answer the
complaint. as above directed, the
plaintiff will apply to the court for
the relief demanded In the ooIQplainh
Given under my hand aud ssex
the District Court OF the Eighth
dicial District of the State Of Idsn5,
in and for Kootenai County, this 2sth
day Of July, 1918.
d. r. DANDY,
(SeaD CLERK.
VIM. d. Keetun, attorney for the
plaintiff. Address and residence, st.