El Paso herald. (El Paso, Tex.) 1901-1931, 1917-08-20
CITATION BY PTRLICATIoN

The state OF Texas
To the sheriff or constable OF FL Paso
You are hereby commanded 20 summon
James w Parr by making publication OF
this citation once in each week Tor -FOUR
successive weeks previous 90 the return
day hereof. ia some newspaper published
iu your county. 90 appear at the next reg
uIar term OF the thlrty-fuur-h district
1rt 81 II Eas1 county. 20 be holden -
The court house thereof i1 the c--y ot ~
fas1. Tex. on the first Monday in Ssur-u-
her. 1917 the same being tla 1rl day %
:. i--i.-l9r- B. ID. 1917. f1eu and mere 10
answer a petition filed DOB said cuu-t on
the etl dag ut January a. j.. 1919. iu
SUR numbered .u the docket q said court
So ltEg-. wherein Della Heulric--slu
Fa-- is plaintiff and James w Parr is
defendant. and said petition alleging that
on or about the 25th day Of December.
A. D., 1892 at Laredo. Texas plaintiff was
legally married % defendant and continued
90 I've with him as his wife until on or
about the fth day Of January. A D.. 1915.
when the defendant abandoned the plain
llf-. leaving her In destitute ClrclulEtauCes
and has not returned 70 her or 20 their
home That az the Jime Of said marriage
plaintiff and defendant were Inhabitants q
the state Of Teas That plaintiff during
the time she lived and cohabited with
the defendant there was born 10 plaintiff
and defendant by said marriage. SIX chill
dren. five bows ranging from Is 90 u
years OF age, and one girl that is dead
That during all OF said time o. said
marriage she conducted herself with pro-
nrlery and managed the household affairs
uf her said husband with prudence and
economy and 90 all times treated her said
nus oall with kindness and l1rlear4DCe-
Plaintiff further alleges that AZ the
time Of her said marriage TO the defendant
she was a mere child. only about thirteen
years OF age and that the defendant was
man about twenty-four years Of age,
and that defendant dlsregardinE the sol
emlity Of his marriage vows and the ten
der years Of the plaintiff az the tiue Of
e h.H pa #HH. g p d HsHH d
treat the plaintiff with kindness and at
teuti0n. within few months after their
said marriage the defendant commenced
course Of uuklud. harsh and tyrl luicll
slight intermisslon until the defendant
finally abandoned her on or about the
4tl day q January. A D.. 1915
Plaintiff further alleges that on divers
and sundry occasions while plaintiff lived
with defendant as aforesaid. the defend
ant was guilty OF excuses. cruel trea -n-e1-
and outrages toward her OF such nature
as Co render their Irving together iusup- .
portable and that within a few months /
after the plaintiff and defendant were ]
married, the defendant would lose his
temper and would curse the plaintiff. I
applying 10 her vile and vulgar gp--h-t- .
and that ou frequent occasions the de- ]
PENDANT would become angry without cause R
on the part OF the plaintiff and work him /
SELF into a ryrannlcal rage and would slap /
and strike the plaintiff in the face and /
on one occasion the defendant struck the I
plaintiff with bride, lnfictinE upon he- I
bruises and causing her great pain. and ON !
another occasion the defendant whipped I
the plaintiff with a razor strap infict.ng I
upon her bad bruises and causing her great D
physical pain That on or about the End /
Gay OF January. A. ID. 1915. az their hl-la }
iu Fl Fsso. Texas, defendant cursed and D
abused plaintiff and among other things I
struck her five times ia the face with his I
list. under circumstance which showed /
utter disregard OF plaintiffs health. and ]
while he was in the tyraunical rage Of /
anger and while he was striking her the ]
defendant threatened her life and told i
her that he would XIII her. and there I
after the defendant remained sulleu toward I
the plaintiff until on the 9Th day Of ]
! truary, A D.. 1915. early in The morn I
Ing and Immediately after breakfast. the +.
defendant packed his grip and abandoned /
the plaintiff and she has not seen him Z
since and she does not know his where ]
abouts. save from rumor-
Plaintiff further alleges that defendant /
Is a man OF violent passion and UNCOVER
able temper and on many occasions during |
The time plaintiff lived with him. defend ]
ant addressed 90 her the most opprobl0us I
ithets AMI threats o. personal violence
and repeatedly threatened TO take her life .
and charged her with iufidel--s and used t
every means 90 humiiiste her and Co pun
.sh her and 10 make her life one contIuu-
Gus burden That IN consequence Of the i
cruel aud inhuman treatment above mem
toned together with the threats afore-
said. and such brutal conduct toward her +
him or 10 remain within the reach % his
violence
Plaintiff further alleges that she has
nor sought the defendant 90 return. bus f.
has through the efforts OF her children /
managed TO- provide means OF susteuauce
and she has continued 90 live ln FL Paso
the best she could. depending upon her
SAID children Tor support and that since
the defendant has Ieft her house he has
refused and failed To- provide Tor hcr
support and maintenance or 90 support and
maintain any Of their said children
Wherefore pIaiu-iG prays the court that
defendant he cited to appear and answer
This petition and that she have judgment
iissolying said marriage relations. Tor cost
lf suit and Tor such other and further
relief special and general. in law and in
guilty that she may be justly entitled 10
Herein fan not. but have you before sale
court. &c IFS aforesaid next regular term.
his writ. with your return thereon show
ug how You have executed the same
Given under my hand and seal ~ said
COURT an office in the city Of I'd Paso,
Texas. this the 9Th day OF August. 1917.
fSeall c. ~ MCKINNEY.
JERK, district court. TT paso county. Tex.
By ~ T. Haynes. deputy