Atlanta tri-weekly journal. [volume] (Atlanta, Ga.) 1920-19??, 1923-02-20

inexpressible chagrin Of plaintiff,
her request was refused by defend
ant.
so. Defendant refused to furnish
plaintiff with either the names or adj
dresses of either of the alleged au-
thors of said statements.
81. Defendant still refuses to iden-
tify said alleged authors of said al.
legged statements, or to give plaintiff
any information which will enable
plaintiff to uncover the masked iden-
tity of said alleged authors, if such
authors exist except in Imagination
80. Your petitioner was, therefore,
left to suffer the stigma of these
shameful ISLANDERS, and to suffer the
humiliation naturally resulting from
the conduct of the defendant who
had abandoned her under the cloak
of charges that were false and with
out foundation, and who deliberately
withheld from her the only simple
means of promptly exposing the
enornlity Of the outrage to which she
has been subjected.
Acted without Probe
SO. Your petitioner says that no
men or man of sufficient character
and integrity to be entitled to belief
by defendant or by any court or
jury ever said to defendant that
plaintiff has been guilty of the con.
duct which was alleged by defend
ant as the reason for this breach OF
his engagement to your petitioler.
"a. Plaintiff charges that no man
or men have ever stated to defend
ant that your petitioner invited him
or them to visit her for improper
purposes.
IS. Plaintiff says that if any in
formation whatsoever was communl-
Gated to defendant, concerning your
petitioner, defendant : acted upon
said alleged rumors, reports or
charges without making any sut'
ficient investigation to enable him.
as an intelligent man deeply inter-
ested in the outcome of the inyestl.
cation, to determine whether said
rumors, charges or reports were true
or false.
Sc. Your petitioner says that she
was the affianced wife of the de
PENDANT and that he was bound by
every moral obligation to her and to
himself to disregard said charges as
part Of deliberate plot to destroy
| her happiness and his, for defendant
well knows that said charges, II
| made, were false and could have
been shown to- be false upon lnves-
| cation.
ST. Plaintiff charges that unless
defendant, from his intimate knoWl-
edge of the plaintiff, was willing TO
| resent and refute said SANDERS
against the good name and character
of his affianced wife when they
were made, it was his solemn opl-
cation, in 1ecency and honor, to
promptly acquaint her with the
names and addresses OF the men
! alleged to have been the authors
of the reports conveyed to him, ana
| to have frankly and promptly &c.
| quainted her with every detall OF
! the incident necessary to enable her
| to expose the falsehood as well as
the cowardly cunning OF It's prepe-
| traitors.
SO. Defendant made no sufficient
| Investigation tofenable him to CON
| clusively ascertain and determine
| that said charges were false am
| vile.
| so. Such investigation would have
| disclosed the fact that said charges
were absolutely false, and IL any
| charges were, indeed, MADE tnae
| they were the cruel fabrications OF
malicious slanderers, actuated by
mercenary motives, so utterly with
on. foundation that the purported
| authors of the calumnies exacted
| the shelter of secrecy as part OF the
| price Of their perfidy.
90. Defendant has persisted IN ms
refusal to even divulge to plalntift
| in response to her urgent requests
and demands, the names of the au-
tbors of said charges, or of those
| by whom said charges We're convey
| ed to him.,
81. Your petitioner, therefore,
brings this action against defendant,
! for damages, in order that the mat
tiers herein set out may be freely
inquired into and determined by
| Jury of said district.
50. Plaintiff alleges that the dam.
ages she has suffered resulting from
defendants breach of promise, which
| damages generally consist of the ex-
pense which plaintiff has incurred
as an incident to said promise, the
humiliation, pain and suffering to
which plaintiff has been subjected
as an incident to its breach, and her
financial loss in the premises, have
been grossly aggravated and increas
ed by the inexcusable conduct of de-
| fendant in ruthlessly, recklessly and
wantonly, without any regard what
soover to plaintiffs feelings, peace
Of mind, and future prospects,
preaching said promise upon the
false charge that she is not a pure,
chaste and virtuous woman, and that
her conduct, as set out in said let
ter breaking said engagement, is
such as to unfit her to be his wife.
Your petitioner prays Judgment
against defendant in the sum of five
hundred thousand (S500, 000) dollars,
as damages, for the breach of prom
Use above set out, and as aggravated
damages in the premises
Wherefore, your petitioner prays.
that process may issue, requiring
the defendant to be and appear at
the next term of said court to an
swer your petitioners complaint.
HARRY GAMBLE,
NOISE, HAMMOND & HOWELL,
DORSEY, BREWSTER, HOWELL
& HEYMAN.
Attorneys for Petitioner.