Montana labor news., 1934-08-09
E. D. Elderkin, Atty.
ALIAS SUMMONS

E. D. Elderkin, Atty. No. 35oss
ALIAS SUMMONS
In the District Court Of the Second Judi
cial District Of the State of Montana, in
and for the County of Silver Bow.
Nerneta CASTLE, Plaintiff,
VS..
Buel M. CASTLE, Defendant.
The State of Montana Sends Greetings to
the Above Named DEPENDENT:
You are hereby summoned to answer the
complaint in this action, which is filed in
the office of the Clerk of this Court a
copy of which is herewith served upon you,
and to file your answer and serve a copy
thereof upon the plaintiffs attorney with
in twenty days after the service of this
summons, exclusive Of the day of service;
and in case of your failure to appear or
answer, judgment will be taken against you
by default for the relief demanded in the
complaint; which is as follows, to-wit: The
plaintiff complains and alleges;
That plaintiff and defendant intermarried
at Butte, Montana, on the 18th day of De-
1929, and ever since said date. have
been and now are husband and wife.
That the plaintiff is now and has been
for more than one year Immediately pre-
ceeding the commencement of this action,
to-wit; the End of August, 1884, an actual
bona fide resident Of the State of Mon
tana.
That as issue OF said marriage, one child
has been born, to-wit; Donald Lloyd Cast
lie, now Of the age Of eleven months; that
said minor child is in the care, custody
and control of plaintiff. at Butte, in the
County of Silver Bow, State of Montana.
That the defendant, disregarding the
solemnity of his marriage VOW, has been
guilty of extreme cruelty of and toward
this plaintiff, by the infliction of grievous
mental suffering uPon the plaintiff by the
defendant, by a course of conduct towards
and treatment of this plaintiff by defen-
dant, which has been existing and persist
ed in by said defendant continuously for
a period of more than one full year inn
mediately proceeding the commencement OF
plaintiffs action, to-wit; the End day OF
August, 1884, which conduct was justly
and reasonably of such a nature and char
acter as to destroy the peace OF mind and
happiness Of the plaintiff and to entirely
defeat the proper and legitimate objects
of marriage and to render the continuance
of the marriage relation between plaintiff
and defendant perpetually unreasonable and
intolerable to the plaintiff. That said acts
and conduct of the defendant which has
caused grievous mental suffering to this
plaintiff are as follows; That defendant
has upon divers and numerous occasions
1udiIeilSus upDidAQcdf sWOic at nv THREAT
en- to strike plaintiff, and on or about the
18th day of March, 1880, at their home
$40 Sheridan Avenue, Butte, Montana, the
said defendant in an angry manner struck
and threw plaintiff against the range in
their home and seriously injured her side
from which said injury, and by reason
thereof she was confined to her bed for a
period of two days; that during the period
Of CESSATION of their baby the defendant
was abusive, inatentive and actually left
plaintiff alone for a period of three months
during her delicate condition. That all oil
the aforesaid conduct upon the part oil
the defendant has occurred without caus,
or provocation upon the part of the plain
tiff who has at all times remained and
been a faithful and dutiful wife of, and to-
ward the defendant.
5.
That plaintiff is a fit and proper person
to have the care. custody and control oil
said minor child; that defendant is not a
fit and proper person to have the care
custody and control of said minor child.
That the sum Of one hundred cl0C.0 0l
dollars is a reasonable amount to be al