Montana labor news., 1937-11-11

ALIAS 6OMMON6
In the District Court of the Second Ju-
dicial District of the State of Montana,
In and for the County of Silver Bow.
JOHN DIXON, Plaintiff.
MILDRED DIXON, Defendant.
The State of Montana Sends Greetings
to the Above Named Defendant:
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
within 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 de-
manded in the complaint a brief state
ment of which is as follows, to-Wit:
That the plaintiff now is and for more
than one year last past and Immediately
preceding the commencement of this ac-
ton has been bona fide resident of the
State of Montana; that the plaintiff and
defendant intermarried at Anaconda, Mon
tana, on or about the End day of Janu-
ary, 1884 that the marriage has never
been annulled nor set aside, and that the
parties ever since have been and now are
husband and wife
That two children, Ronald Dixon, age g.
and Brian Dixon, age 2, have been born
as the issue of said marriage, and are now
under the care, custody, and control OF
tlE llldL lllE u III anu
proper person to have the care, custody, and
control of said minor children, and that the
care, custody, and control of said children
should remain in the plaintiff during the
pendeney of this action; that upon final
decree herein the care, custody, and con-
troll of said minor children of plaintiff and
defendant be awarded to plaintiff.
That the defendant, disregarding the
solemntty of her marriage vows, unjustly
and without provocation or cause, has
been guilty of extreme cruelty of and to-
wards this plaintiff, in this, to-Wit That
the defendant has been guilty of extreme
cruelty of and towards this plaintiff by a
course of conduct towards and treatment
Of plaintiff existing and persisted in for a
period of more than one az year preced-
ing the 2lst day of October, 1887, the date
of the commencement of this action, as
follows. to-wit that the defendant during
said period Of time, has constantly quar-
relied with and found fault with the plain
tiff, and has continually nagged the plain
tiff about small and trivial things; that
during said period of time, the defendant
has treated the plaintiff with Indifference
and contempt that the defendant has
constantly threatened to desert the plain
tiff and their home, during said period
of time, and has since left the plaintiff
and their home without informing the
plaintiff of her whereabouts that said
conduct towards and treatment of the
plaintiff, by said defendant, has inflicted
grleVOus mental suffering upon plaintiff
and is justly and reasonably of such a
nature and character as SO to destroy, and
the same has destroyed the peace of mind
and happiness Of the plaintiff, and entire-
ly to defeat and the same has defeated
the proper and legitimate objects of the
martial relation, and to render, and the
same has rendered the continuance Of
the same perpetually unreasonable and in
tolerable to the plaintiff.
WHEREFORE plaintiff prays judgment
against the defendant:
l. That the bonds of matrimony hereto
fore and now existing between plaintiff
and defendant be dissolved; that the plain
tiff be granted an absolute divorce and
an absolute decree of divorce from de-
fendant and that he be released from all
obligations of said marriage.
q That the plaintiff be awarded the
care, custody, and control of the minor
children of the plaintiff and defendant
during the pendency of this action and
upon final decree herein, and such other
and further relief as to the court shall
seem meet and agreeable to equity in the
premises.
WITNESS my hand and the seal of said
Court this 3rd day of November, 1887.
ELMER SHEA, Clerk.
BY D. F. HOLLAND, Deputy Clerk
COURT SEAL)
w. B. FREEBOURN,
Attorney for Plaintiff,
41-42 Hirbour Building. Butte, Montana.
First publication November 4, l937--4T.