Montana labor news., 1939-08-17
No. 38042
ALIAS SITMMnNS

l. ALIAS SUMMONS
In the. District Court of the Second Ju-
dicial District of the State of Montana,
In and for the County of Silver Bow.
KATHLEEN WOODS. Plaintiff,
JUDsoN WOODS. 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 (20) days after the service
of this Alias Summons, exclusive of the
DAY OF service; and In case of your failure
20 appear or answer, judgment will be
taken against you by default for the relief
plant alleges that Plaintiff has been a
bonafide resident of the State of Montana
for one year Immediately preceding the
commencement of her action; that Plain
tiff and Defendant intermarried at Salt
Lake City, Utah, on or about the 5th day
OF June, 1929, and ever since have been
and now are husband and wife; that there
has been one child born as issue of said
marriage. to-wit, Thomas Woods, a son
age eight years, which said child is in the
care. custody. and control of Plaintiff.
VINO Is a fit and proper person to have
child; that Defendant. by reason of his
indolent and neglectful habits of dissipa-
ton Is not a fit and proper person to
nave the care. custody and control of said
child; that Defendant has been guilty of
extreme cruelty toward Plaintiff by in
fllcting. g%rievous mental suffering upon
Plaintlff by a course of conduct existing
ana being persisted in by said Defendant
for one year before the commencement
Of this action which is of such a nature
ana character as to destroy the peace of
mind and happiness of Plaintiff and de-
feat the legitimate objects of marriage
and render the continuance of the mar
ried relation perpetually unreasonable and
intolerable to Plaintiff, in that commencing
a few months after the marriage of the
PARTIES, and continuing intermittently I'M
I'll on or about the 10th day of June, 1889.
Defendant repeatedly inflicted personal
violence and bodily injury to Plaintiff by
striking and beating Plaintiff on many,
divers, and numerous occasions and times:
that on the 10th day of June, 1899, De-
PENDANT deserted and abandoned Plaintiff
and their child and left Plaintiff and their
child destitute N without the necessaries
OF life, and that said Plaintiff has been
forced to have recourse to friends and to
the Relief Administration in order to
supply herself and the child of the
Parties with the necessaries of life. that
during the period of time when Plaintiff
and Defendant were residing together.
Defendant remained way from home at
nights gambling aWay what money had
been earned and which was needed for
the support and care Of Plaintiff and the
child OF the Parties; that likewise and on
divers and numerous occasions and times
me Defendant has deserted md abandoned
Plaintiff and the minor child of the Parties
and has left them destitute and uncared
for; that on said occasions Defendant has
remained away and neglected Plaintiff
and the minor child of the Parties for
period exceeding six months; that De-
PENDANT has continuously since a few
months after the marriage of the Parties
quarreled with Plaintiff and used vile
and obscene and abusive language toward
Plaintiff without just cause or provoca-
ton; that the last known place of address
OF Defendant was 729 South Dakota
Street, Butte, Montana, and that the
present whereabouts of said Defendant
are to Plaintiff unknown.
Plaintiff seeks an absolute divorce and
the exclusive care, custody, and control
Of Thomas Woods, the minor son of the
Parties, and such other and further relief
as to the Court may seem meet and just
in the premises.
WITNESS my hand and the Seal Of said
Court this 22nd day of July, 1899.
ELMER SHEA, Clerk.
EMIGH AND MURRAY,
Butte, Montana,
Attorneys for Plaintiff.
First publication July 81. 1887.