STATE of Illinois}
Kane county.}SS. To the December Term, A.D., 1898
City of Aurora}
In the City Court of Aurora County
Olive Leonard}
VS. Bill for Divorce.
George F Leonard}
To the Honorable Russell P Goodwin, Judge of said Court:
In Chancery Sitting.
HUMBLY COMPAINING Unto Your Honor, your oratrix Olive Leonard of Aurora, in the County of Kane, and State of Illinois respectfully shows that she is, and for more than a year last past, continuously, immediately preceding the filing of this bill of complaint, has been an actual resident of the State of Illinois also in a resident of the City of Aurora.
YOUR ORATRIX Further shows unto Your Honor, that on or about the 3rd day of November A.D. 1872, at Sandwich in the State of Illinois she was lawfully joined in marriage with George F Leonard , of Sandwich in the State of Illinois, whom your oratrix prays may be made a party defendant hereto, and from thence hitherto, until on or about the 15th day of June A.D. 1896, your oratrix and the said defendant lived and cohabited together as husband and wife.
YOUR ORATRIX Further shows unto Your Honor, that, as the fruits of said marriage, the partis hereto have had born unto them Seven children of whom are now living, whose names and ages are as follows, to wit: and such as are noted minors: viz. Jennie Leonard age 12, years, and Blanche Leonard aged seven years
YOUR ORATRIX Further shows unto Your Honor, that since said marriage, and during all the times he lived and cohabitated with the said defendant, she has treated him kindly and affectionately, and in all things, at all times, conducted herself toward the said defendant in a manner well becoming a good, true and virtuous wife.
YOUR ORATRIX Further shows unto your Honor, that the said defendant is the owner, in his own right, in fee simple of the following described real estate, situate in the County of - State of - to wit.......
of about the value of dollars' and the said defendant is also the owner of personal property, consisting of
said your oratrix shows that she is possessed of no property, either real or personal, and has no means wherewith to support herself or child, or to defray the costs and expenses of this proceeding; and that the defendant is abundantly able to supply all the necessities of herself and child, but wholly refuses so to do; and your oratrix charges that he, the said defendant, now threatens to, and dis about to sell and dispose of, or encumber all his estate, real and personal property, for the purpose of defeating your oratrix' rights in the premises, and to prevent her from
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obtaining alimony for the support of herself and child, and for the payment of the costs and expenses of this proceeding, and your oratrix fears that he will do so, unless restrained by the injunction of this Honorable Court.
YOUR ORATRIX Further shows unto Your Honor, and charges that the said defendant, on or about the 15th day of June, A.D. 1896, wilfully, and without any reasonable or just cause therefor, deserted and abandoned your oratrix and wholly refused to live and cohabit with her any longer as husband and wife, and from thence hitherto, up to the time of filing this Bill of Complaint, has continuously absented himself from her and refused to return and live with her as husband and wife, and still does, without any fault on the par of your oratrix.
YOUR ORAT.... Further shows unto Your Honor, and charges that said defendant, has been guilty of extreme and repeated cruelty to your orat; that the said defendant, on [divers] days and times since their said marriage, has beaten, struck, pinched, choked, kicked, and otherwise cruelly abuse and ill treated the life of your orat...., so that life has been rendered miserable; and your orat.... shows and charges, that on or about the...day of. A,D, 18..., the said defendant.
YOUR ORAT ... Further shows unto Your Honor and charges that for the space of two years last past, prior to the filing of the Bill of Complaint, the said defendant has be guilty of habitual drunkenness...
YOUR ORATRIX Further shows unto Your Honor, and charges that ever since the said marriage she has conducted and demeaned herself toward the said defendant as a true, faithful, chaste and affectionate wife but the said defendant, wholly regardless of h is marriage vows, has, for a considerable time past, given himself over to adulterous practices; that on or about the 1st day of July, A.D. 1895, at Sandwich, in the State of Illinois, the said defendant committed adultery with out Mrs. C. Gardner at her house. and at divers other times and places since said marriage the said defendant committed adultery with out, and with divers other lewd women, whose names are to your oratrix unknown.
YOUR ORATRIX Further shows unto Your Honor, and charges that the said defendant, at a term of the.....Court of.....County, begun and holden within and for said County, on the.... day of...., A.D. 18...., was, on the....day of ...., A.D. 18...., the said defendant was, by the Judge of said Court, duly sentenced to confinement in the State Penitentiary, at....for the term of....years, which said judgment and sentence still remains in full force and effect.
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and not in anywise reversed, vacated or not aside, as by a certified copy of the record of said judgment and sentence, ready to be produced in Court, will more fully appear.
IN TENDER CONSIDERATION WHEREOF, And forasmuch as your oratrix can not have adequate relief in the premises, except in a court of equity, where matters of this nature are properly cognizable and relievable.
TO THE END, THEREFORE, That the said George F Leonard may, if he can, show why your oratrix should not have the relief herein prayed, and.... he may full, true, direct and perfect answer make (but not under oath, answer under oath being hereby expressly waived) to all and singular the matters and things herein stated and charged;
AND That the said...., defendant, his servants, agents, attorneys, and solicitors, may each and all of them be enjoined and restrained from encumbering, charging, selling or otherwise disposing of, or from attempting to encumber, charge, sell, or otherwise dispose of any of the real or personal estate of the said....until the further order of this Court;
AND That the said George F Leonard may be ordered to pay such sum as this Court shall deem reasonable and just for the support of your oratrix and her children during the pendency of this proceeding; and a further sum for her costs and solicitor's fees in prosecution of this case;
AND That upon a final hearing of this cause, the Said George F Leonard may be ordered, directed, and decreed to pay to your oratrix such further sum, in the nature of alimony, for the support and maintenance of herself and children as to this Court shall seem reasonable and just;
AND That the bonds of matrimony existing between your oratrix and the said George F Leonard, defendant, may be thenceforth and forever dissolved and annulled; and that all duties, rights, claims and obligations accruing to either of the said parties by reason of said marriage, shall thenceforth and forever cease and be determined; and that the said parties by severally at liberty to marry again in like manner, as if they had never been married;
AND That your oratrix may have the sole care, custody, and education of the said children
AND that your [?] may resume her maiden name.
AND That your oratrix may have such further or other relief in the premises as to Your Honor shall seem meet, according to equity and good conscience;
MAY IT PLEASE YOUR HONOR To grant unto your oratrix the people's writ of injunction issuing out of and under the seal of this Honorable Court, to be directed to the said defendant,..., and to his servants, agents, attorneys, and solicitors, therein and thereby commanding and strictly enjoining them, and each of them, from encumbering, charging, selling, or otherwise disposing of, or grom attempting to encumber, charge, sell, or otherwise dispose of any of the real or personal estate of the said defendant, ...., until the further order of the Court;
AND MAY IT PLEASE YOUR HONOR To grant unto your oratrix the writ of summons in chancery issuing out of and under the seal of this Honorable Court, to be directed to the said defendant, George F Leonard...., therein commanding him by a certain day, and under a certain penalty, to be therein incerted, that.... he personally be and appear before this Honorable Court, then and there to stand to, abide and perform such order, direction and decree therein as to Your Honor shall seem meet, according to equity and good conscience.
AND YOUR ORATRIX, As in duty bound, will ever pray, etc.
Olive Leonard
Frederick Brown
Solicitor for Complainant,
State of...........................}SS.
...........................County.}
....................................... being duly sworn, says that....he is Complainant whose name is subscribed to the foregoing Bill of Complaint; that....he has heard the above Bill of Complaint
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read, and knows the contents thereof; that the said Bill of Complaint is true of h......own knowledge, except as to the matters and things therein stated to be upon information and belief, and as to those matters and thins....he believes it to be true.
Subscribed and sworn to by the said}
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before me, this......................................................day of}
...................................................................................A.D., 189....}
....................................................................................................................}
State of ......................................................................................}
...................................................................................County.}SS.
................., being duly sworn, says that said defendant is a non-resident of the State of.................., and that h....... last known or present place of residence................, and that upon diligent inquiry said defendant's place of residence can not be ascertained......
Subscribed and sworn to by the said}
..............................................................................................................................
before me this....................................................day of}
.............................................................................A.D., 189....}
..............................................................................................................}
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