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Lucy M. Walker
vs.
Henry Walker
Comes now above named plaintiff and for cause of action against the defendant alleges that she and said defendant have been residents of Custer County Nebraska for upwards of ten years last part and that said plaintiff and defendant are now residents of said county and residing therein
That on or about the 26th day of October 1884 she was married to the defendant
That on or about the 26th day of October 1884 she was married to the defendant
That there are three children now minors resulting from said marriage to wit;
Lynn C. Walker aged 9 years
Norman A. Walker aged 7 years
Keith G. Walker aged 2 years
That during all of this time since said marriage that this plaintiff conducted herself toward said defendant as a kind and indifferent wife.
That said defendant not keeping his marital duties and vows at various times and repeatedly was guilty of repeated and extreme acts of cruelty by the use of acts of personal violence and other means against this plaintiff
That defendant is a person of loose and dissolute habits and that it is dangerous to the lives of the children herein named and of plaintiff to live with defendant or to continue further in the marriage relation with said defendant
That said defendant is not a proper person to have the care and custody of said children by reason of his vicious and immoral habits
That plaintiff is a person fitted and able to take charge of said children and their care custody education and control
That the defendant has been convicted of a felony in the District Court of Custer County Nebraska and has been sentenced to imprisonment in the penitentiary of this state for the term of three years and over by said court and no error has been persecuted therein
Wherefore plaintiff prays for an absolute decree of divorce from said defendant and for the court to award to her the care custody and control of said children absolutely and without any interference on the part of said defendant and for such other further and different reliefs as to the court may be just and understandable.
Lucy M. Walker
By J. R. Bean, Atty.
________________
The State of Nebraska
Custer County
Lucy M. Walker brings forth duly sworn deposes and says that she is plaintiff herein that she has read and swears the contents of said petition; that the facts stated herein are true as she verily believes
Lucy M. Walker (signed)
Inscribed in my presence and sworn to before me this 11th Day of December 1896.
J.R. Rhoades
County Judge
_________________
_________________
In the District Court of Custer County Nebraska
Lucy Walker
vs. ANSWER
Henry Walker
Comes now the defendant Henry Walker and for answer to the petition of the plaintiff filed herein -- admits the marriage of the plaintiff and defendant as alleged in the plaintiff's petition -- But denies each and all of the other allegations therein contained.
Henry Walker
By Cameron & Reece
His Attorneys
Verification waived
J.R. Bean (signed)
Atty for Plaintiff
Copyright © 2021 by Kevin W. Walker
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