Divorce Complaint

N E Wilmoth

Vs.

Ruffin Wilmoth

State of North Carolina

Surry County in the

Court, Spring Term 1895

 

 

This plaintiff complains and alleges

That on the 25 day of Dec 1884 plaintiff and defendant were lawfully married in Surry County, North Carolina.

That about the last of June 1891 defendant abandoned above named plaintiff and lived in fornication and adultery with one Mildred White with total circulation of his wedding vows.

 

That plaintiff has lived in North Carolina, Surry County all her life for more than two years.

 

 

Relief

Wherefore plaintiff desires as (unreadable) that she be divorced from the bands of matrimony and for such other and further relief as she may be entitled to.

 

T W Folger Atty

For Plaintiff

 

 

 

N. E. Alberty being on sworn deposes and says that facts set for this the foregoing Complaint are true to the best of her knowledge and belief and that said Complaint is not made out of levity or by collusion between husband and wife and not for the men purpose of being free from each other but in Cincerety and truth for the causes therein set forth in this complaint as grounds for Divorce have existed to his knowledge for more that six months before the filing of this Complaint and that plaintiff has been a resident of the State of North Carolina for more than two years prior to the Commencement of this action.

 

Sworn to and subscribed before me this March 26th 1895               N. E. Wilmoth

A H Freeman, JP

 

 

                                                                                                                                               

 

 

 

 

 

 

N. E. Alberty being on sworn deposes and says that facts set for this the foregoing Complaint are true to the best of her knowledge and belief and that said Complaint is not made out of levity or by collusion between husband and wife and not for the men purpose of being free from each other but in Cincerety and truth for the causes therein set forth in this complaint as grounds for Divorce have existed to his knowledge for more that six months before the filing of this Complaint and that plaintiff has been a resident of the State of North Carolina for more than two years prior to the Commencement of this action.

 

Sworn to and subscribed before me this March 26th 1895                       N. E. Wilmoth

A H Freeman, JP