Source: TSL&A Microfilm # A-5062
Sumner County Probate Records (County or Chancery)
Loose Records 3444- 3513
Transcribed by Jan J.
Barnes
© 2003
Loose Record # 3447
1889
To the Hon. A. H. Mumford Judge of the 10th Judicial Circuit residing at Gallatin, Tenn.
The Bill of Complaint - or petition of Sarah Bridgewater a citizen of Davidson County Tennessee filed in this Hon'l Court against Tom Bridgewater a citizen and resident of Sumner County.
Petitioner would respectfully represent and show your Honor that she and
the defendant were married in Sumner County on the 26th June 1882 and lived
together for seven years as man & wife and by said marriage there was
born two children both of whom are dead. Petitioner would also show
your Honor that since her marriage with the defendant she has worked all
the time and at all times endeavored to do her duty as a wife should do.
And that most of the time since said marriage the defendant has been
addicted to the habit of drinking and a great part of the time to excess
but he not only drank whiskey to excess but he failed to support & provide
for her and on several occasions has given her a serious whipping or beating,
once or twice in the year 1887 & also in 1888 and when in 1888 he beat
and abused her to such an extent that it became unsafe for her to longer
live with him and that she was forced on several occassions to go to her
Mothers for protection and shelter and that his conduct for the past two
or three years towards her has been cruel and inhuman and such that it was
unsafe for her to longer live and cohabit with him and that he has for the
past two or three years utterly failed to provide for and support her.
And that when drunk he is very obusive to her cursing & abusing her in
in every way.
And to such an extent did he ____ his bad treatment of her that a year ago
she left him entirely & went to the city of Nashville in order to get
work & get out of his reach.
And she is now living in Nashville cooking and supporting herself. The
previous considered, she asks him to file this Bill that the defendant mentioned
in the caption be made such to this Bill, that process issue for him to answer
the same. And that upon the first hearing of the cause, she be granted
a divorce and restored to all the rights of a single person and that she
be restored to her maiden name to wit Sarah Guild.
W. C. Dismukes
Atty for plff.
State of Tennessee
Sumner County
Personally appeared before me Sarah Bridgewater the petitioner who made oath
in due form of law that the matters and facts stated in the foregoing
bill are true and that said complaint is not made out of levity or collusion
with the deft. but in sincerity and truth for the causes herein mentioned
and that she is justly entitled to the redress sought. Petitioner further
makes oath that owing to her poverty she is not able to burden expense of
this suit which she is about to commence, and that she is justly entitled
to the relief asked.
Sarah Bridgewater
Sworn and subscribed to
before me June 14th 1889.
Wm Hall, Clerk
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