TRANSCRIPT OF ABOVE DIVORCE
State of Missouri } In The Howell
County of Howell} Circuit Court April Term 1876
Elizabeth McCammon }
VS } Petition for Divorce
Mathew McCammon }
Plaintiff states that on the 22nd Day of October A.D. 1875 (SIC ACTUAL DATE 1871), in the County Of Phelps and State of Missouri she was lawfully married to defendant, that plaintiff continued to live with de- fendant as his wife, from and after the day and year aforesaid, until the 25th day of February, 1875. that during
all that time plaintiff faithfully de-meaned herself and discharged all her duties as the wife of defendant and at all times treated him with kind ness and affection; but the said defend ant wholly disregarding all the duties of a husband to plaintiff, has treated plain tiff in such a cruel and barbarous manner as to endanger her life, in this, that at diverse times defendant has, while in a fit of rage and passion struck plain tiff on the head with his fist and at one time he struck plaintiff on
the head violently with a quart cup
Plaintiff further states that de fendant has offered her such indigni ties as to render her condition in life in tolerable, in that, defendant has failed to provide plaintiff with sufficient xxxxxx clothing to protect her from the advirsities
of the weather, defendant has repeatedly gone off and left plaintiff for days and weeks at a time and xxxxxxxxxxxxxxxx while she was almost blind with the sore eyes, without sufficient food to keep herself and children from starvation, no
wood to keep her warm.
Plaintiff further states that there was from said marriage two children, both of tender years, one a female now aged three years and the other a female, now aged 7 months. Plaintiff states that she has resided within this State one whole year next before the filing of this petition. Plain- tiff further states that the said defendant is seized and possessed of personal estate and money to the value of ($200)
two hundred dollars, and that she is wholly without the means to prosecute this suit and to support herself during the proceeding. The plaintiff
Therefore, prays to be divorced from the bonds of matrimony contracted as afore- said with defendant, that she may have the care and custody of her said infant children and that the court will afford to her such support and maintenance
out of the property of said defendant and for such time as the nature of the case and the circumstances of the parties may require, and if necessary, compell the defendant to give security for such maintenance, and to make such further
orders, from time to time, touching the same, as may be just, and such other orders & judgments touching this presumed
as may be proper.
Elizabeth McCammon Plaintiff
This affiant, the plaintiff, makes oath & says that the facts stated in the above pe- tition are true according to the best knowledge and belief of plaintiff, and that The complaint is not made out of levity or by collusion, fear or restraint, between the plaintiff and the defendant, for the mere purpose of being separated from each other, but the sincerity & truth for the causes mentioned in the petition.
Elizabeth McCammon Plaintiff
Mathew McCammon Defendant
In the Circuit Court
of Howell County, Missouri
April Term AD 1875
Defendant for answer to the petition of plaintiff, admits that he was married to the plaintiff and lived with her as her husband during the time, and as, stated in the Plaintiffs petition. Denies that during the time plaintiff lived with defendant as his wife she faithfully demeaned herself and discharged all her duties as the wife of defendant and at all times treated defendant with kindness and affection. Denies that defendant disregarded his duties as the husband of plaintiff. Denies that he treated plaintiff in such a cruel and barbarous manner as to endanger her life, or that defendant whilst in a fit of rage and passion struck plaintiff on the head with his fist or at any time
or place he ever struck plaintiff with a quart cup or any thing whatever.
Denies that he offered any in dignities to plaintiff such as to render her condition in life intolerable or that defendant failed to provide for plaintiff the necessaries of life or that he left plaintiff for days and weeks at a time and whilst she almost blind with the sore eyes, without sufficient food to keep plaintiff and chil dren from starvation or failed to keep wood to keep plaintiff and children warm. Denies that defendant is seized and possessed of personal property to the amount of $200. Denies that plaintiff is entitled to alimony out of any estate of defendant or that she is entitled to support and maintenance during the pendency of this action. Denies that on account of the matters stated in the petition plaintiff ought to be divorced from the bond of matrimony entered Into between plaintiff and
Defendant or that plaintiff is entitled to any judgment or decree whatever against defendant.
And further answering states that during all the time defendant lived with plaintiff as her husband he treated her with kindness and affection and provided for her and defend ants children all suitable and necessary food and clothing
in proportion to the station of defen dant in life. That plaintiff wholly disregarded her duties as a
kind and affectionate wife, was possessed of violent and Unfavorable temper and con stantly quarreled at defendant.
That plaintiff was slovenly about her household affairs and would not keep her children clean or decent although often importuned to do so by defendant. That plaintiff was possessed of a violently jealous disposition and was constantly throwing up to defen dant that he had sexual intercourse with other women and was always falsely accusing defendant
of criminal connection with other women so that defendant had no peace of mind. That plaintiff never had a kind word for defendant when he would come home worn out with fatigue and labor but always treated him unkindly and had harsh words for him and offered many other and further disparities to defendant such as to render his condition in life intolerable and wholly unbearable.
Defendant admits that the children were born of the marriage as stated but he avers and states that she is totally unqualified to have the care and custody of said infant children.
Therefore defendant prays to be divorced from the bonds of matrimony contracted as aforesaid between plaintiff and defendant and that he may have the care and custody of his said infant children and for such other and further relief as the court shall deem proper in the process?.
McCown for Defendant
This affiant , the defendant, being duly sworn says that the facts stated in the above petition are true according to the best knowledge and belief of defendant and that the complaint is not made out of levity or by collusion, fear or restraint between plaintiff and defendant for the mere purpose of being separated from each other but in sincerity and truth for the causes mentioned in his answer and that defendant has resided one whole year in this state next before filing his answer and cross bill.
Mathew McCammon defendant,
Subscribed & sworn to before
me this 8th of March 1875.
Wm. H. McCown
Notary Public, Howell Co M
DO NOT HAVE IF THE DIVORCE WAS FINALIZED BUT PRESUMABLY IT WAS IF THE MATHEW LIVING IN JACKSON CO., AR IN 1880 IS MATHEW ALEXANDER