Transcribed by David L. Price
Source: Jackson County Chancery/Circuit Loose Records
Available: Tennessee State Library & Archives and Tennessee Technological University Library
State of Tennessee
To the chancellor assigned by law to hold the chancery court of Jackson County at Gainesboro in said State.
The Bill of Complaint of Polly Ann Gipson a citizen of Jackson County Tennessee against Levi Gipson who resides in parts unknown to your oratrix and who is not a resident of the State of Tennessee.
Complaining your oratrix would respectfully state to your honor that she and defendant were married in Jackson County in March 1867. Your oratrix did all she could while she and defendant lived together as husband and wife to render him happy in the marriage relations but she states that defendant did not reciprocate her treatment to him. She states that defendant abandoned her about two weeks ago and left the state as she is informed and believes with one Eliza Schimerhorn. Your oratrix states that prior to his leaving defendant had been guilty of adultery with Eliza Schimerhorn and had been carrying on with her an adulterous intercourse for some considerable time before they left. Your oratrix states that she has been true to defendant and since their marriage has never violated her marital vows. She states that defendant and her had a bed stand and had clothing, some little cups, and ware and some cooking vessels, two sows, some corn and bacon and defendant has a growing crop of wheat of about three or four acres on the land of one Tobias Gipson.
The premises conseived your matrix prays that Levi Gipson be made defendant to this Bill that copy and process upon or publication be made if necessary - that all of said property be attached, the wheat in the field as well as the balance of the property- that a writ of tellal chiment isue ?- That she be divorced from defendant by decree of your honor and restored all rights of a single woman- that she have all of said property and for all the relief to her care may entitle her - this is the first application for attachment writ in this cause.
Denton Washburn Sols.
State of Tennessee Jackson County }
Came before me Polly Ann Gipson who made oath in due form of law that the facts stated in this bill are true to the best of her knowledge information and belief and that this application for briner? is not made through levity fraud or collusioin with defendant but in truth and surity for the purposes stated and that owing to her poverty she is not able to bear the expence of this suit and that she just entitled to the relief herein sought to the best of her knowledge and subscribed this affidavit before me this 6th Day of March 1871. Polly Ann Gipson
Subscribed and sworn to before me the date above R. A. Cox
In the name of the state of Tennessee To the sheriff of Jackson County Greeting
Whereas Polly Ann Gipson has filed in our honorable court of Chancery at Gainesboro her bill of complaint against Levi Gipson praying for relief in the premises & c and for writs of attachment to issue which is granted she having enaild? her selfe of the Benefit of the Law made for the benefit of poor persons.
Now therfore you are hereby commanded forthwith to attach the following property to wit one bead sted & bed clothing two sows and all the corn and tobacco belonging to Levi Gipson all the cupboard & tableware all the household and kitchen furniture all the farming belonging to Levi Gipson also the growing crop of wheat same? 3 or 4 acres and the land of Tobias Gipson and when so attached that you hold the same subject to the further order of our said cause unless the deft will ??? into bond with security for the fourth coming of the said property at the next Term of our said court - the 4 Monday in April 1871 at the court house in Gainesboro and have you then ??? this this writ and show how you have execute the same.
Witness Robert A. Cox Clerk & Master of our said court at Office in Gainesboro the 3rd Monday in October 1870
In the name of the state of Tennessee to the Sheriff of Jackson County Greetings
You are hereby commanded as as have been heretofore commanded to summons Levi Gipson to appear before the Judge of Chancery Court at the next Term of said court to be holden at the court house in the Town of Gainesboro on the 4th Monday in October 1871 to answer a bill filed in said court against him by Polly Ann Gipson fail not and have you then hear this summons.
Witness Robert A. Cox Clerk & Master of our said court at Office in Gainesboro the 4th Monday in April 1871
R. A. Cox
By A. B. Botts
State of Tennessee
To the sheriff of Jackson County Greeting
You are hereby commanded to summons the complainant John Jackson Leonidas Misser William E. Jones & Paresett Smith to appear before the Judge of the Chancery Court at the next term of said court to be holden at the court house in the Town of Gainesboro Jackson County Tennessee on the 4th Monday in April 1871 to give evidence in behalfe of complainant in a suit now pending in said court wherein Polly Ann Gipson is complainant and Live Gipson is defendant and fail not under penalty presented by law and have you then ??? with this writ.
Witness R. A. Cox C & M at office in Gainesboro the 3rd Monday in October 1871 R. A. Cox