Transcribed by William R. Stout

Source: Jackson County Chancery/Circuit Loose Records
Roll: #87
Available: Tennessee State Library & Archives and Tennessee Technological University Library

America J. Jones
Millard M. Jones

To the Honorable N W McConnell Judge of the fifth Judicial Circuit of Tennessee presiding at Gainesboro Tennessee.

The Bill of complaint of Millard M Jones a citizen of Jackson County Tennessee
America Jones a citizen of same residence.

Humbly complaining your orator would would most respectfully represent to your Honor that he and defendant were intermarried in Jackson County Tennessee on the __ day of ____ 1876 and lived together as husband and wife from that time until sometime during the fall season of 1878, when complainant by defendants conduct was forced to abandon her and no longer claim her as his wife and companion.

Complainant is informed and believes and so charges that the defendant was at the time of his abandoning her, and has since been guilty of repeated acts of adultery with one Alfred Rush and C.C. Mahanay and he is informed and believes and so charges that she is now pregnant the result of her illicit intercourse with the aforesaid Alfred Rush and C.C. Mahanay.

Complainant further show that he has always been to the defendant a kind and affectionate sworn to and subscribed (?) in defense Millard while he was (Unreadable) her as a husband having full regard to the vow he had taken when he was united with her in marriage.

Complainant states that he has not cohabited with Deft at anytime after his knowledge of her illicit intercourse with the aforesaid Rush and Mahanay.

Complainant states that he has been a citizen of the State of Tennessee for more than two years before the filing of this Bill.

The promises considered the Complainant prays that America Jones be made defendant to this Bill, that copy and process issue to require her answer this Bill, and upon a final hearing Compl't prays that the Bonds of Matrimony now and heretofore subsisting between him and defendant be dissolved, and he be restored to all the rights and privileges of a single man and for all such other, further and general relief as he may be entitled and he will ever pray.

B.A. Butler Atty for Compl't.

State of Tennessee
Jackson County

Personally appeared Millard M. Jones the Compl't in foregoing Bill and makes Oath in due form of law that the facts therein stated are true to the best of his knowledge and belief and that his complaint is not made out of levity or collusion with the Defendant but in sincerity and truth for causes mentioned in the foregoing bill and subscribing this affidavit before this ___ day of Dec (blotted) and afficant states that (blotted) to his (blotted) is uable to have the exp (blotted) he is justly (blotted out to end unable to read remainder)

State of Tennessee
To the Sheriff of Jackson County


You are hereby commanded to summons America Jones to personally appear before the Judge of the Circuit Court of Jackson County to be next held at the Court house in the town of Gainesboro on the first Tuesday after the 2nd Monday in January next, there and there to answer the Bill of Complaint of Millard M. Jones for Divorce. Herein fail not and have you there and there this writ showing how you have executed the same. Witness W.M. Gailbreath Clerk of sain Court at Office the first Tuesday after the 3rd Monday Sept 1881

W.M. Gailbreath C&M

Second Summons sent to Sheriff of Jackson County for America to appear
dated 2nd Monday of January 1882.

Millard M. Jones
America Jones

In this case we agree that John Stout have the custody and control of our child Letha Louretta Jones age four year. The said John Stout is the Grandfather of the child and has raised and maintained it up to the present time and is better able to take care of the child than either of the parties.

We therefore ask the court to decree the custody of the child to John Stout it Grandfather he being present in court and accepts the said gift of the said infant and that the parties ask that this be spread upon the record and made part of the decree in the above cause. It is further agreed between the parties that the said Millard M. Jones have the right and privileges to visit the child at anytime.

Millard M. Jones America Jones

To the Hon. N.W. McConnell Judge of the Circuit Court of Jackson County

The Bill Complaint of America J. Jones of said county and state
Millard M. Jones of The State of Texas.

Complainant charges that she and defendant were married in said county and State first above named about ten years ago where she has ever since resided.

They lived together about two years where defendant willfully & maliciously abandoned complainant without any reasonable cause, she having been to him a dutiful wife.

Since then he has not provided anything for her support and that of their child Aletha Louretta Jones about seven years old.

He has remained absent from Complainant more than two whole years and about three years ago last May defendant left county going to the State of Texas as she is informed.

Complainant has no property except a few hogs and a cow & a few household goods that are in her possession and a small patrimony left her by her father John Stout who recently died. Complainant has possession of said child and is the proper person to have its custody.

The promises considered complainant prays that defendant be brought before the Court by publication to make defense hereto that on hearing she be granted a divorce and the custody of said child and that said property be decreed to her & for general relief.

Geo H. Morgan

State of Tennessee
Jackson County

America J. Jones makes oath in due form of law that the statements contained in the foregoing are true according to the best of her knowledge information & belief. She further makes oath that the Complaint is not made out of levity or by collusion with the defendant but is sincerely& truth for the purposes stated in the bill. She further makes oath that owing to her property she is unable to bear the expenses of this suit and that she is justly entitled to the relief sought & subscribed this affidavit before me this 7 day of December 1885.

America J. X Jones

Sworn to and Subscribed
Before me Dec 7, 1885
W.M. Gailbreath C & M.