Transcribed by William R. Stout
Source: Jackson County Chancery/Circuit Loose Records
Available: Tennessee State Library & Archives and Tennessee Technological University Library
To the Honorable W L Crowly Chancellor of the Chancery Court of Jackson County Tennessee
The bill of complaint of Margaret Stout of said county against William Stout of the same county
Your oratix would respectfully show that the defendant married her on 17 day January 1867 in this county and state of Tennessee and there were borned of said marriage - seven children five boys and two girls whose names here follows Sidney Lee, Milton Robert, Mettie Mercilla, Adolphus Tennessee, Albert Hyden, Jones Courphill (?), and Minnie Ellen Stout. That the defendant has been guilty of such cruel and inhuman treatment or conduct towards her as renders it unsafe and improper for her cohabit with him or be under his dominion and control, that defendant has offend his (unreadable) (unreadable) to her person to render condition untolerable. That on __ day 1882 in said county defendant struck your oratix four or five times and kicked her with his knee. That on day of Sept 1882 defendant (unreadable) Sidney Lee Stout the old child and (unreadable) of your oratix and the defendant to kill your oratix and that (unreadable). That on the 11 day of Sept 1882 defendant (unreadable) observed striking her several blow and causing her (unreadable) to be done and threaten to kill your oratix. That the defendant owner of two hogs sow & pigs and one other hog, household and kitchen furniture bed and bed clothing warming apparel. That defendant made a crop with Campbell Smith on the (unreadable) entitled to two fifths of said crop consisting one half crop of corn and parcel (unreadable) Cabbage patch and Turnip patch. All said property is on farm of said (unreadable) (unreadable) Jackson county Tennessee on Martins Creek and (unreadable) Fork of said Creek bordered by the lands of T J Lee & others.
That your oratix has been a citizen of said county more than two whole years before the filing of this application. That defendant has sold or is about fraudulently dispose of said property in order to defeat your oratix right of alimony. The previous caused your oratix prays for a divorce dissolving said bond of matrimony and for alimony for the custody and care of her said children and for an attachment to allow the said property and infructure to(unreadable) the defendant (unreadable) (unreadable) the person of your oratix and (unreadable) her in the (unreadable) of said property until (unreadable) and for general relief.
Came before me Margaret Stout and made oath the allegations in a foregoing bill are true to the best her knowledge & belief, that (unreadable) to property she is recoverable to (unreadable) the expenses of the actions which she (unreadable) to Chancery Court of said County against William Stout and that she is properly entitled to the (unreadable) (unreadable). To the best of her knowledge and belief that said complaint is not made out of bevity or in collusion with the defendant but in sincerity and truth for the cause contained herein.
Sworn and subscribed before me 17 Sept 1882
Margaret B Stout
Signature of C & M (unreadable).
State of Tennessee
To the Sheriff of said county.
Where as Margaret Stout has filed her bill of complaint in our Honorable Court of Chancery at Gainesboro Tenn against Wm. Stout upon oath charging among other things that they were married in the year 1867 and that they have seven children issue of said marriage & that the defendant has offered such insults to her that it is improper & inhuman to her as renders it unsafe & improper for her to live with and cohabit with said defendant & charging him on other things that the defendant is the owner of a share in a corn crop raised on the farm of Campbell Smith on Martins Creek adjoining the lands of J Lee and others and that he is the owner of a lot of (unreadable) stuff cabbage turnips and that he is the owner of (unreadable) household & kitchen furniture and (unreadable) among other things for (unreadable) of (unreadable) to issue which (unreadable)has been granted.
A (unreadable) therefore you are (unreadable) commanded forthwith to attach all of said property mentioned here in & (unreadable) (unreadable) upon bond & good security that the same. Further owners be (unreadable) at our said court to be (unreadable) at the court house on the 4th Monday in September 1882 Where and when you will make known you have executed this writ.
Witness: Tlo W Williams
Clerk & Master of said court at office in Gainesboro on the 2nd Monday
in March 1882.
Tlo W Williams