Original Bill for Divorce Filed June 27, 1918
To the Hon. A. H. Roberts, Chancellor, holding the Chancery Court at Carthage, Tennessee.
Alice Read Hubbard, a resident of Smith County, complainant,
vs
Bobbie Hubbard, a citizen of like residence, defendant.
The complainant would respectfully show to the Court:
That she and the defendant, Bobbie Hubbard, were married in Smith County, Tennessee, on the 16th day of April, 1916 and that she has been a resident of said county ever since.
That the defendant was resonably kind to her for a few months after their said marriage, but soon claimed to be jealous of her, which she asserts was without cause, and would get mad at her, and accuse her of being too intimate with other men, and in the late Winter or early Spring of 1917 he got mad with her and slapped her down with his hand. He continued to complain at her after the above incident, from time to time, would curse her, hit her with his hand and fist, kick her, and at one time hit her with a stick of stove- wood, called her a bitch on various occasions, and on one occasion cursed her and called her a whorish bitch.
She continued to live with him and bear his cruelty and insults longer than she should have done, and longer than she would have done, if she had been a woman of more mature years. She continued to live with him until the fourth Sunday in April 1918, at which time he got mad with her and slapped her and the chair in which she was sitting out of the door, the door being about three feet from the ground. At this time he left a bruise on her body as he had done on other occasions. She states that he was very beastly in his desires and practices. On the occasion last mentioned in April, 1918, she states that she left him, as she could not bear his treatment any longer and has fully made up her mind never to live with him again.
She states that said defendant has been guilty of such cruel and inhuman treatment and conduct toward her, as renders it unsafe and improper for her to cohabit with him and be under his dominion and control.
That he has offered such indignities to her person as to render her condition intolerable, and thereby forced her to withdraw.
Complainant states that she has been kind and good to the defendant, that she was always true to her marital vows, and that she did not give the defendant any cause or just excuse for his misconduct.
The premises considered, complaintant prays:
That process issue to compel the defendant to appear and answer this bill fully, but the oath to his answer is expressly waived.
That an absolute divorce be granted her, that her maiden name, Alice Read Lynch, be restored to her.
That she may have all such other, further and general relief to which in justice she may be entitled.
Signed: Alice Read Hubbard
Signed: W. V. Lee, SOLICITOR
State of Tennessee, Smith County
Alice Read Hubbard, being duly sworn, makes oath that the facts stated in her foregoing bill are true, to the best of her knowledge and belief, that her complaint is not made out of levity or by collusion with the defendant, but in sincerity and truth, for the causes mentioned in the bill; and that owing to her poverty she is not able to bear the expenses of this suit, and that she is justly entitled to the redress sought.
Signed: Alice Read Hubbard
Sworn to and subscribed before me, June 27th, 1918.
Signed: J. H. Gardenhire C. & M.
___________________________________________
Alice Read Hubbard
vs. Order Pro Confesso
Bobby Hubbard
In this cause, it duly appearing to the Court that the defendant, Bobbie
Hubbard, has been regularly served with subpoena to answer the complaintant's
bill and that said
degendant has failed to appear and make defense to said bill, within the time
required by law; it is ordered that as to said defendant, complainant's bill
be taken as
confessed, and the cause set for hearing ex parto.
_____________________________
Alice Read Hubbard
vs. Decree for Divorce
Bobbie Hubbard
This cause came on to be heard, this September 3rd, 1918, before W. R. Officer, Chancellot, etc., upon the bill of the complainant, and order pro confesso heretofore entered against the defendant, and the oral testimony of witnesses examined in open court.
And it satisfactorily appeared to the Court from the proof that the facts charged in the bill are true; that the defendant has been guilty of such cruel and inhuman treatment and conduct toward the complainant, as to render it unsafe and improper for her to cohabit with him, and be under his dominion and control; that he has offered such indignities to her person as to render her condition intolerable, and thereby forced her to withdraw from him; and that complainant never gave the defendant no cause or just excuse for his misconduct toward her.
It is, therefore ordered, adjudged and decreed by the Court, that the bonds of matrimony subsisting between the complainant and the defendant be absolutely and forever dissolved, and that complainant be vested with all the rights of an unmarried woman and that her maiden name, Alice Read Lynch, be restored to her.
That the complainant have and recover of the defendant, Bobbie Hubbard, all the costs of this cause, for which execution may issue.