FANNIE B. PERRY VS. LUKE H. PERRY - 1909 - Jackson Co, GA

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Submitted by Michael M. Black -mmblack@valdosta.edu
26 September 2001
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Jackson County, GA
Civil Cases Book D, page 27

""""""""""""""""""""""""
"   FANNIE B. PERRY    "
"        VS.           "    LIBEL FOR DIVORCE.
"      LUKE H. PERRY   "
""""""""""""""""""""""""

   GEORGIA, CLARKE COUNTY.   TO THE SUPERIOR COURT OF SAID COUNTY.
The petition of Fannie B. Perry shows the following facts: Par. I. That 
the third Sunday in Jan. 1906 the plaintiff and one Luke H. Perry of 
said County, intermarried in due form of law, to-wit:
in the County of Jackson and State of Georgia. Par. II. That your 
petitioner and the said Luke H. Parry lived together as husband and 
wife until the ----- day of Jan. 1908, your petitioner in the meantime
performing all the duties of a faithful and affectionate wife. Par. 
III. Your petitioner was then, and has been since a bona fide resident
of the State of Ga., twelve months next before the filing of this 
application. Par. IV. Petitioner shows that she was very affectionate
and kind to her husband from the time of their marriage up until the
separation, and that during that time said husband had not the least
cause to complain of your petitioner; notwithstanding this the said 
defendant has treated your petitioner in a cruel and inhumane manner,
so as to make it impossible for her to continue her habitation with 
him, and in consequence thereof on the day last mentioned she separated
from the Defendant end has ever since refused to renew her co-habitation
with him; petitioner specifies in part the acts constituting the 
treatment of the defendant toward her as follows Shortly after the 
marriage the defendant ceased to care for her and became indifferent
and abusive, calling your petitioner many vile names, and told her 
to go home to her father, and this while she was en famile, that 
defendant often threatened to knock her down, and finally after 
the baby was horn, struck her in the face with his hands, that defendant
became enraged because petitioner was unable to go to the field 
and hoe cotton, that at this time the baby was only two months old.
Par. V. Your petitioner further shows that the defendant had a one 
horse crop on the farm of Sam Swindles, working on halves, and that
with her labor she helped to make said crop, and with her labor 
she helped to purchase the household and kitchen furniture. Par. 
VI. That the defendant is an able bodied man, young and in good 
health, and is able to earn $30.00 per month as a laborer.
Par. VII. Your petitioner further shows that the issue of said marriage
is one child, born on the 26th, of March, 1907, viz: Raymond Perry. 
Par. VIII. That she is entitled to her share in the crop she helped 
to make, that she is entitled to temporary and permanent alimony, and
cost and counsel fees for bringing this suit. Wherefore your petitioner
prays: 1. That a total divorce from defendant that is to say a divorce
a vinculo matrimonii upon legal principles he granted between the 
petitioner and the said Luke H. Perry. 2. That the custody of the boy,
Raymond Perry, above mentioned be awarded to the petitioner. 3. That
a reasonable provision for permanent alimony be made for her support
and the support of the child above mentioned, out of the property 
and labor of the defendant.
4. That the defendant be requested to pay a reasonable sum into the 
court to defray the expense of this action, and for counsel fees and
that he pay to the petitioner such further sums for temporary alimony
for the support of herself and her child, during the pendancy of 
these proceedings, as may seem just to the court. 5. That process may
issue direct to the defendant requiring him to be and appear at the
next term of the Superior Court, to be held in and for said county, 
to answer your petitioner's libel for total divorce. Shackelford & 
Shackelford, Petitioner's Atty.

I have this the 17 day of July, 1908 served the defendant Luke H. 
Perry personally with a copy of the within writ and process. Frank 
Collier, Deputy Sheriff.
Received of S. J. Nix, Clerk Superior Court, $2.OO my cost in the 
within stated case, B. H. Collier, Shff.

Filed in office July 14, 1908. S. J. Nix, Clerk.
Recorded Jan. 28, l909,
                                   S. J. Nix, Clerk.