Jackson County IL Archives Divorce.....Grammer, Margaret - Grammer, John Wesley (Jr.) April 1, 1878
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Chancery Court Divorce Petition March 1878
CHANCERY COURT DIVORCE PETITION MARCH 1878 MARGARET GRAMMER vs JOHN WESLEY
GRAMMER, JR. 

TO THE HON. M. C. CRAWFORD, JUDGE OF THE FIRST JUDICIAL CIRCUIT OF ILLINOIS, IN
CHANCERY SITTING 

Your Complainant, Margaret GRAMMER of Jackson County Illinois, respectfully
requests unto your Honor, that she is an actual resident of said county and has
been a resident of Jackson County, Illinois for a number of years last past;
that on the 4th day of July 1872 in said county and state, she was lawfully
married to one John W. GRAMMER, Jr., the defendant hereinafter named, and
continued to live and cohabit with him as his wife, until about the 15th day of
May, 1877, when she learned, and became convinced, of his infidelity to his
marriage vows and obligations, as hereinafter charged, and thereupon left him,
and has refused to live and cohabit with him, as his wife, ever since. 

Complainant further represents, that she has ever since said marriage, demeaned
herself to the said John W. GRAMMER, Jr., as a faithful, chaste, and
affectionate wife; and as the issue of said marriage, Complainant has born of
the said John W. GRAMMER, Jr., two children, viz: Louis Franklin and Victoria,
now aged four and two respectively, who are both living and have remained under
the care and control of your complainant. 

Complainant further represents that the said John W. GRAMMER, Jr., wholly
regardless of his marriage duty, obligations and plighted faith, has for a
considerable time past, and subsequent to the said marriage, to wit, from
October 1875, given himself up to adulterous and licentious practices; that on
or about the 29th day of August 1877, he, the said John W. GRAMMER, Jr., took
with him one notorious character, to wit, one Ada CUNNINGHAM of Carbondale,
Illinois, and eloped, and for months absconded, and lived with said Ada
CUNNINGHAM in a state of adultery and has at ______ other times and place, since
said marriage, to complainant unknown, committed adultery with the said Ada
Cunningham, and with divers and other lewd women, whose names are also to your
complainant unknown. 

Complainant further represents that the said John W. GRAMMER, Jr., is a man of
low, vicious, and vulgar habits, and is addicted to the use of obscene and
profane language toward your complainant and their said children; and is a
person wholly unfit to be entrusted with the care, custody and education of
children. 

Forasmuch, therefore, as your complainant is without remedy in the premises,
except in a court of equity; and to the end that the said John W. GRAMMER, Jr.,
who is made party defendant to this bill, may be required to make full and
direct answer to the same; that your complainant may be divorced and forever
freed from the bounds of matrimony now existing between her and the said John W.
GRAMMER, Jr.; that the care, custody and education of the said children may be
awarded to your complainant; and that your complainant may have such other and
further relief in the ___________ as equity may require, and to your Honor shall
seem meet. 

May it please your Honor to grant the writ of summons in chancery directed to
the sheriff of the said county of Jackson commanding him to summon the defendant
to appear before the said court on the first day of the next March Term thereof,
to be held at the court house in the city of Murphysboro, in the county of
Jackson aforesaid, then and there to answer this bill, etc. 

Margaret GRAMMER Complainant By Geo. W. HILL, her solicitor 

Subscribed and sworn to before me This 7th day of February 1878 Robt. W.
HAMILTON, Clerk 

Margaret GRAMMER being duly sworn on her oath says that she is the complainant
in the above styled cause; that she is a poor person, and has a just and
meritorious cause of action; that she is unable to prosecute herself said suit
and pat the costs and expenses thereof. 

Complainant therefore prays to be allowed by this court to prosecute her said
cause of action without having costs to pay a poor person. 

MARCH TERM 1878 

Margaret GRAMMER being duly sworn, on her oath says that she is the complainant
in the above suit; that John W. GRAMMER, the defendant in said suit, is a
non-resident of Illinois as Complainant is informed and believes; that he was a
resident of this county and state at the time Complainant filed her bill of
complaint; and immediately thereafter he left this state, or so secreted himself
that his exact whereabouts can not be ascertained or personal service can be had
on him; that Complainant has made due and diligent inquiry to ascertain
defendants place of residence since he departed, but without effect - only that
she learns from his relatives that he is a resident of the state of Texas,
Missouri, or Arkansas but just where he is Complainant is not, after diligent
inquiry, able to know and state. Complainant would state that upon such
information and belief, that defendant is a resident of either Missouri or
Arkansas, but his exact place of residence or post office address, Complainant
can not positively state. 

Subscribed and sworn to before me this first day of April A.D., 1878 Robt. W.
HAMILTON, Clerk 



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