Mrs. M.N. Josey                                  Filed May 3, 1915                                           NO. 19675

            Vs                                                A.S. Hardin                                                 First District Court     

R.L. Josey                                                 Dy Clerk.                                                  Caddo Parish, LA

 

                                                                        Petition.

 

            To the Honorable Judge of the First Judicial District Court in and for Caddo Parish, Louisiana:

 

            The petition of Mrs. N.M. Josey, a resident of your said parish and state with respect represents;

 

1                    That she was married in Miller County, Arkansas, to R.L. Josey, her husband, on the 4th day of July, 1898, and lived with her said husband in said Miller County Arkansas, for a few years, and about the year of 1910, she and her said husband moved to Caddo Parish Louisiana, where they lived together as man and wife until about February 1st, 1913.

2                    That the following named children were born issue of the marriage between your petitioner and her said husband, to-wit: Charley 13 years of age, William 11 years of age, Ralph 8 years of age and Roy 6 years of age.

3                    Your petitioner futher shows that she has been a dutiful and faithful wife to her said husband, but that regardless of her said husband’s marriage vows, he has abandoned your petitioner and that on or about the 1st day of February, 1913, your petitioners said husband was guilty of cruel treatment toward your petitioner, that he struck your petitioner with a dangerous weapon, commonly called a trunk lid, and that he made an assault upon your petitioner with a certain dangerous weapon, commonly called a shot gun, and threatened to take the life of your petitioner;

4                    Your petitioner futher shows that said above described cruel treatment and attempt upon the life of your petitioner, is of such a nature as to render their living together insupportable. And a judgment for separation of bed and board should be granted. 

5                    Your petitioner further shows that she being the mother of the above named children is entitled to their care and custody.

6                    Your petitioner futher shows that she should be authorized to stand in judgment and prosecute this suit, she being a married woman.

7                    Your petitioner futher shows that her said husband is an absentee he having left the state of Louisiana permanently and a curator ad hoc should be appointed to represent him herein. Wherefore your petitioner prays that she be authorized by the Court to institute and prosecute this action, that a curator ad hoc be appointed herein to represent her said husband in this suit, he being an absentee; that her said husband be cited, through said curator ad hoc to appear and answer this petition, that after due and legal proceedings had, that there be judgment in favor of your petitioner and against her said husband, granting her the care and custody of her above named children, and in due cource, that your petitioner have judgment in her favor decreeing a separation “a mensa et thro” from her said husband. And for general relief.                                                    Mabry & Foster Attorneys for Petitioner