The Dallas Journal, Volume 51, 2006 Page: 3
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Early Twentieth Century Divorce
State of Texas, * In the District Court of Dallas County, Texas in and for the County of Dallas
* Judicial District of Texas.
To the Hon.Judge of said Court.
Ben C.Nelson,Jr., hereinafter styled plaintiff, complaining of Annie Momand Nelson,hereinafter styled
defendant, brings this suit for the purpose of obtaining a divorce from the said Annie M.
Nelson,defendant,alleging for grounds,excessive cruel treatment and outrages toward plaintiff on the
part of the said Annie M. Nelson,defendant,and for grounds of his said action,he alleges:
1st. That plaintiff is a bona-fide inhabitant of the County of Dallas & State of Texas,and has been for
more than six months preced- the filing of this suit,and that defendant is a resident of Dallas County
That plaintiff and defendant were legally married in Dallas County Texas July 16th .1899
That plaintiff and defendant lived peaceably together as husband and wife, for about six weeks after
marriage,when upon plaintiffs' suggesting a visit to plaintiffs fathers home,defendant became suddenly
angry and at first refused to go,but finally did go,and while on the way and after reaching there,
defendant was and continued to be violently angry,without any provocation whatever she violently
abused plaintiff,calling him vile names ,slapping and striking him,and on one occasion breaking her
parasol over plaintiffs head,and fighting him with anything that came to hand.Plaintiff all the while
bearing with her as best he could and offering her no provocation whatever. On another
occasion,sometime in Sept. 1899, plaintiff and defendant visited Ft.Worth,Texas,remaining over
night,defendant fought plaintiff all that night,biting and scratching him,and hitting him with anything
she could get hold of.All the while plaintiff bore with her, offering no provocation whatever. This kind
of conduct continued on the part of defendant,till finally on Feb. 18th,1900,while at plaintiffs fathers
home,defendant fought plaintiff and spit in his face two or three times, this conduct continued till
finally on the morning of Feb. 19th. 1900,plaintiff left defendant being unable to bear with her longer.
On every occasion in addition to her violent and abusive conduct, defendant has slandered plaintiff
and his family. In one instance defendant wrote plaintiffs friend
N. C. Boles, of Ft- Worth, a long letter, slandering plaintiff in every way, using language too vile for
repetition;and at various other and sundry times she has written silimar letters to other parties. Defendant
would approach strangers and mere acquaintances and charge her husband the plaintiff, with having
venereal diseases.Royal Tombly,Leslie Wright and various others she approached in this way.
Plaintiff says that at all times he conducted himself toward defendant as a good and dutiful husband
should, and at no time did he do or say anything to defendant calculated to arouse or anger her in the
Plaintiff alleges that defendant has been guilty of such excesses, cruel treatment and outrages toward
him, and that such ill-treatment was and is of such a nature as to make their living together insuportable.
Premises considered your plaintiff prays the court that defendant be cited to appear and answer this
petition,and that on final hearing the bonds of matrimony between plaintiffand defendant be forever
dissolved,and for such other relief general and special as may be mete in the premises,in duty bound will
/s/ R. B. Seay
Attorney for Plaintiff.
Dallas Journal 2006 3
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Dallas Genealogical Society. The Dallas Journal, Volume 51, 2006, periodical, October 2006; Dallas, Texas. (texashistory.unt.edu/ark:/67531/metapth186865/m1/7/: accessed May 26, 2017), University of North Texas Libraries, The Portal to Texas History, texashistory.unt.edu; crediting Dallas Genealogical Society.