The Archive · 1902

The Divorce Sur

a vineu' was procesiied with.

The secund suit, which wis or div-nee

affidavit.

Mr. Curtis, tists pot in the following

Mrs. John Henry Rolker being first duly sworn deposes and says, that'she is the plaintiff in the above entitled action that her sole source of revenue consists of the defendant's promise to pay herself and daughter's board bill ay the Board House, No. 17, Nanking Road, and one hundred dollars Mexican, for sonal expenses of herscli and daughter hat defendant has threatened to bre s promise to pay this board bill and prive her of the meagre sum allowed herself and daughter for personal expenses, and force her to earn her own living even if it were necessary for her to scrub floors to do so.

Wherefore the plaintiff prays this Honourable Court that she be allowed tro hundred dollars gold a vioull, -foi herself and daughter, pending the trial of this action, and two hundred dollar gold, counsel fees to prosecute her for_ divorce. a tier. aghter we.

Jer was made coulingly.

The first, ani send wee tau stine others set torch —That ire the 12th day of October, 1881, to about June, 1882, the plaincitt and defendant lived together: in Maracaibe, Venezuela, and from about sine 1882, to August, i899 they lived toget in Now York, and irom about august 1899, to Novembes, EL, they uveu together i ised, and sco id date of filing of Chis petition and at present time, the plaintiff and dete ty with the exception of about three weeks, dating from the said 17th day of November, 100i, have noe lived ana wohabiiedt together in the relation of husband il That the plaintiff has by the d side City of Shanghai, and the defendant resides at No. 33, Kian Road. That the plaintiff has resided cons tantly and uninterruptedly in. the said hai, since Tick day: 19G1, to the presoitt time, defendant has resided const: interruptedly in the said City of Shanghai from about ths—day of Deesmber 1900 to the present time.

4.—That the defendant is the Manager of the American firm of Castle Brothers, and rreeives th firm of four hundred della: anth, ist lawful money of the United States, or its equivalent in Mexican dollars, together with a certain interest in the profits of the said business. -"5.—That the plaintiff hath in all respects demeaned herself as a kind and affectionate wife, and although by the lacs of God, a: well as vows plighted to each other, they were bound to that uniform constancy and rerd which ought to be inseparable from the marriage state, yet so it is,'that the said defendant John Henry Kolker, in solation of his marriage vow as well as of the laws of the United States of America, has offered such indignities to 5—Defendant. states. that_aS he. has to plaintiff $90.07 on account, he had said all Tight tke your money the person of the plaintiff as to render

Text read from the printed page and cleaned; old type leaves the occasional error.

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