State of............

............County.

ss.

In the........Court of........County.

To the........Term, A. D. 190..

vs.

.............................

Bill for Divorce.

To the Honorable...................., Judge of said Court,

In Chancery Sitting:

Humbly Complaining Unto Your Honor. ., your orator............

............of...................., in the County of.................., and State of....................respectfully shows that he is, and for more than a year last past, continuously, immediately preceding the filing of this bill of complaint, has been an actual resident of the State of................

Your Orator Further shows unto Your Honor.., that on or about the...................day of........................A. D. 190..., at..................in the State of..................he was lawfully joined in marriage with............................, of................

in the State of...................., whom your orator prays may be made a party defendant hereto, and from thence hitherto, until on or about the

............day of................A. D. 190.., your orator and the said defendant lived and cohabited together as husband and wife.

Your Orator Further shows unto Your Honor.., and charges that the said defendant, on or about the....................day of............

........, A. D. 190.., wilfully, and without any reasonable or just cause therefor, deserted and abandoned your orator, and wholly refused to live and cohabit with him any longer as husband and wife, and from thence hitherto, up to the time of filing this Bill of Complaint, has continuously absented herself from him and refused to return and live with him as husband and wife, and still does, without any fault on the part of your orator.

Your Orator Further shows unto Your Honor.., and charges that ever since the said marriage, he has conducted and demeaned himself toward the 6aid defendant as a true, faithful, chaste and affectionate husband, but the said defendant, wholly regardless of her marriage vows, for a considerable time past, given herself over to adulterous practices; that on or about the

....................day of..................A. D. 190.., at..........

in the State of.............., the said defendant committed adultery with one.................................................................

.............................................................................................................................

and at divers other times and places since said marriage the said defendant committed adultery with one................................, and with divers other lewd men, whose names are to your orator unknown............

.........................................................................................................................

Forasmuch, therefore, as your orator is without remedy in the premises, except in a court of equity; your orator prays that the said................

............who is made party defendant to this bill, may be required to make full and direct answer to the same; that the said marriage between your orator and the defendant may be dissolved and declared null and void, by the decree of this court, according to the statute in such case made and provided;...........................................................

and that your orator may have such other and further relief in the premises as equity may require and to your honor shall seem meet.

And May it Please Your Honor To grant unto your orator the writ of summons in chancery issuing out of and under the seal of this Honorable

Court, to be directed to the said defendant.............................., therein and thereby commanding her by a certain day, and under a certain penalty, to be therein inserted, that she personally be and appear before this Honorable Court, then and there to stand to, abide and perform such order, direction and decree therein as to Your Honor... shall seem meet according to equity and good conscience.

And Your Orator, As in duty bound, will ever pray, etc.

............................................

...................................... ...............................

Solicitor.. for Complainant.

State of............

............County.

ss.

..................................being duly sworn, says that he is the Complainant whose name is subscribed to the foregoing Bill of Complaint; that he has heard the above Bill of Complaint read, and knows the contents thereof; that the said Bill of Complaint is true of his own knowledge, except as to the matters and things therein stated to be upon information and belief, and as to those matters and things he believes it to be true.

Subscribed and Sworn to by the said.................before........

me this..............day of........

.............................................

....................................................................