Tressie Packnett, Plaintiff

vs

Charles T. Packnett, Defendant

State of Oklahoma, County of Pushmataha

Office of Court Clerk

Filed January 3, 1924

By J. C. Moyer, Court Clerk

WELCH & WELCH, Antlers, Okla., Attorneys for Plaintiff

Comes now the plaintiff, Tressie Packnett and for cause of action against the defendant, Charles T. Packnett, alleges and states:

That she is now and has been for one year next preceding the filing of this petition an actual resident in good faith of the State of Oklahoma, and is now an actual resident in good faith of this County.

That said plaintiff and said defendant were legally married at San Antonio, Texas, on the 20th day of December 1922, and have ever since been husband and wife. That of said marriage one child, to-wit, Charles Ray Packnett, was born.

That from the date of their said marriage until the separation of plaintiff and defendant said defendant was guilty of extreme cruelty towards this plaintiff in that said defendant continually cursed said plaintiff and applied vile epithets toward her both in private and public; that during said period defendant repeatedly struck and beat this plaintiff with his hands and fist; that defendant was intensely jealous of plaintiff's associations with and regard and affections for her sisters and mother, and defendant would continually abuse and mistreat plaintiff for desiring to visit with and be visited by her said close relatives, although this plaintiff alleges that she did not permit her associations and affections for her said mother and sisters to interfere with her duties toward this defendant as his wife; that defendant's cruelty, striking, abusing and cursing of plaintiff finally became so unbearable that plaintiff was forced to cease living with him. That in the early part of November 1923, in a quarrel over the continued affections of plaintiff for her mother and sisters, the defendant flew in a rage and struck plaintiff with his closed fist, whereupon plaintiff separated from the defendant and has since lived with her mother in Antlers where she has had custody of and supported the said child of said parties, Charles Ray Packnett.

That plaintiff has always demeaned herself properly, and acted toward her said husband, Charles T. Packnett, as a faithful wife, and is without fault in the premises; that she has given said defendant no cause or provocation whatsoever for his extreme cruelty towards her as aforesaid.

Wherefore plaintiff prays that she may be divorced from her said husband by reason of the fault of said defendant as aforesaid; that she be allowed and decreed the care and custody of the said child of her marriage with defendant, and that she have all other proper and equitable relief.

Signed by Welch & Welch, Attorneys for Plaintiff

STATE OF OKLAHOMA, Pushmataha County.

Tressie Packnett being first duly sworn on her oath states: That she is the plaintiff above named; that she has read the foregoing petition; knows the contents thereof and that the matters and facts therein set forth are true and correct.

Signed by Tressie Packnett

Subscribed and sworn to before me this 1st day of January 1924.

Signed by Gena May, Notary Public

My Commission Expires March 21, 1925.

_________________________

No. 1543

App. Docket, Civil No. 3, Page 405

IN DISTRICT COURT

vs

Issued January 3rd, 1924

Returnable 13th of January, 1924

Ans. Due February 4th, 1924

Attorney for Plaintiff: Welch and Welch

You are hereby commanded to notified Charles T. Packnett that he has been sued by Tressie Packnett in the District Court of Pushmataha County, Oklahoma and that Charles Packnett must answer the petition of said Tressie Packnett filed against him in said Court, in the City of Antlers in said County, on or before the 4th day of February 1924, or said petition will be taken as true and judgment rendered accordingly. You will make return of this summons on or before the 13 day of January 1924. Given under my hand and the seal of said Court this 3rd day of January.

Signed by J. C. Moyer, Court Clerk.

_________________________

No. 1543

vs

State of Oklahoma, County of Pushmataha

Office of Court Clerk

Filed January 14, 1924

By J. C. Moyer, Court Clerk

Comes now the defendant, Charles T. Packnett and hereby acknowledges service of the foregoing summons upon himself on date herein set out, enters his general appearance herein, and hereby waives further time in which to answer, and waives notice of the trial of this cause and agrees that this cause may be set down for trial and tried at any time without his attendance and without notice to him.

Dated this 11th day of January, 1924.

Signed by Chas T. Packnett