State of Illinois
White County

In White Circuit Court
To May Term A.D. 1921

Isaac N. Felty vs. Lillie Felty
Bill for Divorce

To the Honorable Judges of the Circuit Court of the County of White, in the State of Illinois.

In Chancery sitting:

Your oratrix Isaac N. Felty, of said county, respectfully represents unto your honors, that he is an actual resident of the county of White aforesaid, and that he has been for more than two years last past a resident of the State of Illinois; that on the 1st day of April A.D. 1914 in said county he was lawfully married to one Maur now Lillie Felty, the defendant hereinafter named, that there have been born to said union three children namely Wilburn Felty aged seven years, Wilma Felty now aged three years and Aileen Felty aged five years, that since his marriage to the defendant he has always himself toward her as a chaste dutiful and affectionate husband.

Your orator further represents, that the said Lillie Felty, wholly disregarding her marriage vows, duties and obligations towards your oratrix, has ever since said marriage been guilty of extreme and repeated cruelty towards your oratrix; that is to say, that the said Lillie Felty on divers days and times since said marriage, has struck, beaten and otherwise ill treated your oratrix, and particularly that on or about one year after their said marriage she struck your oratrix with a stick of wood and often threw sticks of wood at your oratrix and that your oratrix would have to flee from their said home to keep from receiving great injury at the hands of the said defendant.

Your oratrix would further represent unto your honors that this extreme and repeated treat and cruelty continued until on or about the 15th day of April A.D. 1920 when he and the said Lillie Felty separated.

Your orator would further represent, that at the time of these several acts of cruelty by the defendant towards your oratrix the defendant would be guilty of the most profane abusive and vulgar language towards your oratrix and in the presence of various people and in the presence of their said children.

Forasmuch, therefore as your orator is without remedy in the premises, except in a court of equity; and to the end that the said Lillie Felty, who is made party defendant to this bill, may be required to make full and direct answer to the same; that your orator may be divorced and forever freed from the bonds of matrimony now existing between your orator and the said Lillie Felty; that your oratrix may have such other and further relief in the premises as equity may require and to your honors shall seem meet.

And may it please your honors, to grant unto your orator the writ of summons in chancery, directed to the sheriff of the said county of White, commanding him that he summon the defendant Lillie Felty to appear before the said court, on the first day of the next May term thereof to be held at the court house in Carmi, in the county of White aforesaid then and there to answer this bill, etc.

Isaac N. Felty
Complainant

F. M. Parish
Solicitor for Complainant