In the Tippecanoe
Circuit Court, February
Term A. D. 1852

To the Honorable Isaac Taylor Judge of said Court in Chancery Setting:

Humbly complaining shows unto your Honor, your Oratrix Rachel Shigley now and for many years, a resident of said county that about eighteen years since she intermarried with one Adam P. Shigley (who your Oratrix prays may be made defendant herein) and lived with him as a dutiful, faithful and affectionate wife until the 14th day of October 1851.  When the said Adam, without any cause or fault whatever on the part of your Oratrix abandoned her and fled from the State of Indiana.  That he took with him one Sabrina Turner, the wife of one of his neighbors, a woman about twenty eight years of age, and a woman of infamous character, and with whom, as your Oratrix has since learned, the said defendant had long been maintaining illicit and adulteress intercourse and your Oratrix expressly charges that the said defendant is guilty of adultery with the said base woman, Sabrina Turner), with whom he eloped as aforesaid, and left the State of Indiana with the intention as your Oratrix believes and charges of never returning.  That even should he return his treatment and infidelity to her have been such as to render it utterly impossible that she could ever be reconciled to live with him again.  Your Oratrix further shows unto your Honor that during the 18 years she has been the wife of the said Shigley, she has from him thirteen children all of whom have died in childhood except five who are now with your Oratrix, viz. Mary Jane, age 16 years; Barbara E., aged 12 years; Hester A., 5 years; Deborah A., 3 years and George W., aged one year.

These five helpless children are dependent upon your Oratrix for sustenance, and like her are abandoned by this cruel and unnatural husband and father.  Your Oratrix further shows unto your Honor, that the time she was married to said Shigley, neither she nor he was possessed of much property.  That at the time said Shigley left aforesaid he was the owner of 93 acres of land in Tippecanoe County and of some personal property and money; that he took with him his horse and buggy loaded with his possessions and all the money he could raise.  That she believes there are some debts due and owing against the said Shigley.  That she fears he will sell and dispose of all his property and thereby bring your Oratrix and her children to great want.

In consideration of this state of facts your Oratrix says that the bonds of matrimony now existing between your Oratrix and said defendant be declared dissolved.  That she be permitted to have the care and custody of her said children who she tenderly loves and that to enable her to support them she be permitted to enjoy the personal property now in her possession and that she may have a decree for alimony against the said defendant, in such case as to your Honor may deem proper, and for such other and further belief as Equity and good conscience may require.

Rachel Shigley
By Chafin & O'Brian

Solicitors

The State of Indiana
Tippecanoe County

Do personally appear before Mark Jones, Clerk of the Circuit Court in said county, Nathan Webb, who being duly sworn says he is disinterested in the above case and Adam P Shigley the within named defendant is not a resident of the state of Indiana as he is informed and verily believes.

Nathan Webb

Subscribed and sworn before
Me this 13th day of Jan 1852
Mark Jones, Clerk
By Fed W. Cole, Deputy
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Newspaper Notice

THE STATE OF INDIANA
Tippecanoe County
Tippecanoe Circuit Court, To February Term A. D. 1852

Rachel Shigley}
         vs.            Bill for Divorce
Adam P. Shigley}

BE it remembered that on the thirteenth day of February, in the year of our Lord, one thousand eight hundred and fifty-two and petitioner, by Chapin & O'Brian her solicitors filed in the office of the Clerk of the Tippecanoe
Circuit court, her petition in this behalf and also the affidavit of a disinterested and competent person that the said defendant is a nonresident of the State of Indiana.  He is therefore hereby notified of the filing of said petition and pendency of this suit, and that unless he personally be and appear before the Judge of our Tippecanoe Circuit Court on the first day of the next term thereof, to be holden at the Court House in the town of Lafayette, in said county on the third Monday in February next, and then and there on or before the calling of said cause, plead, answer or demur to the petition in this behalf, the matters and things therein charged and stated will be taken as confessed and true, and will be heard and determined in his absence and decreed accordingly.

Witness Mark Jones, Clerk of our said Tippecanoe Circuit Court and the seal thereof affixed at office in Lafayette, on this 13th day of January, A. D.
1852.

MARK JONES, Clerk,
By F. W. Cole, Dept. w&w
 
The State of Indiana
Tippecanoe County SS
Tippecanoe Circuit Court, February
17th A. D. 1852

     Personally appeared before me Mark Jones, Clerk of said Court William R. Ellis, Who being duly sworn according to law upon his oath says that the annexed notice was published in the Lafayette weekly Courier a paper of general circulation in said county for three weeks successively to wit on the 14th, 21st and 28th days of January A. D. 1852.
     And that he is the Editor of said paper.

W. R. Ellis

Subscribed and sworn to before me this 17th day of February A. D. 1852

Mark R. Jones, Clerk

Submitted by Marie C. Waters