THE BILL OF COMPLAINT OF SARAH JANE HUFHINES AGAINST DANIEL HUFHINES, both of Jackson Co. TN.
12 Aug. 1872.
. . . she and the defendant intermarried with each other in Jackson Co. TN many years ago, about the year 1845 and lived together enjoying a reasonable degree of happiness for several years. They have continuously resided in Jackson Co. TN from the time of their said marriage to the present and have raised a family of eleven children, or partly raised them. Five of said children are of lawful age and married, the balance, to wit, Daniel F., Jessee J., Demorsa Angeline, Alexander, Sydney S., Thomas E., Nancy E., Almedia & Miles J. Hufhines, aged respectively in the order of their names above, 20 - 18 - 16 - 14 - 12 - 10 - 5 - 3 & 8 years, being minors and residing with complainant.
Summary: about four years ago, defendant accused complainant of adultery with almost every man in the neighborhood, then abandoned her for a few days. He returned and continued to live with complainant until June 1871 when he again abandoned complainant and they have not lived together since. Since then, he has refused to provide any support for her or the children. She accuses her husband of adultery with "divers wicked, lewd and base women, to wit, one Jane Braswell, one Sibby Cowan and Hannah Cowan." -bp.
Complainant further charges that she and defendant are possessed of the following property situated in Jackson Co. TN, to wit, about 2/3 of an acre of land in Civil District No. 3 on Wartrace creek and the mill thereon or 1/3 of said mill, being the same that is owned by the defendant and J. W. Carver jointly.
She asks for divorce, custody of the children and all real and personal property. -bp.
16 Sept. 1872.
Custody of the children is to be with complainant, all property is to go to complainant. Court costs are to be paid by defendant, enough property is to be sold to pay the lawyer. -bp.