Front of Count Packet:

807
Prince vs. Prince ) Bill
Filed Dec. 21st 1835
Geo. F. Hatcher ck
April 1836 cont.
Oct. cont.
April 1837 cont.
July cont.
Oct. cont.

LAWRENCE COUNTY (?) CIRCUIT COURT

To the honorable Judge of the Lawrence circuit court in chancery now sitting your oratrix Rachel Prince humbly complaining (?) unto your honor that about twenty-five years ago she inter-married with one William Prince her present husband, in the county of Russell, state of Virginia. That they resided many years after their marriage in said county and state and finally about seven or eight years ago they removed to this state and settled in the county of Lawrence. That ever since her marriage with the said Wm. Prince who she prays may be made a defendant to this bill she has conducted herself toward him as a prudent, dutiful and affectionate wife should do until the defendant by his abusive and cruel conduct towards her made it necessary for her to protect herself and then she only resisted his illnatured command and abuse so far as was necessary to her safety and protection.

That about six or seven years ago he finally abandoned your oratrix and took up with one Arty Mullens with whom he lives in open acts of adultery and by whom he had two children. She would further represent that the defendant has left her she has purchased and procured about one hundred and twentyfive acres of land and cleared about fifteen acres upon which she settled with eight children and so soon as she was enabled to live from from want and by her and her children's industry able to support themselves the defendant came upon the land with his said woman and built a house thereon and in which he openly lives with said woman as his wife within three hundred yards of the house of your oratrix. That he has assumed authority over and taken possession of your oratrix's farm and stock which stock amounted to about twenty head of hogs, and three head of cattle, and appropriates them to his own and his woman's use. He has also taken from her her only earthly comfort and support in her old age and adversity (her children) and has taken them to the house in which he and his woman lives and placed them under her tuition and (?) (?). He has also advertised to the world not to trade with or credit your oratrix on any account thereby cutting her out of all means of support but the protecting arm of your honorable court and the law.

She charges that the title to said land is in the commonwealth your oratrix having (?) the land under treasury warrants of the State of Kentucky and that the defendant has been endeavoring to get the patents issued in his name. The the patents are by contracts of your oratrix to issue in the names James and John Prince the sons of your oratrix and who lived with and assisted your oratrix until the defendant forced them from her. That patent for one hundred acres is to issue to said James Prince and twenty five to said John Prince the sons of your oratrix.

All which outings and doing are contrary to equity and the statute in such case made and provided tends to the impoverishment of your oratrix. She prays therefore that your honor would deem that she be divorced from her said husband, Wm. Prince, and that all persons be restrained from issuing a patent to said Wm. Prince or to any person or persons but the above named James and John Prince her said sons and that the said Wm. Prince be restrained and enjoined from any further control of the said farm and stock and from any further interference with your oratrix until the matter and things can be heard by your honor in your honorable court. And then upon due proof of the several allegations in this bill desire that the said farm be and the said stock be at the disposal of your oratrix for her alimony and maintenance and her childrens maintenance and education and desire that the patents issued as above stated.

Prays that defendant make true and perfect answers to this bill grant (?) (?) and such other and further relief as to equity belongs. Your oratrix in duty bound will ever pray.

(???????????)
Before the subscriber one of the commonwealth Justices of the peace in and for the county of Lawrence personally appeared Rachel Prince and made oath that the matter and things set forth in her above bill are true so far as they came to her by her own knowledge and so far as she has then given information of other she believes to be true. Given under my hand this 16th day of December 1835.

(???????????)
We the undersigned Justices of the peace in and for the county of Lawrence appointed for the circuit court of said county to grant injunction and (?) having been presented with the above bill and having read the same do grant the injunction as made (?) therein and the clerk is hereby commanded to issue (?) and injunction pursurant to the prayers of said bill. Given under our hands this 21st day of Dec. 1835.

Lewis Ningles (???)

Joseph Davidson (???)

Front of Count Packet:

807
Prince vs. Prince ) Bill

Filed Dec. 21st 1835
Geo. F. Hatcher ck
April 1836 cont.
Oct. cont.
April 1837 cont.
July cont.
Oct. cont.

tas paid
Moseby

Front of Court Packet:

Rachel Prince vs. Wm. Prince ) spa in Chancery

To April 1836
Executed April 6th 1836
Jacob Rice (???)
John Stafford (???)


Moseby pg.

Summons for William Prince:
The commonwealth of Kentucky to the the sheriff of Lawrence County greeting. We command you that you summons William Prince to appear before the judge of our Lawrence Circuit County at the courthouse in Louisa on the 1st day our April Term next to answer a bill in Chancery in our said court exhibited by rachel Prince for a Divorce and have then there this writ. Witness Geo. F. Hatcher, Clerk of our said Court at the Courthouse this 4th day of January 1836 and in the 44th year of the commonwealth.

Geo. F. Hatcher, Ck.
Return to Resources Page