- NOTE: her attorney's are Park and Carpenter
- married 25 MAR 1896
- living together until 20 AUG 1906
- 5 children: Guy Martin, George Martin, Hazel Martin, Edward Martin, Jessie Martin
- all children reside with him and he refuses to deliver them to her
- starting 5 years ago he began cruel treatment
- neglect, and has frequently called her names, and swore calling her a "God damned fool".
- stating many times that he wanted to be free of her . . .
- failure to support so that she had to work
- he addicted to liquor and drank his earnings thru most of the marriage
- in summer of 1906 threatened to strike her . . .
- in May 1906 did strike her in the face breaking her teeth
- on 5 JUL 1906 accosted her in bed at her sister's and injured her severely
- 29 SEP 1906: He did not answer the summons and defaulted
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