To the Honorable Broomfield L. Ridley, Judge of 3^rd Chancery Division of the State of Tennessee, presiding at Gainesboro. The Bill of complaint of JANE WITCHER, a citizen of Jackson County Tennessee against WILLIAM WITCHER a citizen of said county and state.

Humbly complaining, your oratrix would respectfully represent to your honor that about the 30^th day of May 1859 she and defendant WILLIAM WITCHER intermarried, that she promised herself a life of conjeigal felicity and happiness with her said husband, but to her utter disappointment, very soon after she was married to defendant she found that she was very mistaken in the kind of man which she had chosen for her beloved companion. For instead of her said husband being kind and affectionate to her as a husband should be, he commenced immediately such a course of cruel and inhuman treatment to your oratrix as to render it unsafe and improper for her to live and cohabit with or be under his dominion and control. In fact, he has even threatened to take the life of your oratrix, which she fears he will do if she is forced to live with him and be under his dominion and control. She states that the next day after they were married the defendant went off to where there was whiskey and got drunk and returned home and commenced abusing your oratrix in an insufferable manner by cursing her in the most abusive manner and threatening to whip your oratrix with a limb, that he accused her of acts of adultery that he said to her "{explitive} her. He could see hell working in her back bone and that the blue blazes of hell were working in her temples," and divers other abusive and slanderous words did use and heap upon your oratrix.

Your oratrix here states that the defendant had no property or effects at the time of their intermarriage except his clothing. She states that she had at the time of their marriage the following property: (Viz) 1 mule, 3 beds and furniture, 1 cow, 5 head of hogs, 8 head of sheep, 10 chairs, 1 ox cart, 3 plows, and 1 pair of gearing, some pot vessels and some other household and kitchen furniture and a growing crop of corn and wheat, garden stuff, etc, all of which property she states she either acquired from the estate of her former deceased husband JAMES HUFHINES or by her own industry. Your oratrix here states that the defendant is threatening to make way with her said property, which she fears he will do unless prevented by the interference of your Honorable Court. She states that she had 5 children, the eldest 12 years old and the youngest about 3 years old, all issue of her and her said former deceased husband. She states that the oldest child as above stated is 12 years old, a girl. So your oratrix states that such conduct of said defendant as above stated is highly improper to be had before these children or anyone else, that he is not the proper person to have said children under his control. The premises considered, may it please your honor to cause said WILLIAM WITCHER to be made defendant to this bill. Let him full, true and perfect answers make to all and singular the allegations in this bill contained on his oath. Let units of attachment issue to attach said property. Let the same be secured for her benefit as may seem right to your honor. Let defendant be enjoined from in anyway interfering with her or her property or the children. Let copy proceed and show issue and a final hearing grant that she be divorced from him the said WILLIAM WITCHER and restore to all the rights of a single woman again, and that said property be settled and her forever be released from the bonds of matrimony , and that her name be changed back to HUFHINES, and to grant to her all such other and general relief as she may be entitled to according to rights and good conscience. This is the first application for injunction in this cause.

Whereas JANE WITCHER has filed in our honorable court of chancery at Gainesboro her bill of complaint against WILLIAM WITCHER praying for relief in the premise and for an attachment to issue and which is granted ivan(?). Therefore you are hereby commanded to attach the following property and where so attached, deliver the same over to complainant: 1 mule, 3 beds and furniture, 1 cow, 5 head of hogs, 8 head of sheep, 1 table, 10 chairs, 1 ox cart, 3 plows, and one pair gears, all the pot vessels in complaint purposed, and all household and kitchen furniture.