THE CIRCUIT COURT OF

BAITIMORB CITY.

A

LUCILLE MASSEY

VS.

HEBRY MASSEY

1Mr.Clerk:-

file.

\—yA*j-~<^?i«0R

DAVIS & EVANS

BAUMSARTtN a CO.. I

LUCILLE MASSEY : IU THE CIRCUIT COURT

VS. : OP

HEIRY MASSEY : BALTIMORE CIIY

TO THE HONORABLE,THE JUDGE OP SAID COURT:

Your Oratrix complaining respeotfully says:

I* That she entered Jnto a marriage ceremony with the

above defendant on the 4th day of July,1926 in Baltimore City,

State of Maryland, end with whom she lived as husbend end wife

until the I2th day of July,1926 when your Oretrix discovered

that the defendant had a prior marriage undisolved.

2. Thet since the discovery of the fraud end deceit

practiced upon your Oretriy she has not lived nor cohabited

with the said defendant and has in no wise condoned the offense.

3. That both your Oretrix and the defendant are residents

of Baltimore City, State of Maryland, and have been for more

than two years prior to the filing of this Bill of Complaint.

4. That your Oratrix is destitute and without-meenfl of

financing the expenses of this suit and that she is advised by

Counsel that she is entitled to have an order passed by this

Honorable Court awarding some amount as alimony pending this

suit and some certain emo Jnt to compensate her Solicitors.

The defendant is employed and earns about thirty-five dollars

per weei»

WHEREFORE YOUR ORATRIX PRAYS:

(a) . That the marriage of the parties hereto be declared

nul and void*

(b) That she may resume her maiden name "MILLER".

(o) That she may have such other and further relief es

her case may require.

it please your Honor to grant unto your Oretrix

the Writ of Subpoena directed unto the defendant, commanding

and requiring him to be and appear in this Court on some dey

certain to he named therein to^anBwisrr.therpBemiBee-ranS abide by

and perform such decree or order ®s may be passed thsrein.

AND as in duty bound,etc

SOLICITORS FOR PLAINTIFF.

Ct. Ct.B-319

192 Docket No.

Lucille Massey

V8.

Henry teassey

SUBPOENA TO ANSWER BILL OF COMPLAINT

No. B-30877

"t U)

SOUCITOR

Form 18—5M

EQUITY SUBPOENA

The State of Maryland®o HENRY MS.SSEY

10E7 S. Sharp S t r e e t ,

of Baltimore City, Greeting:WE COMMAND AND ENJOIN YOU, That all excuses set aside, you do within the time limited

by law, beginning on the second Monday of AUgUSu n e x t

cause an appearance to be entered for you and your answer to be filed to the complaint of

LUCILLE laSSEY

against you exhibited in the Circuit Court of Baltimore City,

HEREOF fail not, as you will answer the contrary at your peril.

WITNESS, the Honorable JAMES'P. GORTER, Chief Judge of the Supreme Bench of "Baltimore

City, the day of ?' 192 6 #

Issued the 22nd day of JU-ly9 , in the year 192 6 ,

Clerk

MEMORANDUM: You are required to file your answer or other defense in the Clerk's Office, room 206,in the Court House, Baltimore City, within fifteen days after return day.

(General Equity Rules 11)

B Docket

CIRCUIT COURT.

vs.

Order for AlimonyPendente lite

ORDER

BNo.

Fd:

IN THE

CIRCUIT COURTOF

BALTIMORE CITY

ORDERED BY^THE COURT this

that the defendant

pay to the plaintiff!

the sum of

Dollars per weefy during the continuance of this suit, accounting from the

day of ^CAA/H 192 fc? to the said plaintiff,

as alimony^endewte live, unless cause to the contrary be shown on or before the

TERM, 192

192

a^^^Y

192 c? provided a copy of this Order be served on the said defendant

Sfon or before the

day of

TRUE COPY—TEST:

CLERK

i 7 -/ 7 A

CIRCUIT COUR

19 Docket No

vs.

ORDER OF APPEARANCE

IN THE

Circuit CourtOF

BALTIMORE CITY

Mr. WHITEFORD, Clerk.

Enter my appearance lor Defendant

_L

I Tnc. /-I-H- THiS -CIRCUIT COUKT OF

BALTIMORE 01'.

LUCILLi; MS.SSEY"

V S .

HiDUHY

AITSWEH

Mr. C l e r kPlease file

Charles Coffin Pitts Jisq.905 Pennsylvania Ave.

Baltimore, Md.

• " : - " * -••••

LUCILLE MASSEY

VS.

HENRY MASSEY

IN THE CIRCUIT COURT

BALTIMORE CITY.

DEFENDANTS ANSWER

And now comes the Defendant in the above e n t i t l e d

complaint and moves that sa id complaint "be dismisssed for th-

with for the reason that the sa id Defendant i s not the

le^a l husband of the P l a i n t i f f according to the Exhibi t s

here to annexed, marked Exhibi ts "A" and WB°, and according

to the Codes in such case made and provided.

Henry G. Mfrssey

By his Solicitor

Form 406-8 aof

City of Baltimore, Set.

TO ALL WHOM IT DOTH OR MAY CONCERN:

UlljiH IB to (Efrtifu That on the _«_? ..7^..Z...... day of

in the year one thousand //(adAA?. hundred andQi^(^T5f^w__7^2<^C-a Marriage License was

issued from the office of the Clerk of the Court of Common Pleas, authorizing any Minister of the Gospel,

or any other person qualified by law, to perform the Rites of Marriage between a certain

Acre 2 ^ / _ Color

*J&.And afterwards, to wit: on the /.. day of.

the year one thousancKTv^CvwC-... hundred an<C-^

filed in the Clerk's Office of said Court, to wit:

I HEREBY CERTIFY, That on this .._£ day ofsi*

one thousand ...t^/Z^/14_<%^. hundred and

. in

he following certificate was

were by me united in Marriage, in accordance with the License issued by the Clerk of the Court of

Common Pleas for Baltimore City in the State of Maryland.

Minister of the Gospel, Official Character

As it appears by the Record of Marriages in the Clerk's Office of the Court of Common Pleas which

Record is now in my custody and keeping.

IN TESTIMONY WHEREOF, I have hereunto set my hand and

affixed the seal of the Court of Common Pleas, this

day of .^y.^Q^Z.^: 19

"A"

MARRIAGE LICENSEAFFIDAVITS TO OBTAIN LICENSE

STATE OF SOUTH CAROLINA

County of York

I do solemnly swear that I am legally capacitated to marry, that my full name is

Henry. .G... .Masaey ; that my age is.. — 27.

months; my place of residence is Fo .r t . -Mi-ll-,. • S . C •

.GOl. ; my nationality is. . . AfXQ. .AmerA c a n

SWORN to before me this #SQ"ph

of .June A. D. i9i.7.

. . . .years and

. .; my race is |

day Henry G. Massey....&... Williams.,Probate Judge [Ll s -j

STATE OF SOUTH CAROLINA

County of York

I do solemnly swear that I am legally capacitated to marry, that my full name is.

R.Q Sa . ParlC e r ; that my age is ??-. years and

months; my place of residence is. . . .FOr.W. .~ i . l l . , . . P.* y.#. ; my race is

GOl. ; my nationality is Af r.O. . Ame.ri.Can

SWORN to before me this EV.til

day of June , A. D. igi.7.. ... Rosa Parker ... /J....H,.Wil l lama,

Probate . .Judge [L. s.j

of jioutfy (UarolmaCOUNTY OF YORK

WHEREAS, It has been made to appear to me, J. L. HOUSTON, Judge of Probate

for York County, upon oath that___H,enry__G_.__Maa§:_ey

F o r t M i l l S. C. , Rosa P a r k e rof i ana

of ??^._____r--*.--.-—--'- are legally capacitated to contract matrimony,

27and that their ages are respectively years and months

and A l years and months; and that their race is C-9.±J

and their nationality is Afro_ Arae_ric_a_n_

These are, therefore, to authorize any person qualified to perform marriage cere-monies to perform the marriage ceremony for the persons above named, and for the sodoing this shall be sufficient warrant.

Given under my Hand and Seal this

A. D. 193JZ.

of June

Judge of Probate for York County.

No 3000 j

State of South Carolina •COUNTY OF YORK \

IN THE PROBATE COURT '

MARRIAGE LICENSE jTO ;

Henry. Gt. .Jfegg. y. jAND |

Rps a Parker :

OWEN G DUNN PRINTER NEW BERN N C ' *