In the Superior Court Sonoma County,
State of California --
Rachel A. Fulkerson, Plaintiff
vs.
John Fulkerson, Defendant.

The above name plaintiff, complaining of the above named defendant, for a cause of action alleges:

i.

That the plaintiff and defendant were intermarried at Santa Rosa on the 19th day of September, 1861, and are now husband and wife, both residing in the city of Santa Rosa, County of Sonoma, State of California.

ii.

That the plaintiff is now and has been an actual resident of the State of California for more than six months next before the commencement of this action, to wit: thirty-two years.

iii.

That the issue of said marriage is seven living children and the following names are minor children, to wit:--Luda V. Fulkerson, aged seventeen years; Charles A. Fulkerson, aged twelve years; Dace Fulkerson, aged six years; and Sylvester Fulkerson, aged three years.

iv.

That the plaintiff and defendant are now and have been living separate from each other and have not lived together as husband and wife for two months.

v.

That the said defendant did on or about the 18th day of April, 1889, at his farm about three miles east of Santa Rosa in the County of Sonoma, State of California, commit adultery by having voluntary sexual intercourse with one Sofia Nilson, and has at divers times and places since said 18th. day of April, 1889, committed adultery by having voluntary sexual intercourse with the said Sofia Nilson, the dates and particular places of which last named acts are to the plaintiff unknown. And on Thursday, August 22nd, 1889, at a house near the city of Sonoma in this County and State the said defendant did commit adultery by having voluntary sexual intercourse with the said Sofia Nilson; and on Thursday, August 29th, 1889, at the place last aforesaid the said defendant did commit adultery by having voluntary sexual intercourse with the said Sofia Nilson.

vi.

That plaintiff has not lived with said defendant as his wife since she discovered that he was guilty of any of the said acts of adultery, but has and does refuse to live with him for the reason of his said acts of adultery.

vii.

That the plaintiff has always been a faithful wife to the defendant. And the said minor children are now in her custody, and that she is a fit and proper person to have the care, custody and control of said minor children, but the said defendant is not a fit or proper person to have the care, custody and control of said minor children for the reason of his said acts of adultery aforesaid.

Whereby the plaintiff commands a judgment and decree of this court dissolving the bonds of matrimony now existing between the plaintiff and defendant: and for a divorce, and for the care, custody and control of said minor children and for such other and further relief as to this Court may seem just and equitable.

<Signed by> Jno. Brown,

att'y for Pl'ff.