Ruth Barnes xxxxxxxxxxxxxxxState of California
Plaintiff xxxxxxxxxxxxxxxxxx County of Sonoma
xx vs xxxxxxxxxxxxxxxxxxxxxxxIn the District
William A. Barnes xxxxxxxxCourt of the Seventh
Defendant xxxxxxxxxxxxxxxxx Judicial District

The complain of the above named Plaintiff respectfully shown to this Court. That she is a resident of the County of Sonoma and State of California, that she has resided in this State for more than six months next immediately before the commencement of this suit. That she is the wife of said Defendant, that she was lawfully married To said Defendant in the County aforesaid in the year 1857. That she Plaintiff has two children, the fruit of her marriage with said Defendant to wit Frances aged about three years, and Richard aged about one mont and two weeks both of which said children are in the possession and under the control of Plaintiff.

The Plaintiff further shows to the Court that, according to the best of her Knowledge, information and belief, the said Defendant in or about the month of March A.D. 1860 at the County of Humbolt in this State committed adultery with one Maria Mize material crossed out here and more or less unreadable but the Plaintiff ? that she had no Knowledge of the said commission of the said adultery by the defendant until about the month of December AD 1861 since which time she has not cohabited with said Defendant.

And the Plaintiff ? said Defendant in consequence of dissolute and intemperate habits, is not a suitable or proper person to have the care, custody or control of her, Plaintiff's said children.

When the Plaintiff prays a Judgment and ? decree of This Court annulling, setting ? and forever dissolving this marriage contract existing between them said Plaintiff and the Defendant, and that she, Plaintiff, may have a divorce from the bed and board of, and from the bonds of matrimony existing between Plaintiff and Defendant, and this she may be allowed to have the possession, care, custody and control of her said children or that Plaintiff may have further relief, or both in the premises that may be just.

W. Ross Attorney for
Plaintiff

Certified by Wm L. Anderson, Clerk, and Wm. H. Cromell, Dep. Clerk, 3 May 1862.