...denies that in or about the month of March A.D. 1860, or any other time, at the County of Humbolt in this state, or at any other county, or at any other place, this defendant committed adultery with one Maria Mize or with any other person.
This defendant denies that in consequence of dissolute or intemperate habit he is not a suitable or proper person to have the care custody or control of the said children name in said complaint.
This defendant alleges that from the month of December, A.D. 1861, the time when the Plaintiff alleges she had Knowledge of the commission of the alleged adultery, that the said plaintiff co-habited with the defendant until the 22nd day of April, A.D. 1862.
This defendant for further defence to this action alleges, his habits are not dissolute or intemperate, but that, on the contrary, his conduct and habits are chaste and moral, and that he is a fit and proper person to have the care custody and control of said children.
Wherefore this defendant prays that he may have judgement in his favor and against the said plaintiff.

<Signed> Chas. P. Wilkins

Attorney for Defendant

Certification signed by W. A. Barnes that the information which he has stated is true, dated 12 Apr 1863.

Acknowledged receipt by the plaintiff's attorney. Filed April 11, 1863.