...William A. Barnes, the above named defendant, being duly sworn, on oath, deposes and says, That judgment was entered up in the above entitled action in which Ruth Barnes is plaintiff and this affiant is dependant, in form of said plaintiff and against this defendant on the 24th day of October, A. D. 1862, on service of the summons herein by publication, and not in personal service of this defendant. That this action is brought by the plaintiff to obtain a decree of said Court that the plaintiff he? divorced from this affiant and to her the care, custody and control of the children of the plaintiff and affiant. That he, the defendant, never received any copy of the summons and complaint in this action, and was wholly ignorant of, and never had notice of such judgment so entered as aforesaid, until the 27th day of March, A.D. 1863 when he was first informed there of at Santa Rosa by Chas. P. Wilkins, to wit: within six months now last part after the rendition of the final judgment. That this defendant has crossed out material fully and fairly states his case in the above cause to Charles P. Wilkins, his counsel, who resides in Santa Rosa, in the County of Sonoma, and that the defendant has a good and substantial defense, on the merits, to the whole of the plaintiffs allegations on which this action is brought, as he is advised by his said counsel and ? believing to be true --

<Signed> W. A. Barnes

Sworn to and subscribed before

me this 9th day of April 1863

<Signed> Wm. A. Crowell Dep. Clerk