Territory of Washington
County of Walla Walla SS
The District Court
1st Judicial District
At Chambers before Hon
J. K. Kennedy Judge
Habeas Corpus
Charles Gahres & Martha J. Gahres Plffs
vs
Isabella Sutton & W. H. Barrett Defts
answer
Defts for answer to the complaint herein filed and return to the writ in said cause issued says that they have the child in said writ described now in court.
1 Defts say as they are informed and believe that said Plffs are not the parents of said Etta Dora Cravens and
2 deny that said Plffs are the lawful guardians of said minor etta Dora Cravens.
3 Defts deny that
they or either of them wrongfully or unlawfully detain or restrain said Etta Dora Cravens of her liberty at the court of Wallula County of WallaWalla Territory of Washington or elsewhere
4 Defendants aver that said minor child has been in the posession of said defendants for about three years and now that the said child has been sickly that said defendants have been at great expense and trouble in the rearing so far of said child that they have taken great care pain and trouble with said child and have watched over the same and have become greatly attached thereto
5 That the mother of said child Martha J Cravens had no home and no
means of procuring one and did not posess the ability to take care of and provide for said child and expressing great hate and disgust for the father of said child and desirous of removing from her gaze. the child that would constantly remind her of one so hateful to her and also expressing hate for the child besought these defts to take and rear said Etta Dora Cravens promising and agreeing to leave said child in the quiet possession of these Defts if they would agree so to do. Defts aver that they did on the day of August AD 1868 take said child from its mother Martha J Cravens under said arrangement and have kept and provided for the same ever since defts aver that the disposition manifested toward
said child by its mother aforesaid renders her an improper person to have control of said child
6 Defts aver that said Plffs are residents of the state of Oregon and have it in contemplation and threaten to take the said minor child Etta Dora Cravens out of and beyond the jurisdiction of this court
7 Defts aver that they are proper persons to have the care control and custody of said child that they have no children of their own that they are willing able and anxious to keep and take care of rear and educate said child
Wherefore Defts ask that said petition of Plffs be dismissed and the
prayer thereof be denied and that said child be remanded to the custody of these Defts and for costs
W. A. George & N. T. Catin attys for defts
