Territory of Washington
Walla Walla County
In District Court for the First Judicial District of Washington Territory Before the Hon J.R. Lewis Judge At Chambers
Charles Gahres & Martha J Gahres Guardian of Ella Dora Cravens, a Minor- Plaintiffs
vs
W.H. Barret and Isabella Barret - Defendants
Plaintiffs complaining of Defendants for cause of action alleges:
1. That the above named Plaintiff Martha J Gahres (formally Martha J Carvens) is the mother of the said minor child Ella Dora Cravens by a previous marriage with one W.H. Cravens and that she is the natural and lawful guardian of the said minor child and entitled to the custody and control of the same[?]
2. That the said Martha J. Ghares formally Martha J. Cravens as aforesaid. Attained[?] a Judgement of divorce from her former husband
W. H. Cravens at a tern of the circuit court of the State of Oregon on the County of Union begun[?] and held on the first day of November AD 1866[?] in which this[?] the said court further ordered and decreed that the said Martha J Gahres then Martha J Cravens had[?] the custody and education of the girl Ella Dora Cravens
3. That with[?] said Divorce such the members thereby[?] and the said Ella Dora Cravens were within the Jurisdiction of the said court.
4. That since the said decree of divorce the Plaintiffs herein have been lawfully married and are now living together as husband and wife
5. That Plaintiffs have ample means for the Education of the said Ella Dora Cravens and that the Plaintiff Martha J Gahres the mother of the said minor child has ample means for that purpose in her own wealth
6. That the said Ella Dora Cravens is now seven years of age and [?] in the Plaintiff [?] the Education
has been wholly neglected.
7. That the said Ella Dora Cravens is wrongfully and unlawfully withheld from the custody of Plaintiff at Walluda in the County of Walla Walla and Teritory of Washington by Defendants W.H. Barret and Isabella Barret.
8. That the cause of the said alleged restraint and detention of the said minor child is the best of the knowledge and belief of Plaintiff is an alleged gift[?] of the said Ella Dora Cravens to Defendants Isabella Barret by the said Martha J Cravens now Martha J Gahres before the decree of divorce aforesaid from her former husband W.H. Cravens and this the illegality of the said restraint and detention [?] in [?] [?] said alleged gift [?] [?] without foundation and [?] a fiction of defendants.
Therefore Plaintiffs pray then a Writ of Habeas Corpus may issue directed to the Defendants W.H. Barret and Isabella
Barret commanding them to have the body of the said Ella Dora Cravens before the Hon Judge of this court at a time and place designated by said judge and then and there [?] and [?] what the said Hon Judge shall consider in the premises concerning[?] said minor child and that the [?] cause why the said minor child is withheld from the care and custody of Plaintiff and for Costs in this proceeding.
J. H. Lassater and T.J. Auden Attorneys for Plaintiffs
