Territory of Washington
County of Walla Walla
In District Court
First Judicial District
In the matter of the application of J. H. Sheffler and Josehpine Sheffler for writ of Habease Corpus for Edna Elenor Edwards otherwise called Edna Elenor Montague a minor aged 8 years} Complaint Invocation
To the Hon Samuel G Winegard Judge of said Court
The petition and complaint of J. H. Sheffler and Josephine Sheffler showith to your Honor the following facts towit:
1. That Josephine Sheffler one of the complainant herein is the mother of Edna Elenor Edwards otherwise called Edna Elenor Montague an infant girl of the age of Eight years. the Fruits of the marriage of the said Josephine Sheffler with one Charles A. Edwards
2. That said Josephine
Sheffler was lawfully married to
J H. Sheffler the other complainant
herein and they are now husband
and wife and living together as such
3. That said Edna Elenor Edwards child of aforesaid of there complainants is illegally restrained of her liberty and prevented from returning to complainants her parents by one John B Montague at Walla Walla City Washington Territory
4. That the cause or pretense of such restraint as complainants believe said John B. Montague claims the said child as his own by virtue of a certain agreement of adoption entered into by and between himself and Josephine Sheffler one of there complainants on the 26th day of June 1875 a copy of which said agreement is hereto appended and made a part hereof
5. That said
restraint is illegal: that the
illigality consists in the following
1. That said John
B. Montague commited and
agreed in said agreement
to rear the said Edna Elenor Edwards
"in his family to educate her and to
morally and religously train her with
due parental care and regard"
and complainants allege that said
Montague has totally disregarded
the said covenant so essential
to the present and future well
being of said minor and has
kept her in and about a saloon
were all manner of vile language
is used and caused her and
is now causing her to associate
with the vile and as complainants
are informed with women of
ill fame
2. That the sole consideration of said agreement of adoption on the part of Josephine Sheffler mother of said infant and one of the complainants herein was the covenant promises and agreement of John B Montague as above enumerated all of which have been wholy violated rendering the said agreement null and void
Wherefore complainants
pray the Honorable Samuel G Winegard
Judge of said court for a writ of
Habeas Corpus commanding the
said John B Montague to provide
the body of said Edna Elenor
Edwards and that the matters
herein complained of being [?]
into and the said minor be
returned to her parents
A. E. Isham & N. T. Catan
Attys for Complainant
