Territory of Washington County of Walla Walla
In District Court First Judicial District
In the matter of the application of J. H. Sheffler & Josephine Sheffler for Writ of Habease Corpus} Reply to answer & Return
J H Sheffler & Josephine Sheffler for reply to the answer and return of John B Montague
1. Deny that for several months prior to the execution of said agreement or for any length of time Josephine Sheffler or any other person voluntarily or at all let said Defendant have said child or placed the same in the family of Defendant to be by him or his wife kept or raised or educated or that said child was sick or required nursing or medical aid
2. Admit that at the
time of execution of agreement
Defendant Montague kept a
saloon and that the same was
known to Josephine Sheffler
but denies that Defendants
family lived in the Saloon
at the time of the execution of
said instrument or that
J. H Sheffler or Josephine Sheffler
knew or believed that it was
the intention of Defendant
Montague to live with his
family in a saloon or that
he would keep said child
in or about a saloon
and over that the class
character and kind of saloon
kept by said Montague
at the time of the execution
of said agreement has been
changed by said Montague
3. Denies that said
Montague has treated said child
as his he would his own child
and aver that said child
has been illtreated and abused
by said Montague & wife
4 Denies that said Montague or his wife have become strongly or affectionatly attached to said child or that a like attachment exists with said child for Montague or his wife or such as a child has for its own parents
Wherefore J H Sheffler and Josephine Sheffler pray that said child be ordered into their custody & for costs
A E Isham N. T. Catan atys for Sheffler & wife
