In the matter of the application of Alice McKay for a Writ of Habeas Corpus } Petition
To the Hon. Roger S. Greene Judge of the District Court of the 3d Judicial District of Washington Territory. Holding terms at Seattle for the Counties of King and Kitsap.
The petition of Alice McKay respectfully shows:
That one Mary McKay aged about five and a half years, daughter of petitioner is unlawfully restrained of her liberty ^and from petitioner at the City of Seattle in King County, Territory of Washington by one John Kevans and his wife Mrs. Kevans whose given name is to petitioner unknown.
2 That according to the best of petitioners knowledge and belief, the cause or pretense of the said restraint of said child Mary McKay, is that the said Kevans and his said wife claim that the said child was given to them by the Sisters of the Holy Name
with whom your petitioner about eighteen months ago left said child to be cared for, while she (your petitioner) was very sick and while the child also was very sick
That when said child became well the said sisters as this petitioner verily believes gave said child to said Kevans and his said wife, but that in truth and in fact your petitioner never gave said child to the Sisters or to any other person, but merely left her with the aid sisters to be cared for during the sickness of said child and petitioner — that said your petitioner has frequently demanded the said child but the said Kevans and his said wife refuse to allow petitioner to have said child, or to allow her to visit the same, and they have threatened to shoot your petitioner if she (petitioner) attempts to come in said Kevans house to see her said child — That said Kevans and his said wife do not want the said child and
to that end teach said child not to remember or to know the said childs own mother, your petitioner. That petitioner is informed and believes and so avers the truth to be that said Kevans and his said wife unlawfully and cruelly bed, abuse, and otherwise ill treat your petitioner's said child, the said Mary McKay —
3. That the said confinement and restraint are illegal and that the illegality thereof consists in this to wit: The said child is the ^ legitimate[?] daughter of this petitioner by her husband Archie McKay; and that neither she and her said husband, or either of them ever gave or abandoned said Mary to the said Sisters nor to any other person or persons whatsoever
Wherefore your petitioner prays that a writ of Habeas Corpus may be granted derected to the said Kevans and his said wife commanding them to have the body of the said child Mary McKay before your honor at a time and place
therein to be specified to do and receive what shall them and there be considered by your Honor concerning her together with the time and cause of her restraint and said writ; and that she may be restored to her liberty and to petitioner, and your petitioner will ever pray—
Dated Seattle W. T. Jan. 19. 1884
Alice McKay
