In the Third Judicial District of Washington Territory holding terms at Seattle.
In the matter of the application of Mary Le Febvre for a writ of Habeas Corpus.}
To the Hon. R. A. Jones Judge of the above entitled Court. The petition of Mary Le Febrve shows.
I
That she is the wife T. LeFebvre they having been married in the year 1884.
II
That they have a minor child. a boy named Henry Luke LeFebvre now aged three years.
III
That an action is now pending in the District Court of this Territory holding terms at Ellensburg, between your petitioner as plaintiff and her husband T. LeFebvre as defendant in which your petitioner seeks to attain a decree dissolving the bonds of matrimony existing between her and her said husband on the grounds of the neglect and refusal of her
2 said husband to make suitable provisions for his family and on the further ground of cruel treatment by her said husband of your petitioner. And petitioner in said action further asks that the care and custody of said minor child be awarded to her on the ground that her said husband is not a proper person to have the care and custody of said child.
IV
That for a long time prior to the commencment of said action your petitioner had by her own labors supported herself and said child and that after the commencement of said action petitioner continued to so support herself and child.
V
That after the commencement of said
action and about six weeks ago said T. LeFebvre came to the
restuarant in Ellensburg where petitioner
was working and forcibly by force
took said minor child from the custody
of petitioner and since then has been traveling about the country
with said minor child and said
T. LeFebvre now has said child concealed
3 and confined in some place to petitioner unknown, in the city of Seattle
VI
That said T. Le Febvre is unable to properly care for said child - and has since so taking said child neglected him, and said child by reason of said neglect has contracted disease - and is now as petitioner is informed - sick and greatly in need of a mothers care.- That said T. LeFebvre refuses to inform petitioner where said child is confined and concealed and refuses to allow petitioner to see said child
VII
That said T. LeFebvre is a man of violent and ungovernable[?] temper and is shiftless and improvident - and is not a proper person to have the custody of said child.
VIII
That petitioner believes that said T. LeFebvre so conceals and confines said child as a means of inducing petitioner to dismiss her said action for divorce
Wherefore your petitioner prays a writ of habeas corpus to deliver said Henry Luke LeFebvre from the
custody of said T. LeFebvre - and that he be restored to the custody of petitioner
Mary LeFebvre
