In the District Court of the 3rd Judicial Districts of Washington Territory holding terms at Seattle in King County
In the matter of the application of Jennie Miller Powers for a writ of Habeas Corpus} Petition for writ
To the Hon. Robert A. Jones Chief Justice of Washington Territory and Judge of the 3rd Judicial District
The petition of Jennie Miller Powers respectfully shows
That she is the mother of Mary Alice Powers an infant child of the age of five years and is lawfully entitled to the possession thereof that said Mary Alice Powers is now in the keeping and possession of Mary Elizabeth Miller and J RJ Miller her husband and is unlawfully detained confined and restrained of her liberty and from the possession of your petitioner by said Mary Elizabeth Miller and her said husband J RJ Miller, in King County and Washington Territory
That said detention confinement and restraint are illegal and the illegality thereof consists in this towit: That heretofore on to wit the 6th day of April AD 1888 this Hon. Court ordered and adjudged a decree of divorce between your said petitioner and her husband John Powers and among others ordered adjudged and decreed that the said Jennie Miller Powers be awarded the care education and custody of the said minor child Mary Alice Powers
That on to wit the 7th day of April AD 1888 legal recourse[?] was made by your petitioner and the sheriff of said King County on said Mary Elizabeth Miller and J RJ Miller her husband exhibiting the said sheriff a certified copy of said divorce[?]
[?] that they deliver the said minor child to said Jennie Miller Powers but said Mary Elizabeth Miller and said J RJ Miller her husband have each and both of them refused and failed and still refuse to so do
Wherefore your petitioner prays that a writ of Habeas Corpus may be granted directed to the said Mary Elizabeth Miller and said J RJ Miller commanding them and each of them that them and each of them have the body of the said Mary Alice Powers before your Honor at a time and place therein to be specified to do and receive what shall then and there be considered by your Honor concerning the said Mary Alice Powers together with the time and cause of her detention and that she said Mary Alice Powers may be given and placed in the care custody and keeping of your petitioner
Mrs. Jennie Miller Powers
April 9 1888
