Catharine L Martin
v
Jesse Martin Jr } Application for writ of habeas corpus
To the Honble Judge Wyche Judge of the 2d Judicial District
The complaint of your petitioner respectfully shows that Catharine L Martin the complainent is the wife of the defendant and the Mother of two Children named Martha M Martin and George O. Martin cause aged respectively three years and the other 18 months years the issue of the marriage with him
That said defendant by his failure to make provision for his family, and his utter inattention to the in necessities and wants has made it impossible for the complainant to live and cohabit with the defendant. That complainant is residing with her father in the county of Thurston in this Territory and has had the care and custody of the said minor children
That the defendant is floating from place to place and claiming to reside in the State of Oregon, from whence he came recently, that on his arrival in this Territory he close destinly sought an opportunity in the temporary absence of complainant and obtained the possession of Mary M. Martin one of the said minor children, complainant avers that the defendant is not a fit or competent person to have the care, custody and control of said minor child. She therefore prays that a writ of Habeas Corpus may issue directed to the said Jesse Martin Jr the defendant, commanding him to produce before your Honor the said Minor child, forthwith, or at such time as given Now may direct Either at Chambers or at the Ensuing term of the U States Dist Court to be held in Olympia, that the right to the care & custody of the said minor child, as well as the care and custody of the minor child now in possession of the complainant may be determined And as Serious apprehensions are entertained that the defendant may remove the minor child in his possession as well as the one which she now has beyond the Jurisdiction of of your Honor and outside of the limits of the Territory of Washington. She therefore prays that the defendant may be restrained from carrying beyond the jurisdiction of the Court either of the said minor children untill the right to the care of them can be determined.
AS Manter for Catharine L Martin
