In the matter of the application of Ray Raymond for a writ of Habeas Corpus
Territory of Washington County of Spokane} ss
To the Hon. George Turner, Judge of the District Court of the 4th Judicial District, holding terms at county dept of Spokane County, Wash Territory.
The petition of Ray Raymond made and certified for and on her behalf by her attorney Thomas C. Griffith, respectfully shows:
1. That the said Ray Raymond is unlawfully imprisoned, detained, confined and restrained of her liberty by E.F. Whittier, Sheriff and keeper of the jail of Spokane County, Wash. Territory at the County Jail of said County at and within the city of Cheney in said Spokane County, Territory aforesaid.
2. That the cause and pretense of said imprisonment, restraint, and restraint according to the best knowledge and belief of the applicant and affidavit herein is as follows:
Said Whittier restrained said Ray Raymond is prison as aforesaid by virtue of a certain warrant of commitment directed to city constable and to the keeper of the jail of Spokane County aforesaid from J.J.L. Peel and Jud. J. Booge, the Justice of the Peace of said Spokane County, dated July 2nd 1886, commanding him to to detain her without bail in the jail aforesaid on a charge of murder in the 1st degree – for killing one John W. Finch, at and within Spokane County Washington Territory, June 26, 1886, until discharged by due cause of law.
3. That such imprisonment and restraint of said Ray Raymond is wrongful and illegal in this.
a. Ray Raymond is not guilty of of the said charge in said warrant of commitment named, nor is the proof of ther guilt, thereof evident, nor the presumption great.
b. That no such crime as murder in 1st degree in the killing of said John W. Finch has been committed.
c. That said Ray Raymond
is entitled to bail on said
charge, and that does not thought
and bail is wrongfully denied
her thereon.
d. That the evidence addresed by the Territory of Washington against said Ray Raymond on said charge, fails to show that the crime of murder in the 1st degree in the killing of John W. Finch had been committed, rather the proof thereof was evident or the presumption thereof great, in that Ray Raymond had committed such crime of murder in the 1st degree but such evidence shows that a less offense had been committed if any and that she is entitled to bail on said charge.
The said Ray Raymond
is entitled to bail be admitted to bail
on the said charge, for which she is
so held and restrained by said
Whittier and bail thereon is
wrongfully and unlawfully
denied her, and she asks to
have the witnesses against
her examined and for the
purpose of admitting her
to bail thereon.
Ray Raymond is entitled to bail on said charge for the further reasons that she is and ever since June 26, 1886, has been subject to frequent fits of swooning and hysteria and she has been advised by her physician Dr. J. M. Morgan that further confinement in said jail will greatly endanger her life, and under her malady permanent and possibly reasulting[?] in insanity or death–
Dated July 5, 1886 Ray Raymond by Thomas C. Griffitts for and on behalf of Ray Raymond
Caton & Stanford Attys petitioner
