Show f sf min afi fri tg ya sul juuli jy umu luy liable A answer er or cf tb gue ghe nc 1 tn an the DI district court third ju duclai district op he 0 territory of bf utah 0 I 1 lake alij aar 1 euza Enza alzay youg au by her next Tri trl frid nii tid hii george eorge dorge taa faa I 1 I 1 plaintiff vs brigham young defend arit answer now com comes esthe the said defendant brigham young and for answer t to 0 tho the bill of complaint of tho the sal sai said sald d ann I 1 eliza ellza liza ilza vou xou you koun poun n plain tiff denies that on the I 1 ilay ot of april 1863 dt the tho t county oa 01 uty nty O of f salt L lake ake awe utah at any other time or laed place this defendant and the said plaintiff intermarried inter married or that since since that timoor time or at any time the said sald plaintiff has been or that she nbc is ia of this defendant int for this defendant on information and belief alleges 1 that before that time to td wit ph loh tiie tile loth day of april 1863 at salt lake lahe city utah Territory 1 tilo tho sa said sald id pl was married to one ono james L dee dec who wilo Is still living and that ever since owsald tenth lay day of april 1863 1861 the thus said plaintiff lias has been and on the said sixth day of april ua ya wa it and still 1 is 13 3 the lawful the said james jamea L De ime ike enever never as ast asi this thi defendant 19 ad and bellet beliet ebe efe alb ceh cen cen divorced flom nom the raid J james tames ame adie edle K dee but hib this his defendant further says bays say sav that m Of April 1868 and at it tito tho time timo of the ceremony hereinafter referred to he lle was informed and then verily believed that the plaintiff had prior to that time been legally divorced from flom t the he said james ti nee dee and the defendant fur further answering di legEs alleges that at the town of kirtland I 1 in n the bt ate of ohio on the tenth day of january A J D 1834 this defendant ban beins being then therl an unmarried led man was dui dul lawfully a marri edito mary ann Anu Angell by a minister or of tho tile gospel who was then and there by tiie tiiu laws lawi of said state authorized to solemnize marriages and that tile tiie said marriage was then and there fully consummated and that the said sald mary ann angell who chols is still living then and there became and ever eve ince has been and still Is i the lawful wife of this defendant all ali of which said hald facts fact the aut nut id complainant on the said sixth baylot april arll 1868 and for a long iong time prior thereto had full R knowledge now ledge and information but defendant ays that bo be and the said complainant were on the sixth day ony of april 1868 1658 of the said church of 3 jesus jesua of latter ratter day saints I 1 and abatie that it was a doctrine and belief of bald baid church that members thereof might rightfully euter enter into plural oi or celestial marriages and dan t ad mits wits that on tilo tile sixth day of april 1868 at salt LI lake laka city butali territory inae inne corda corrance cor dance ilce with and pursuant f to the tho said doctrine custom and belief of the tile sal sai said sald d church a ceremony was performed to unite the plaintiff and defendant in what is known kilow nas as such plural or br celestial marriage the said first viro wife vire of this defendant being then living and as plaintiff then and there ther well knew but defendant denies that on the said sixth day of A april pr or at any auy other time lie he and t the lie said plaintiff intermarried inter married in any other or different F ense sense or manner than that above admitted and set forth defendant further alleges that the said complainant was then informed by the tho defendant antaus and aud then and there well knew that by reason of said marri marriage age in in the manner mannex aforesaid she could not have and need not expect tile cheso so arety or personal attention or of this defendant us as in the tile bid inary relation between husband and wife defendant denies that thab about a ye year fir pir after the said alleged maneage with plaintiff or at any other time defendant commenced or practiced towards the said plain tiff a systematic or auy any course of neglect or unkindness or cruel or inhuman treatment or that at the said time defendant commenced or practised practiced toward the said plain plaintiff tIT I 1 s systematic or any course of neglect or unkindness or cruel or er inhuman treatment ending in an absolute desertion of her or otherwise but on tho the contrary this defendant alleg alleges aes that he ha hag always and and at all nil times treated the said plain plaintiff tili till with due 1 kindness and consider consideration atloff defendant denies that during tho the year or at any time ho hot con anu t ned nera the complainant against hr f vp ps Rs wishes or remonstrance to relt ainu it iove to a farm belonging to delv deti defendant enfant situated four miles from bait salu lake lako city I 1 or to remove to any place against her wishes Defel defendant denies that during all the time or any of the time said plaintiff resided on his farm she was compelled to perform or under the necessity of performing menial services in order to obtain the necessary means of subsistence or br for any As to what friends or comp companions the said plaintiff may have bad with her luring during her sojourn on the said farm in her complaint mentioned aed led this defendant is unable to S state ta t c r bub nub uit tit he be den denies t s that he e ever ver prohibited her from having or forbade ade ado lier her to have other or dif dlf different lerent companions with her besides beside her mother defendant denies that ho he did after the mother odthe of the said plain phlin tiff became infirm and unable to render lender assistance to said plaintiff or at any time object to lier her remaining longer on the place as a companion or otherwise to the plaintiff defendant denies that during his visits to the said farm while tho tile plaintiff resided thereon he treated the plaintiff with studied neglect or contempt or any neglect or contempt or that ho he intentionally gave her to understand stand or that he gaye gave her any cause to understand or infer that his vib vis ts were not for her but for the purpose of supervising the work on thy bo earm farm but defendant sais says at nil alt s such uch times and at all other times he treated said plaintiff with kindness kindne sg and gavero save gave to her as much attention as was consistent with defendants duties defendant denies that during all or any of the time while plaintiff resided on defendants farm she was restricted to the coar noar coarsest sest and epst meager meagen on to fro coarse or meagre fare or that thab from necessity sheh she had a d to less dress 1 ia lna 4 a 1 manner w wholly hol hoi y unsuitable or at all nil unsuitable goer gner station and position in life we but on ahe abe the Conti contrary defendant alleges mes ales e es t thab hatt during all of sald said paid time 8 said sald a d plaintiff 11 a ta w was as provided by this dieu dependant defendant with i tit plenty of food and clothing and means to 9 p said sald plaintiff and her family as well p provided ro for oon and as elegantly dressed as ivas was usual pr consistent with the simple manners and customs of the that time defendant admits tatt taft in the fall of 1872 3 he e provided a residence for the said plaint plaintiff lir jn an salt lake city abid and that she resided in said city in defendants house from that time until on or about the lath day of july A D 1873 at which last mentioned time timo defeli defell defendant daut dant says that the said plaintiff voluntarily and without his knowledge or consent and without any cibie cause for fear or vlola violence nce nee or hostility or vindictiveness ivaness from defendant did leave desert ind and abandon defendant s house and premises since which time plaintiff has not noti solicited any aid or asi assistance stance stanco from defendant nor has he be given her any defendant denies that plaintiff was constrained b by her destitution or feeble feebie he health althor of marof fear of violence from the hostility or vindictive disposition of de defendant fondant to vacate said E house ouse but nut alleges that while she resided there thero the i ra he provided berwith her with ampie ample means to live upon and that he never by word or other otherwise gave the plain tiff any reason to fear that he would ti eau eat her with violence or otherwise than with kindness and consideration defendant den de nies that since bince plaintiff s residence in salt lake cit city V after the fall of bf 1872 lie he has wholly absent absented d himself from complainant or refused to visit her ilar at her domicile but alleges the fact to be that during said bald time and aud during the year last past before the filing of the complaint lier iler herein eln elb defendant visited the said plaintiff at her domIcI domicile 16 at different times and as frequently as ast defendants duties would admit defendant admits that plaintiff has hag and did during tho the year aforesaid frequently calt call upon nhim him at another another house occupied by him in salt lake city and request him tol tal furnish her with articles necessary for her maintenance or the means mearis to procure them but defendant defenda git fit denies that in hi answer anser to td her said sala solicitations citations soli or any of them or ate ati auy any time he used towards opprobrious her ifer and most offensive language or opprobrious or offensive language in any degree Defendant denies that the tho articles furnished tho the said plaintiff by him since the fall of 1872 1972 were not sufficient in quantity and quality for her subsistence and that of her dependent eit cit children ildren lidren but avers favers that duning during all ali of said sald time and d at all times time t tin til said eald plaintiff left his hou hoube house Q eks eab e As aa aforesaid he furnished her with ample means mearis to support herself and imily family defendant denies that during sald said time nine or any part thereof plaintiff was fareed to do jar jan arwas was under the tho necessity of doing constant or severe manual labor labori jn order norder to procure the common necessaries of life for herself and chIldren i although defendant admits that thai plaintiff may have necessarily nece smaily smally performed some labor labora during that time timo ilithe in the management of hen her jin domestic af faira denies has frequently or at all ali communicated to him or that lie is or was aware of tho the fact that the plaint ill ili had bad for foi the last four years or for fon or any I 1 considerable part thereof been in delicate delicata e 0 or feeble health henith or that b by reason thereof she abd had been or ok was during that entire period or any portion thereof unable to perform any in manual anual labor lavor laboOn in her ber ordinal ordina na duties of ilfe life without u suffering n k fiFth at sho aho llad had sen uen or was in constant or any danger of permanent malid malig hit bit dis djs disease 6 or of that sho she bad been 1 in pt or any any heed of the ee services orvices RC qi deor a cia cla clano ciano medicines eines elnes or of ofa t fod 1901 rod rad proper to sueh such conditions 0 n ditiberis dit ibris defendant denies U that lat plaintiff 1 ain aln tiff at divers or any teme time pi times time s in the three 3 years last before beford the falln filing of the complaint herein asked or demand iemand ed of defendant to procure for her the attendance or treatment of a competent or any physician clan clau or t that hat he should furniss furnish the complainant with medicines or food nece necessary wary mary for her and appropriate to her feeble condition or that defendant has or li bad had ad always or at any time failed ore onye one fused to provide her with either medicines or medical at attendance or proper food or the means necessary to obtain them or that tn in consequence of any failure or refusal of the tho defend defendant antso go to do p la lias been compelled to rely solely or at a all oil on the charity of friends but nut on the contrary this defendant avers avem that he be has always and atall at all ali times furnis jurnis furnished hed her with all means necessary to procure her suitable provisions and sue suc sueh such h medicines a and rd medical attendance as he was advised ad she was at any ti wo in need or defendant denies that in the month of may 1873 at salt lake city or at any other time or place defendant lil Ili informed formed plaintiff that ho he would never again in any manne 0 to any extent poli contribute tribute to her support or that she must thenceforth rely solely on her own exertions f nor for or her subsistence or that of her children but OR on the contrary this defendant avers that since that thab time defendant has repeatedly pea peat edly furnished her means of subsistence tence and after that time and until she voluntarily left it as aforesaid he furnished her ar with a good dwelling house to reside in defendant says that lie he has no HO knowledge information or belief as to plain plaintiff tint tift being compelled to sell at a sacrifice such buch furniture if there wa any such as she claims to have owned purchased or had given to her or any furniture or household articles to procure means tos to support herself and children but defendant alleges that she was waa not compelled so to do and rind that there was no necessity for her doing so at any time between the oth goh day of april the time of the alleged marriage of plaintiff with this defendant and the timo time when plaintiff left defendants house as aforesaid on or about the lath day of july 1873 defendant denies that h he e has or had for a period of mom more than one year or for any time before the filing of the bill of complaint herein wilfully or without cause deserted fromyer plaintiff ain aln tifa tiff 0 01 absented himself from her society socie 3 or that ho he had deserted her at all defendant denies deniis reason or in in consequence of any apt or acts cf defendant or of any treatment or neglect of plaintiff by defendant fen dant either jn the nature of the pretended cruel or inhuman treatment in the complaint set forth or for any neglect bad ba 1 cruel or inhuman treatment of any kind whatsoever the said plaintiff and defendant cannot live in peace and union together or that by reason or in conse consequence que nce nee thereof their mutual Ny elfare welfare or the welfare of either or of them requires a separation defendant denies on information and belief that the sum of twenty thousand dollars or an auy any y sum what ever over would bon ben bo a creaso reasonable n able ablo or proper fee neo for the plaintiff solicitors and counsel in asserting her pretended I 1 legal egal or equitable rights growing browin g out of said alleged marriage defendant denies that one thousand dollars or any other sum exceeding one hundred dollars per mo monah nth would be a reasonable allowance to he plaintiff even if defendant was any legal obligation to provide for the maintenance anee ance education 3 and proper medical attendance attendance of said plaintiff and her children during this litigation defendant denies that he be is or has been the owner of wealth amounting to several millions of dollars or that he is or has been in the monthly receipt from property of forty tho thousand usand dollars or more on the conom contrary ry de defendant alleges that according to his best knowledge information an and d belief all his pro property erty erly taken together does nov not exceed in value e tho sum of six hu hundred adred thou thousand rand sand dollars and that his gross income from all of his property and nil nii devery every source does not exceed six thousand dollars per |