[citing St Helena Parish Suits in 6th District Court 90-157] "4 Feb 1862. The petition of Mary Susannah Draughon the wife of Thomas Warren Day, both residents of St. Helena Parish, who states that she has been duly authorized by the Judge to institute this action. That she married Day about 9 Mar 1859. That since then she has continued to live with him performing all duties of a good, faithful wife, until by the conduct of Day, living with him became intolerable and insupportable. That Day has been in the custom of treating her in an outrageous manner, abusing her, using threats of violence, and actually striking her since marriage. Petitioner is convinced that a longer residence with him will only result in further injurious treatment. That she and Day have had of their marriage one child now living, which child is not two years old, that said Day has taken the child away from her and threatens her that she shall never see said child, and that he will place the child out of the way where she shall never see him. That the child should not because of its tender age be separated from petitioner, and that she as the mother should have its care. That during her marriage they have acquired considerable property, one-half of which after debts are paid should belong to her. Petitioner asks for the care of the Child, Jefferson Munroe Day, until final termination of this suit, and then to have permanent custody. She also prays for a separation of bed and board."
"4 Feb 1862. Leonidas W. Draughon, sworn, states that he is the brother of Mrs. Mary Susannah Draughon" [...]
