Moore/Findley
Custody Dispute
21 December 1918 Glynn County

Georgia, Glynn county,

To the Honorable Edwin W. Dart, Ordinary of Glynn county, Georgia.  The petition M.M. Moore and his wife Mrs. M.M. Moore shows the following.

1.  Under order of the superior court of Glynn county, Georgia, in the case of Katie C. Findley vs. N.W. Findley, pending in said court, and on the 23d day of April, 1918, your petitioners were awarded the custody of N.W. Findley, Jr., a male child of the age of nine years, until the further order of the court.

2.  Petitioners show that now and for some time past N.W. Findley, of Glynn county, Georgia, has taken away from your petitioners and is illegally detaining in his possession and from the custody of your petitioners the person of the said N.W. Findley, Jr., harboring and restraining the said child at the resident of the said defendant, in said Glynn county.

3.  Petitioners aver that they did, through petitioner Mrs. M.M. Moore, demand the said child from the said defendant, on the 25th day of November, 1918, and endeavored to induce him to deliver to your petitioners the person of said child.

4.  Nevertheless the said N.W. Findley fails, neglects and refuses to deliver the said child to your petitioners as in duty bound.

5.  Petitioners do not know under what pretended claim the said defendant is holding said child.

6.  Petitioners aver that said detention of said child by the defendant is illegal because under the order of the Court aforesaid the custody of said child was awarded to them, and they have not released their right.

Wherefore they pray your Honor to grant to them the State's writ of habeas corpus, directed to the said N.W. Findley, commanding and requiring him to produce the said child before your Honor at such time and place as to your Honor shall seem mete and proper, to the end that what appertains to justice shall be done.

Respectfully submitted,

C.M. Conyers?
Attorney at law for petitioners.

 

Georgia, Glynn county.

In person appeared before the undersigned Mrs. M.M. Moore, one of the petitioners named in the foregoing petition, who on oath says that the facts stated in the foregoing petition are true; and further says that she has reason to apprehend that the defendant in the foregoing petition, who is detaining or holding the said child, N.W. Findley, Jr., in custody, will remove him beyond the limits of the county, or conceal him from the officers of the law unless the body of the said N.W. Findley, Jr., be brought before the court.

Mrs. M. Moore [signature]

Sworn to and subscribed before me this 21 day of December, 1918.

 Edwin W. Dart, Ordinary G.C. Ga.

 

Georgia, Glynn county.

To N.W. Findley, of said county:

You are hereby commanded to produce the body of N.W. Findley, Jr., alleged to be illegally detained by you, together with the cause of the detention, before me on the 21 day of December, 1918, at 2:30 o'clock p.m., at the Court House, Glynn county, Georgia, then and there to be disposed of as the law directs.

Given under my hand and official signature this December 21, 1918.

Edwin W. Dart, Ordinary, Glynn county, Georgia.

 

Georgia, Glynn county.

To the Sheriff, Deputy Sheriff, or any Legal Constable of said county:

Mrs. M.M. Moore, one of the applicants for the foregoing writ of habeas corpus, having filed along with her petition therefore her affidavit that she has reason to apprehend that N.W. Hindley [sic] will remove N.W. Findley, Jr., beyond the limits of the county, or conceal him from the officers of the law, you are hereby commanded to search for and arrest the body of the said N.W. Findley, Jr., so detained, and bring him before me, to be disposed of as I may direct.

Herein fail not.

Witness my hand and official signature, this the 21 day of December, 1918.

Edwin W. Dart, Ordinary, Glynn county, Georgia

 

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