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In the District Court. 17th Judicial District.  Los Angeles County.  State of California


Amanda E. Pyle




John H. Pyle


The above named Plaintiff complains of the above named defendant and for cause of complaint Alleges:


That the Plaintiff and Defendant are husband and wife.  That they intermarried at Tucson in the Territory of Arizona on 17th day of August 1859 and have ever since been and now are husband and wife.


That the plaintiff is and has been a resident of said state of California ever since her said marriage and a resident of Los Angeles County for the two years last past.


That on or about the 3rd day of September 1870, the defendant disregarding the solemnity of his marriage vow willfully and without


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cause deserted and abandoned the plaintiff and ever since has and still continues so to willfully and without cause desert and abandon said plaintiff and to live separate and a part from her without any sufficient cause or any reason and against her will, wish and consent.


That there were born to the said plaintiff and the said defendant as the issue of said marriage the following children viz William James Pyle aged 12 years—Mary E. aged 10 years old—Edward A. aged 8 years—Henson M aged 5 years—all of whom are now living with and in the custody of plaintiff and have been since the said separation and plaintiff asks the judgment of his court awarding to her the custody and control of the said  children -


Wherefore plaintiff demands judgment.


That the bonds of matrimony between herself and defendant be dissolved and that the custody of said


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Minor children be awarded to her and she will ever pray.


O’Melveny & Hazard

Attys for Plantiff


State of California

County of Los Angeles


Amanda E. Pyle being duly sworn deposes and says that she is the plaintiff in the above Entitled Cause.  That she has heard read the forgoing Complaint and knows the contents hereof that the same is true of her own Knowledge.


Amanda E. Pyle



Sworn to Subscribed before me this 25th Day of Sept A. D. 1873


A. W. Potts Clerk

By S. H. Hott Deputy.





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In the District Court 17th Judicial District of the state of California within & for the County of Los Angles


Amanda E. Pyle


John H. Pyle


The above entitled cause having been by order of Court duly made and entered of Record on the 15th day of April 1874 referred to the undersigned Court Commissioner to take the testimony and under the name of this Court, and it appearing that said defendant had been duly served with summon by publication and he having failed to appear & answer I did upon the application of H. K. S. O’Melvary atty for plaintiff on the 15th day of April 1874 proceed to take the testimony in said cause which was as follows. -


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[Deposition of Amanda E. Pyle]


Amanda E. Pyle was introduced and by me duly sworn who testified as follows

Qu - What is your name

An. - Amanda E. Pyle


Qu - How long have you resided in this county


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An. - Two years last December and in this state ever since 1859 excepting two years in Oregon from 60 to sometime in 62 -


Qu - Do you know John Pyle, Deft -

An. - Yes sir—was married to him in Tucson Arizona in 1859 on the 17th of August


Qu - Has your husband left you.—

An. - Yes sir.—


Qu - When did he leave you—

An. - Three years ago last September


Qu - Has he ever lived with you since—

An. - No sir.—


Qu - Has he ever provided any support or means of support for you or your family since that time—

An. - No sir.—


Qu - Had he any cause or reason or justification for leaving you—

An. - No cause of mine.—He killed a man .  He left home Sunday morning saying that we was going on business.  The next morning I heard that he had stabbed a man and from that time to the present


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Qu (cont) I have never seen him


Qu - How many children have you of this marriage and what are their names and ages

An. - I have first - William James thirteen years old. - Mary E. about Eleven years old. - Everett A. - nine July next and Hensen about six years old.—


Qu - Do you desire the custody of these children

An. - Yes sir


Qu - Did you live together as husband & wife from the time you were married until he left you . -

An. - Yes Sir


Amanda E. Pyle


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[Deposition of J. C. Barnes]


J. C. Barnes was introduced and by me duly sworn who testified as follows.—


Qu - Are you acquainted with the plaintiff and defendant in this action

An. - I am.—I have know her since she was a child have known defendant fourteen years.—


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Qu - How long have you known them as husband and wife living together

An. - I have known them from the time of marriage until the time of separation


Qu - Has the defendant ever lived with plaintiff since the time of separation or provided her with any means of support for herself or family.—

An. - He never has lived with her to my knowledge nor has he ever provided her or her family any means of support since he left her.—I have known her for over two years in Los Angles County and during that time the defendant has never lived with her or provided her or her family with any means of support.—


Qu - Do you know the causes which let the defendant to abandon the Plff.—

An. - Only from report.—The cause was he killed [“murdered” crossed out] a man and had to flee the county for his own safety


J. C. Barnes


[Deposition of W. S. Neel]


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W. S. Neel was then introduced and by me duly sworn who testified as follows.—


Qu - How long have you known the plaintiff in this County—

An. - Over two years.—


Qu - During that time has the defendant ever lived with her or provided her with any means of support.—

An. - He has never lived with her and has never provided her any means of support to my knowledge.


Qu - How long did you know of the plaintiff & defendant living together as husband & wife.—

An. - Two years.—I lived neighbor to them two years before he left


W. S. Neel


Plff xxxxx.—


The above and foregoing is a true record of all the testimony introduced before me in the above cause.


John D. Bicknell

Court Commissioner


Divorce:  April 15, 1874
John H. Pyle and Amanda Barnes


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Los Angles County, CA

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April 15, 1874 - Divorce: Amanda Barnes &

John H. Pyle




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