"The complainant further alleged that these several claims,
representations, and pretensions were wholly and maliciously
false, and were made by her for the purpose of injuring him in
his property, business, and social relations; for the purpose
of obtaining credit by the use of his name with merchants and
others, and thereby compelling him to maintain her; and for
the purpose of harassing him, and in case of his death, his
heirs and next of kin and legatees, into payment of large
sums of money to quiet her false and fraudulent claims and
pretensions. He also set forth what he was informed was a copy
of the declaration of marriage, and alleged that if she
had any such instrument, it was 'false, forged, and
counterfeited;' that he never, on the day of its date, or
at any other time, made or executed any such document or
declaration, and never knew or heard of the same until within
a month previous to that time, and that the same was null and
void as against him, and ought, in equity and good conscience,
to be so declared, and ordered to be delivered up, to be
annulled and cancelled."
The complaint concluded with a prayer that it be adjudged and decreed
that the said Sarah Althea Hill was not and never had been his wife;
that he did not make the said joint declaration of marriage with her,
or any marriage between them; that said contract or joint declaration
of marriage be decreed and adjudged false, fraudulent, forged, and
counterfeited, and ordered to be delivered up and cancelled and
annulled, and that she be enjoined from setting up any claims or
pretensions of marriage thereby.
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