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Alice McKay v. John Kevan and Della Kevan

In the District Court of the Third Judicial District of Washington Territory, Holding Terms at Seattle for the Counties of King & Kitsap

In the Matter of the Application of Alice McKay for a Writ of Habeas Corpus for the Body of Mary McKay, her Infant Daughter,

No. -----
Petition for Writ of Habeas Corpus

To the Honorable Richard A. Jones, Chief Justice of Washington Territory, and Judge of the Third Judicial District thereof:

The Petition of Alice McKay respectfully shows:

1

That Mary McKay, an infant child of the age of eight and one-half years is unlawfully detained and restrained of her liberty and from the custody of your petitioner by John Kevan and Della Kevan, his wife, at the city of Seattle, King County, Washington Territory.

2

That according to the best knowledge and belief of your petitioner the cause or pretense of the detention of the said Mary McKay, is that the said John Kevan and Della Kevan claim to have taken said child, some years ago, from the sisters of charity in the said city of Seattle, and ever since said time have cared for and supported said child.

3

That the said detention, restraint and the unlawful keeping of said child from your petitioner are illegal, and that the illegality thereof consists in this, to-wit: 1. That your petitioner has been for        years last past and now is a bona fide resident of the city of Tacoma, Pierce County, Wash. Ty. 2. That your petitioner is the mother of the said Mary McKay, and has a home at the said city of Tacoma, at which she is amply able to support, maintain and educate said child. 3. That your petitioner dearly loves said child, and life is unendurable to her without the custody and comforting society of her said infant daughter. 4. That your petitioner was deprived of her said daughter, Mary McKay, without her consent. 5. That the said John Kevan and Della Kevan are endeavoring to teach said child to forget its said mother, or to recognize your petitioner as such. 6. That the said John Kevan, and Della Kevan have refused to allow your petitioner to visit said child or to hold communication with her although your petitioner has often requested the right so to do. 7. That the said John Kevan and Della Kevan have refused and now refuse to surrender to your petitioner her said infant daughter.

Wherefore your petitioner prays that a writ of habeas corpus be granted, directed to the said John Kevan and Della Kevan, commanding them to have the body of the said Mary McKay before your honor at a time and place therein to be specified, together with the time and cause of her detention, and said writ, and that the said Mary McKay be surrendered to your petitioner.

Ronald & Piles
Attorneys for Petitioner


Territory of Washington
County of King ss.

Alice McKay being duly sworn, on oath says: That she is the petitioner in the above entitled action; that she has heard the foregoing petition read, knows the contents thereof, that the same is true

Alice McKay

Subscribed and sworn to before me this 25th day of Nov. 1887
L. H. Piles
Notary Public in and for Washington Territory


Territory of Washington,
County of King ss.

I, James Seavey, Clerk of the District Court, holding terms at Seattle, in King County, Washington Territory, hereby certify that the foregoing is a full, true and correct copy of the               in the foregoing entitled cause, now on file and of record in my office.

Witness my hand and the Seal of said Court this day of          188  

James Seavey, Clerk
By                  Deputy Clerk.


5662

In the matter of the Application of Alice McKay for a writ of Habeas Corpus

Order for writ

Now on this 25th day of Nov. 1887, on reading and filing the petition of Alice McKay praying for a writ of habeas corpus to produce the body of Mary McKay and surrender the same to said petitioner It is order by the Court that said writ issue as prayed for & that John Kevan and Della Kevan, his wife, be and they hereby are required to produce the body of said Mary McKay in Open Court at the hour of 1:30 pm of this day


In the District Court of the Third Judicial District of Washington Territory, holden terms at Seattle for the Counties of King and Kitsap.

Habeas Corpus.

The People of the United States of America, to John Kevan and Della Kevan his wife "Greeting–

We command you that you have the body of Mary McKay by you restrained and detained as it is said, together with the time and cause of such restraint and detention by whatsoever name said Mary McKay shall be called or charged, before the Hon Richard A. Jones Judge of the aforesaid Court at the Court House in the City of Seattle W.T. at the hour of 1.30 P.M. of this day to do and receive what shall then and there be considered concerning the said Mary McKay. And have you then and there this writ.

S.S.

Witness the Hon. Richard A. Jones Judge of said District Court, and the seal thereof this 25th day of 
Nov. A.D. 1887. W. E. Ledgerwood clerk


In the District Court of the Third Judicial District of Washington Territory, holding terms at Seattle.

In the matter of the application of Alice McKay for a Habeas Corpus to obtain possession of her infant child Marie McKay

Summons

Comes now petitioner herein and demurs to the return of the respondents herein to the writ of Habeas Corpus herein granted, for that no authority or cause for the restraint of the person of Mary McKay is in said return averred.

2nd

An alleged adoption, or attempt to claim an adoption, is insufficiently made, nor is it averred as made by competent authority or by a Court having Jurisdiction.

3d

There are no allegations in said return Justifying or lawfully authorizing said restraint.

Elwood Evans & Ronald & Piles


5662

In the matter of the application of Alice McKay for a writ of Habeas Corpus to obtain the person of her infant child Mary McKay

Now on this 26th day of November 1887, this matter coming on before the court to be heard, and after hearing the evidence in the matter, it is ordered by the Court that this matter be and the same hereby is continued for argument, and final Judgment and final disposition of said infant, until the 16th day of Dec. 1887 at the hour of 130 P.M. And it is ordered, adjudged & decreed by the court that in the meantime the said infant child, Mary McKay be and she hereby is the ward of this court, and suffered to remain in the custody of John Kevan & Della Kevan as such until the said 16th day of November 1887, at 1.30 P.M. at which said time the said John Kevan & Della Kevan are required to produce the body of the said Mary McKay before this court to be disposed of as the court shall deem meet and equitable. And it is further ordered that the said John and Della Kevan are hereby enjoined from removing said child from without the Jurisdiction of this Court.


In the District Court of this Third Judicial District of Washington Territory holding terms at Seattle

In the matter of the application of Alice McKay for a writ of Habeas Corpus to obtain the person of her infant child Mary McKay

Answer.

Comes now petitioner herein and answer in the return of respondents to the writ of Habeas Corpus herein issued

1.

Denies each and every material allegation in said return set forth, and

2

Petitioner alleges that she is a fit, competent and proper person to have charge of the said child, her control maintenance and education, and that she is an affectionate mother and is a Protestant and believes in the Protestant Christian religion, and desires to have her daughter educated and instructed in said religion, instead of in the Catholic religion in which respondents are now seeking to have her instructed and educated. Wherefore petitioner pray that she be awarded the custody of her said child

Elwood Evans and Ronald & Piles
Attys for Petitioner.

Territory of Washington
County of King ss

Alice McKay being first duly sworn on oath says that she is the petitioner named in the above entitled cause, that she has heard read the foregoing answer knows the contents thereof, and believes the same to be true.

Alice McKay
L. H. Piles

Subscribed & sworn to before me this 26th day of November 1887.

L H Piles Notary Public


In the District Court, holding Terms at Seattle, King County Washington Territory.

In the matter of the application of Alice McKay for a Writ of Habeas Corpus, to obtain the person of her infant child, Mary McKay.

Comes now Alice McKay, Petitioner for said Writ, and for amended traverse to the return of John Kevan and Della Kevan, Respondents to said Writ of Habeas Corpus.

Denies, 1. That the said child Mary McKay is otherwise known as Mary Kevan, or that she is named otherwise & known as Mary McKay.

Denies that in August 1882, or at any other time, Petitioner abandoned or deserted said child, when at the tender age of three years, or at any other age, and denies that she ever abandoned or deserted said child.

Denies that she left said child on the door step of the Sisters of Charity, or abandoned her there or at any other place at the time alleged or at any other time whatever.

Denies that said child has ever been adopted by said respondents, denies upon information and being that said respondents have educated and reared said child. Denies that she has any information as to the financial abilities to rear and educate said child sufficient to form a belief, and cannot therefore admit or deny the same.

Denies all of the paragraphs of said answer in which it is alleged to be an unfit person, and each and every allegation in said paragraph contained.

Denies the whole of paragraph as to the intemperate and criminal habits of the Father and Mother of said child, and each and every allegation therein contained denies that the Father is a Fugitive from Justice. Denies that she is now living in adultery with any person. Denies that she is addicted to the use of liquor or in the habit of getting intoxicated. Denies that she is the proprietor of a saloon. Denies that she is unfit to rear said child, but avers that she is in every way competent financially and morally to make a good home for said child and give her a proper education and support.

Denies the last paragraph which alleges that Respondents are legally entitled or in any other way entitled to the custody of said child.

And for further traverse and answers to said Return to said Writ.

Petitioner alleges that she is the mother of said child, and that at present, her husband William McKay, who is a sea-faring man is absent in Scotland, and that she is making an honest livelihood by labor, and earns sufficient to make a good home for herself and children. That she is a fit, competent and proper person to have charge of the said child, her control, maintenance and education and that she is an affectionate mother and is a Protestant and believes in the Protestant Christian religion and desires to have her daughter educated and instructed in said Faith, instead of in the Catholic religion in which respondents are now seeking to have her instructed and educated. Wherefore Petitioner prays that she be awarded the custody of her said child.

Ronald & Piles & Elwood Evans
Attys for Petitioner


Territory of Washington
County of King s.s.

Alice McKay being first duly sworn on oath says that she is the petitioner named in above entitled cause. that she has heard read the foregoing answer knows the contents thereof and believes the same to be true.

Alice McKay

Sworn to and Subscribed before me this 26th day of November 1887

L. H. Piles


In the District Court, holding terms at Seattle in King County, Washington Territory.

In the matter of the application of Alice McKay for a writ of Habeas Corpus for the body of Mary McKay.

No. 5662.

Return to Writ.

To the Hon Richard A. Jones, Judge of said Court:

The respondents, John Keevan and Della Keevan, his wife for a return to the writ of habeas corpus served on them herein respectfully show Your Honor; that the said child Mary McKay, otherwise Mary Keevan, when an infant of tender years, to-wit: of the age of about three years and on or about the       day of August 1882 deserted and abandoned by the said Alice McKay and by her left on the doorstep of the Sisters of Charity in said Seattle, and never has been cared for, supported or in any way provided for or maintained by said Alice McKay, since said date; that said child was supported and maintained by said Sisters of Charity for a brief period, to-wit for about two years, when she was by said sisters given to these respondents, and taken and adopted by them as their own child, and has ever since up to the present day been nourished, supported, cared  for, maintained and educated by these respondents, and has lived with them in their own home in the City of Seattle and is in all respects treated by them as their own child and is being educated and reared by them to a useful, honest and virtuous life; that the whole expense of rearing said child since she was received by them from said sisters has been borne by your respondents; that your respondents are deeply attached to said child; that they have no children of their own and love said child dearly, and said child reciprocates their affection, and is contented and happy with them, and has never known any other home save that of these respondents, and has come to regard these respondents as her parents; that these respondents have abundant ability financially to rear and educate said child properly and desire and intend so to do.

And your respondents further allege and state that said Alice McKay is a wholly unfit person to be permitted to have the care or control or custody of said child, having abandoned the same to the care of strangers voluntarily when a mere infant, and never having cared for her since. That said Alice McKay has no means whatever and is wholly unable to properly care for, maintain or educate said child.

And your respondents further aver that the father of said child, and its mother, the said Alice McKay, are both of a grossly immoral and intemperate character; that   the father of said child is now a fugitive from justice and absent from Washington Territory; that the said Alice McKay is now living separate from her said husband and is cohabiting and living in adultery with a man, whose name is unknown to affiant; that said Alice McKay is greatly addicted to the use of liquor and is frequently grossly intoxicated; that the said Alice McKay is now the proprietor of a low saloon in the City of Tacoma, Washington Territory, to which saloon, as respondents are informed and believe she proposes to take said child should this Honorable Court award her the custody of the same; that said Alice McKay is a person of very bad moral character having been convicted of the crime of selling liquor to Indians at the November term of the District Court, holding terms at Tacoma W. T. on or about the 1st day of January 1884, and is a person wholly unfit to have the care of an infant child; that if said Alice McKay be given the custody of said child, these respondents verily believe that said child will be reared up to lead an immoral life: that said child is desirous of remaining with these respondents, and if left in their custody will be reared in a good home and to a good life.

By reason of the aforesaid facts, your petitioners allege that they are legally entitled to the custody of said child, nevertheless they here produce the body of said Mary McKay, and request that she be again remanded to their custody.

John Keevan
Della Keevan her X mark


Territory of Washington
County of King ss.

John Keevan and Della Keevan, on oath each says; that the foregoing return has been read to them; that they know the contents thereof; that the same is true in substance and in fact.

Della Keevan her X mark
John Keevan

Subscribed and sworn to before me this 27th day of November, A. D. 1887.

L. C. Gilman
Notary Public.


In Superior Court of King County, Washington. No 5662 

Order

In Re Application of Alice McKay for Writ of Habeas Corpus to Obtain Possession of Mary McKay

Now May 5, 1891 on presentation and reading of affidavit of Della Keevan, a warrant is directed to issue for the arrest of Alice McKay and Katie McKay Doe formerly Katie McKay whose marriage name is unknown for contempt without Bail, as prayed for in said affidavit.

I. J. Lichtenberg
Judge
5 May /91


In the Superior Court of King County, State of Washington.

In the Matter of the Application of Alice McKay for a Writ of Habeas Corpus to Obtain the Person of Her Infant Daughter, Mary McKay.

No. 5662.

State of Washington
County of King ss

Della Keevan, being first duly sworn according to law, deposes and says: that on the 26th day of November, 1887, the above-entitled matter coming on to be heard in the then district court in and for King County, in the then Territory of Washington, before Honorable Richard A Jones of said court, and it was so proceeded in that the said Honorable Richard A Jones made and entered the following order in the above entitled cause:

In the Matter of the Application of Alice McKay for a writ of habeas corpus to obtain the person of her infant child, Mary McKay.

Now, on this 26th day of November, 1887, this matter coming on before the court to be heard, and after hearing the evidence in the matter, it is ordered by the court that this matter be and the same hereby is continued for argument and final judgment, and final disposition of said infant until the 16th day of December, 1887, at the hour of 1.30 p. m. and it is ordered, adjudged and decreed by the court that in the meantime the said infant child, Mary McKay be and she hereby is the ward of this court and suffered to remain in the custody of John Keevan and Della Keevan as such until the said 16th day of December, 1887, at 1.30 p m at which said time the said John Keevan and Della Keevan are required to produce the body of the said Mary McKay before this court to be disposed of as the court shall deem meet and equitable. And it is further ordered and that the said John and Della Keevan are hereby enjoined from removing said child from without the jurisdiction of this court.

That on the 16th day of December, 1887, a further order was entered in said cause continuing the further hearing until the 29th day of December, 1887, and that said cause has never been finally disposed of either in said district court or in the superior court, the successor of said district court. That since the making of said orders in said cause, Mary McKay, known as Mamie Keevan, in accordance with said order of November 26, 1887 has been in the care, custody and control of affiant and her husband, John Keevan, as a member of their family and has been cared for and provided for by them as one of their family and that they have always held her in their care and custody as the ward of said court according to the terms of said order up to April 17, 1891, and that they have obeyed said order in all respects and have not taken said child out of the jurisdiction of this court. Affiant further says that on the 17th day of April, 1891, Alice McKay, the mother of said child, and the daughter of said Alice McKay, Katie McKay Doe, now married, and whose marriage name is to the affiant unknown entered upon the premises of affiant in the City of Seattle and forcibly and against her will abducted and carried away said Mary McKay, known as Mamie Keevan, said Mary McKay then and there being in the custody of the affiant and her husband, John Keevan, as the ward of this court, in contempt and disregard of the aforesaid order of said court and carried her as affiant is informed and believes into the county of Pierce and State of Washington and Alice McKay and Katie McKay Doe, whose marriage name is to the affiant unknown, now have said Mary McKay concealed in said county of Pierce, in or near the City of Tacoma, aforesaid and against her will. Affiant further says that said Alice McKay and Katie McKay Doe are not fit and proper persons to have the care, custody and control of said Mary McKay, who is now of the age of fifteen years and that this affiant verily believes and expects to prove that said abduction and carrying away was for the purpose of placing said Mary McKay where she would be obliged to enter upon a life of shame in a house of prostitution and for no other purpose whatever, as said Alice McKay is and has been well-known for years as a drunken, disreputable character and a common prostitute and a keeper of disreputable places including houses of prostitution. Affiant further says that at the time of such forcible abduction and carrying away, said Alice McKay and Katie McKay Doe, her daughter, were fully aware of the fact that said Mary McKay was in the care and custody of the affiant and her husband as the ward of this court and were fully cognizant of said order of court hereinbefore set forth and perpetrated said abduction and carrying away with full knowledge of said order and in contempt thereof.

Wherefore affiant prays that a warrant of arrest be issued for the apprehension of said Alice McKay and Katie McKay Doe, whose marriage name is to the affiant unknown, without bail, and that they be brought before your honorable court to answer for the contempt by them committed in the aforesaid abduction and removal of said Mary McKay from the care and custody of the affiant and her husband.

Della Kevan

Sworn to and subscribed before me this 5th day of May, 1891.
James Riefer
Notary Public in and for the State of 
Washington, residing at Seattle.


In the Superior Court of King County, State of Washington.

In the Matter of the Application of Alice McKay for a Writ of Habeas Corpus to obtain the Person of her Infant Daughter, Mary McKay

Comes now the defendants Alice McKay and Katie McKay Buderick, and -

Demurrer to the affidavit and warrant upon which they are arrested and held for contempt of court for violating the order of the District Court of the Territory of Washington made on Nov. 26th 1887, making said Mary McKay a ward of said court on the ground.

First That said affidavit and warrant do not nor does either of them state facts sufficient to constitute 
an offense nor a contempt

Second That said matter involved appears to have been submitted more than 90 days prior to the commencement of this proceeding–– and the Court appears not to have rendered a decision therein and has thereby lost jurisdiction to make and find order on said hearing in said Habeas Corpus matter, and is without jurisdiction to enforce the provisional order made therein pending the final decision of said Habeas Corpus matter.

[unclear signature]
Attorney for Defts


#5662 

In matter of Habeas Corpus for body of Mary McKay

Demurrer of Defts Alice & Katie McKay to affidavit & warrant for contempt

Filed.
May 8 1891
W. B. Spencer, Clerk
by W P McBride
Deputy Clerk


In the Matter of the Application of Alice McKay for a Writ of Habeas Corpus to Obtain the Person of Her Infant Daughter Mary McKay.

No. 5662.

The State of Washington

To J. H. Woolery Sheriff of King County, Greeting

Whereas complaint has been made under oath before the undersigned, one of the judges of the Superior Court of the County of King, in the State of Washington, that on the 26th day of November, 1887, the above entitled matter came on to be heard in the then district court in and for King County, in the then Territory of Washington, before Honorable Richard A Jones of said court, and it was so proceeded in that the said Honorable Richard A Jones made and entered the following order in the above entitled cause:

In the Matter of the Application of Alice McKay for a writ of habeas corpus to obtain the person of her infant child, Mary McKay.

Now, on this 26th day of November, 1887, this matter coming on before the court to be heard, and after hearing the evidence in the matter, it is ordered by the court that this matter be and the same hereby is continued for argument and final judgment, and final disposition of said infant until the 16th day of December, 1887, at the hour of 1.30 p m and it is ordered, adjudged and decreed by the court that in the meantime the said infant child, Mary McKay, be and she hereby is the ward of this court and suffered to remain in the custody of John Keevan and Della Keevan as such until the said 16th day of December, 1887, at 1.30 p m at which produce the body of the said Mary McKay before this court to be disposed of as the court shall deem meet and equitable. And it is further ordered that the said John and Della Keevan are hereby enjoined from removing said child from without the jurisdiction of this court.

That on the 16th day of December, 1887, a further order was entered in said cause continuing the further hearing until the 29th day of December, 1887, and that said cause has never been finally disposed of either in said district court or in the superior court, the successor of said district court. That since the making of said orders in said cause, Mary McKay, known as Mamie Keevan, in accordance with said order of November 26, 1887 has been in the care, custody and control of affiant and her husband, John Keevan, as a member of their family and has been cared for and provided for by them as one of their family and that they have always held her in their care and custody as the ward of said court according to the terms of said order up to April 17, 1891, and that they have obeyed said order in all respects and have not taken said child out of the jurisdiction of this court. Affiant further says that on the 17th day of April, 1891, Alice McKay, the mother of said child, and the daughter of said Alice McKay, Katie McKay Doe, now married, and whose marriage name is to the affiant unknown entered upon the premises of affiant in the City of Seattle and forcibly and against her will abducted and carried away said Mary McKay, known as Mamie Keevan, said Mary McKay then and there being in the custody of the affiant and her husband, John Keevan, as the ward of this court in contempt and disregard of the aforesaid order of said court and carried her as affiant is informed and believes into the county of McKay Doe, whose marriage name is to the affiant unknown, now have said Mary McKay concealed in said county of Pierce, in or near the city of Tacoma aforesaid and against her will. Affiant further says that said Alice McKay and Katie McKay Doe are not fit and proper persons to have the care, custody and control of said Mary McKay, who is now of the age of fifteen years and that this affiant verily believes and expects to prove that said abduction and carrying away was for the purpose of placing said Mary McKay where she would be obliged to enter upon a life of shame in a house of prostitution and for no other purpose whatever, as said Alice McKay is and has been well-known for years as a drunken, disreputable character and a common prostitute and a keeper of disreputable places, including houses of prostitution. Affiant further says that at the time of such forcible abduction and carrying away, said Alice McKay and Katie McKay Doe, her daughter, were fully aware of the fact that said Mary McKay was in the care and custody of the affiant and her husband as the ward of this court and were fully cognizant of said order of court hereinbefore set forth and perpetrated said abduction and carrying away with full knowledge of said order and in contempt thereof; praying that a warrant of arrest be issued for the apprehension of said Alice McKay and Katie McKay Doe, whose marriage name is to the affiant unknown, without bail, and that they be brought, before your honorable court to answer for the contempt by them committed in the aforesaid abduction and removal of said Mary McKay from the care and custody of the affiant and her husband.

Now You Are Hereby Commanded to forthwith take the bodies of Alice McKay and Katie McKay Doe formerly Katie McKay, whose marriage name is unknown and forthwith bring them before Honorable I J [several words missing] court room in the city of Seattle, in the county of King and State of Washington, there to answer the charge of contempt hereinbefore recited and them safely keep; and for so doing this shall be your sufficient warrant.

Witness the Honorable I J Lichtenberg, one of the judges of said court and the seal of said court, this 5th day of May, A D 1891.

W. B. Spencer Clerk.
By Geo. F. Stanley, Dep Clerk.


In the Superior Court of King County, State of Washington.

In the Matter of the Proceedings against Alice McKay and Katie McKay Doe, whose true name is Katie Budenich.

No. 5662.

The respondents, Alice McKay and Katie Budenich, having been brought up upon the warrant heretofore issued and the court having heard the testimony adduced on the 8th day of May, 1891, and having adjourned the further hearing of the matter until the 9th day of May, 1891, and the matter having been fully heard and considered by the court on said 9th day of May, 1891, and the respondents being present in court, the court finds the following facts:––

I.

That on the 26th day of November, 1887, the Hon. Richard A Jones, Chief Justice of the Territory of Washington, presiding at a term of the District Court of the Third Judicial District, declared Mary McKay a ward of the court, and placed her in the custody of John Keevan and Della Keevan as such ward, until the final judgment and disposition in case No. 5662, an application by Alice McKay for a writ of habeas corpus to obtain the person of said infant.

II.

That in obedience to said order said infant was in the custody of said John and Della Keevan until the 17th of April, 1891, to-wit in the city of Seattle, King County, State of Washington. That on said date said Alice McKay entered the dwelling of the parties having charge of the said ward and by force abducted said infant Mary McKay, taking her to the County of Pierce and there detaining her.
 
III.

That at the time of said abduction, said case No. 5662 was undisposed of. That neither the parties in charge of said ward nor the ward herself nor the Superior Court of King County had given any consent to the removal of said ward. That at the time said order constituting said infant the ward of this court was made said Alice McKay was aware of the order and had full knowledge thereof.

IV.

That in the said abduction, and taking of the said ward, said Alice McKay was assisted by her daughter, Mrs Katie Budenich.

Whereupon it is considered by the court that the defendants, Alice McKay and Mrs Katie Budenich, are guilty of contempt of court and they are so adjudged.

Wherefore it is ordered, adjudged and decreed by the court that Mrs Katie Budenich be fined for said contempt of court the sum of five dollars and that she jointly with her mother, Alice McKay, pay the costs of this proceeding, and it is further considered, ordered adjudged and decreed by the court that the defendant, Alice McKay, pay a fine of fifty dollars for said contempt and jointly with Katie Budenich pay the costs of this proceeding that they both be committed to the custody of the sheriff until the sentence of the court is complied with.

And it is further ordered, adjudged and decreed by the court that said Mary McKay be declared and she is hereby made the ward of this court and she is hereby committed to the care, custody and control of Della Keevan, wife of John Keevan, until the final disposition of the application of Alice McKay for a writ of habeas corpus to recover the possession of said Mary McKay now pending and undetermined in this court; said Mary McKay, ward of this court, not to be taken out of the County of King without the consent of the court first had and obtained and all persons are hereby enjoined from intermeddling with said ward of the court.

Lichtenberg
Judge.

13 May/91

This order to be of force & effect [unclear] on May/91

Lichtenberg
Judge
23 May/91


Dear Friend Mrs Fountain

I hope that you are not offended with me for you no that it was the beer that was talking. I can not take more then one glass of beer scence I was sick and you now that I had two or three yesterday, and it went to my head. I did not now what I said untill Mamie told me late in the evening you now yourself that you are the last in Seattle that I would offend Because you were all ways a good kind friend to me I cannot forget your kindness. I now that you are too kind hearted to keep in spite. Be sure and come to-morrow to see me. If I did not care for you I would not write this and send Mamie over with it 

Believe me to be your sincere Friend
Idella Keevan


#5662

EX A

A.C.B.

Lichtenberg 
Judge 
1 July /91


F. A. Buck & Co. 
Dealers in Wine
Spirit Merchants
Union Block
Agents for 
To-Kalon Vineyard,
Napa.
Telephone No 313.

Seattle, Wash July 11 1891

Sold to Mrs Keevan

1889

June 5 ½ gal Rose 1. & 1 gal Claret 90 1.90

" 14 ½ " Brandy 1.50

July 3 ½ " " 1.50

" 12 1 " Claret .50

5.40


Mrs Keevan 
5662 Ex B 
A.C.B.
 
Exhibit "B" 
5662

In the matter of the petition of Alice McKay for writ of Habeas Corpus to obtain the body of Child Mary McKay

Filed July 11, 1891
W.B. Spencer, Clerk
By H. B. Lund[?]
Deputy Clerk