ing, the issue of that
marriage, and also grandchildren, the children of a deceased
daughter of the marriage; that he was possessed of a large
fortune in real and personal property; was extensively engaged
in business enterprises and ventures, and had a wide business
and social connection; that, as he was informed, the defendant
was an unmarried woman of about thirty years of age, for some
time a resident of San Francisco; that within two months then
past she had repeatedly and publicly claimed and represented
that she was his lawful wife; that she falsely and fraudulently
pretended that she was duly married to him on the twenty-fifth
day of August, 1880, at the city and county of San Francisco;
that on that day they had jointly made a declaration of
marriage showing the names, ages, and residences of the
parties, jointly doing the acts required by the Civil Code of
California to constitute a marriage between them, and that
thereby they became and were husband and wife according to the
law of that State.

"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 mar