That afterwards said by the procurement of said Joseph Smith deceased to the said & infant children of said Joseph Smith deceased & your orator charges that the said Joseph Smith deceased purchased and paid for the said land & caused the same to be conveyed as aforesaid with the fraudulent intent & purpose aforesaid and without any consideration from the grantees in said deed

That one Francis Church about the year AD 1842 being seized of the west half of the southeast quarter of section No thirty one in township No five North Range No eight west & the west half of the Northwest of five & the east half of the northeast quarter of six in Township four north in Range eight west of the fourth principal meridian in conveyed the same to the said Joseph Smith dec in fee, that afterwards and about the year AD 1842 the said Joseph Smith dec joined with said his wife & conveyed said lands & premises so purchased by him of said Church & conveyed by said Church to him as aforesaid to the said , & his infant children aforesaid & your orator charges that the said Joseph Smith was then indebted & insolvent as aforesaid & that said conveyance was made contrived & executed [p. [14]]