Your orator further states & charges that about april AD 1839 the said Joseph Smith deceased contracted with one for the purchace of the south east quarter of section No 2 in township No 6 north in range No 9 west of the fourth principal meridian for the sum of about four thousand dollars ($4,000,) and of which premises the said was then seized in fee & the said Joseph Smith then being indebted to your Orator as aforesaid & also to other persons to a large amount and being wholly insolvent with a fraudulent intent of delaying & hindering said creditors and to have & to keep the said property to his own use caused & procured the said to execute his obligation for the of said land to one that said was then a person of no property & insolvent & was used by said Smith as a mere man of Straw in fraudulent collusion with said Smith the more successfully effect the purpose aforesaid that about [p. [8]]