paragraph described and did make or cause to be made and spread upon the records of a deed without and <any> consideration and for the fraudulent purposes aforesaid from him said Joseph Smith discribing himself as sole Trustee of the Church of Jesus Christ of Latter Day Saints, a pretended religious society, a deed of the premises in this paragraph described to the said , , , and .
Your Orators further state that after the death of the said deceased the said intermarried with the said Lewis C. Bidaman and the said , intermarried with the said Elisha Dixon.
And that the said , Lewis C. Bidaman, , , and together with said defendant now claim, title and interest in the lands, Lots, Blocks, and premises described in the last two paragraphs,
And Your orators charge that their said claims of title is fraudulent and void as to your Orators.
Your Orators further state that in or about the month of September A. D. 1841, the said Joseph Smith deceased purchased from one Eli <Eri[e]> Rhodes,
The North East quarter of section No. eight in Township no. six North of Range no. eight West in Illinois, except thirty seven (37) acres in the South East corner of said quarter section bounded as follows,
Commencing at the South East corner of said qr, thence East eighty rods, thence North seventy four rods, thence West eighty rods, thence South seventy four rods, to the beginning & took from said Rhodes and Bond for a Deed of said premises containing one hundred and twenty nine and one half (129½) acres
That said Smith deceased paid and caused to be paid to said Eli <Eri> Rhodes and to one Hugh Rhodes administrator of the estate of the said Eli <Eri> Rhodes deceased all the purchase money for said premises,
That at the time of such purchase and payment as aforesaid said Smith deceased was largely indebted to your Orators and others, and for the fraudulent purpose of hindering delaying and defrauding your Orators and other creditors of the said deceased in the collection of their said debts, combined and confederated with said to assign to said said Bond for a deed of said premises and said to procure a conveyance of said premises to said to be by him held for the use and subject to the control of said Joseph Smith deceased.