nothing whatever has been received by them or has been paid upon the judgement herein before described in favor of your orators, that said judgement now remains wholly unpaid and unsatisfied.
Your Orators <further> show that the said Joseph Smith deceased, died seized of the following tracts of land, situated in the said County of and State of and lying West of the fourth principal meridian, to wit;—
1. The North West quarter of the South East quarter of section six, township five North of Range eight West.
2. The North West fractional quarter of section ten, township seven North, Range eight West.
3. The South West fractional quarter of section nineteen, township six North, Range eight West
4. The South East quarter of the South East quarter of section twenty six in township seven north in Range eight West.
5. The South West quarter of section twenty five, township township seven north, Range eight West.
6. The West half of the North East quarter of section thirty five in township seven North, Range eight West.
Your Orators further show that the said as administrator aforesaid of the Estate of said Joseph Smith deceased, applied to the Circuit Court of said , at its [blank] Term A. D [blank] while said was acting as administrator de bonis non aforesaid, for an order of said Court, authorising him to sell the real estate of the said deceased for the payment of the debts of the said deceased, and that such proceedings were therein had that an order was made by said Court authorising said sale, and the said pretending to act under [blank] said order, proceeded afterwards to make a pretended sale of said lands above described, and at said pretended sale struck off and conveyed the first tract of land above described to wife of the said for the pretended consideration of fifty dollars, and struck off and conveyed all the other tracts of land above described to one now a citizen of for the pretended consideration of four hundred and twelve dollars and fifty cents.
Your Orators further show, and so charge the fact to be, that no consideration whatever was paid for said lands or the conveyance thereof, by the said purchasers and , and that the said sale and purchase, and conveyance were made by fraud, and collusion between the said and the said purchasers, and for the purpose of hindering, delaying and defrauding your Orators and other creditors of the said Joseph Smith deceased, in the collection of their just debts against said deceased, and [p. 491]