Daniel Brown and Others, Answer, 21–23 November 1850 [United States v. Joseph Smith III et al.]
Source Note
and Joseph Sibley on behalf of Daniel Brown, Joseph Weisbrod, , John G. Kauffmann, Silas G. Strong, Abner Powers, Lewis Telle, and Peter Reimbold, Answer, [], Hancock Co., IL, and , Iowa Territory, 21–23 November 1850, U.S. v. Joseph Smith III et al. (United States Circuit Court for the District of IL 1852). Copied [ca. 17 July 1852] in Transcript of Proceedings, U.S. District Court for the District of Illinois, Complete Records, 1837–1856, vol. 4, pp. 548–561; handwriting of ; Records of District Courts of the United States, Record Group 21, National Archives at Chicago, Chicago. Includes seal.
That at the several times of the several purchases in this answer mentioned and set forth, they and each of them for himself say:—
That so far as said purchases were made by them respectively as shown by the deeds and exhibits herein before stated in this answer mentioned and described, the same were made bonafide and that the valuable considerations mentioned in said deeds to them respectively were then paid and without any knowledge or information or belief of any judgement, lien, encumbrance or debt in favor of complainants and against any of the premises in said bill described or against said Joseph Smith decd. or his estate, in any manner whatever or in favor of any other person or persons and without any knowledge, information or belief of any fraudulent conveyance, device, trust or any other matter or thing whatever, made, intended or done to defraud, delay or hinder the said Complainants or any other person or persons in the collection of any judgtment, execution, debt, or any other thing whatever in any manner or for any fraudulent purpose whatever.
And each for himself says:
That the same is strictly true as to the premises mentioned and conveyances named in the paragraph above to which his name appears opposite in the margin written with the words “This paragraph relates to respondant.”
And all of respondants are informed and believes the same to be true as to each and every of these respondants and as to the premises mentioned and conveyances named in each of the paragraphs in this answer above written and to which respondants names are severally in the margin written as above stated and these respondants deny so far as they have any knowledge, information, or belief that any of the conveyances in this their answer mentioned or alluded to or referred to were made for the purpose of hindering, delaying or defrauding the complainants or any other person or persons in the collection of any judgements, s or debt whatever or for any fraudulent purposes,
And each for himself positively denies any knowledge, information or belief of any such fraudulent conveyance or conveyances as is in said complainants’ bill alledged at the times of the said purchases respectively in this answer set forth.
And charge that so far as they are concerned their said purchases respectively were made in good faith and without any such notice or knowledge as in said bill alledged and without any other notice of any fraud whatever and for the valuable considerations actually paid, indicated and mentioned in the said several conveyances to them respectively made and herein before mentioned.
These respondants further state each for himself that the conveyances from said Joseph Smith now [p. 555]