laws of this state on due judgement of the Circuit Court of said and due proceeding had in the matter thereof, for the taxes, interest and costs due on the West half of lot 1 in block 147 in said in Complainants’ bill mentioned, purchased the same premises, in the ordinary course of public sales,
That said Bidamon afterwards assigned his certificate of purchase thereof to this respondant and afterwards, on the 20th. day of November 1850, this respondant obtained said Sheriff deed therefor, of which deed a copy is herewith filed marked (A) and made a part of this answer,
And respondant denies that said purchase was made for the purposes and with the intent in complainants’ bill charged or for any fraudulent, or illegal purpose whatever and he claims said premises in fee by virtue of said deed a copy of the record of which said judgement this respondant will produce to this honorable Court should the Court so award and direct,
Respondant further denies all and all manner of combinations or confederacies wherewith he is charged for any purpose whatever.
Respondant further says, as to that part of the Complainants’ bill which charges the situation of the records of Illinois &c were notice of the interest of said Joseph Smith deceased in said premises, are insufficient in law or in equity to require him to answer the same, and so to that part of said bill he demurs.
Respondant further says that as to all the rest and residue of said bill of Complaint and the things therein contained he has no interest and does not know the facts and circumstances either to deny or admit them.
And now respondant having fully answered the said Complainant bill of Complaint prays that he may be discharged with his reasonable costs and charges to be adjudged to him &c
D. W. Vrowman
Solicitor
<A>
Exhibit “A”
This Indenture made and entered into this twenty fifth day of April in the year of our Lord one thousand eight hundred and forty three, between Joseph Smith as sole trustee in trust for the Church of Jesus Christ of latter day Saints of the County of and State of of the first part and of the County of and aforesaid of the second part, witnesseth, that the said Joseph Smith party of the first for and in consideration of [p. 595]