said last mentioned deed Lots 1, 2 and 3 on Block No. 116, Lot No. 4 on Block No. 142 Lot No. 3 on Block No. 143, Block No. 144, Lot No. 1 on Block No. 145, Lot No. 3 on Block No. 147, Lot No. 2 on Block No. 159, and Lot No.1 on Block No. 160, are located on said qr. section conveyed by said to Respondant as aforesaid and of which she then held the legal title.
That said lots were intended in good faith to be conveyed by said Church to said and others in said deed named, for their use and benefit and not to hinder, delay or defraud the creditors of Said Smith deceased.
Defendant and Lewis C. her husband claim to be interested in and the owners in fee of all that part of the quarter section last aforesaid which was conveyed as aforesaid by said to and which has not been conveyed by said to individuals as in this answer before particularly stated.
And also to be entitled to dower in all the lands of which her said husband died seized or possessed of an estate of inheritance or an equitable estate or of which he contracted for before his death and the title was obtained after his death, except such as she has released her dower as herein before stated.
Respondant claims an interest in all the property herein before stated to have been conveyed to him, and also the undivided fourth part of all the estate and effects of said deceased as heir at law.
Respondants , and respectively claim to own the premises hereinbefore mentioned as having been conveyed to them in common or severally and also an equal undivided fourth part each of all the estate and effects of the said deceased as heirs at law.
Respondants and Elisha Dixon claim to be the owners of all the property hereinbefore described as claimed by said and also all the other property herein stated to have been conveyed to said either in common with others or severally.
Respondants and Elisha Dixon further state all the conveyances made by said Joseph Smith deceased in his lifetime or by his procurement by others to said were made in good faith and for a good and valuable consideration and not with intent to hinder delay or defraud his creditors.
That at the time said Joseph Smith deceased adopted Respondant and about the year A. D. 1830, when said Joseph Smith deceased was solvant and long before the debt upon which the Judgement in said bill mentioned was obtained accrued, the said Joseph Smith deceased received a [p. 521]