The answer of Evert L. Yates, Isaac S. Sanders and Napolean Perry defendants to the Bill of Complainant of the Complainants.
These defendants now and all times hereafter saving to themselves all and all manner of benefits and advantages of exception or otherwise that can or may be had or taken to the many errors, uncertainties and imperfections in the said Bill contained and here protesting, that said complainants have not shewn themselves entitled to any relief or equity as against these defendants for answer thereto or so much thereof as these defendants are advised it is material or necessary for them to make answer to.
Answering as to Interrogatory No. 1, in said bill propounded saith;— That they have no knowledge of any indebtedness of the said Joseph Smith deceased to the complainant or any other persons except as they are informed of the same by the said complainants’ Bill nor have they any knowledge of the renedition of said judgement and the issuing the executions and the returns thereon nor of said judgement remaining due and unpaid except from information derived from Complainants said Bill, nor had they any knowledge, information or belief of any of the matters in said interrogatories mentioned and referred to, nor of any such indebtedness until within the last past three [p. 524]