on the part of this defendant that the said premises were or ever had been the property of the said Joseph Smith, or that he had or ever had had any interest therein as the owner in his own right legal or equitable and if this defendant had then been by reason of said deeds or from any other cause put upon e[n]quiry as to whether the said premises belonged in equity to the said Joseph Smith in his own right, he this defendant denies, that this defendant would on such inquiry have learned or understood that the said Smith was or ever had been the owner of said property, or that it was conveyed to the said to defraud the creditors of the said Joseph Smith deceased.
This defendant further answering denies all and all manner of combination, confederacy, or fraud wherewith he is charged in the said bill and now having fully answered the said bill so far as he is advised it is necessary or material for him to make answer unto, this defendant prays to be hence discharged with his reasonable costs &c.
Joshua Ward.
and
Solicitors
United States of America)
District & Circuit of Illinois)
ss. [scilicet]
This day Joshua Ward who signed the within and foregoing answer in personally appeared before Henry Ashbury Esq. a commissioner of the Circuit Court of the United States in and for the district of and being first duly sworn, says that the matters and things in his said foregoing answer contained, so far as they are therein stated of his own knowledge are true in substance and in fact and that so far as they are stated from the information of others he believes them to be true.
Joshua Ward
December 16th. 1850, Sworn to & Subscribed before me