the said premises by them to her except what is stated in the said deed and that from said deed it appears and therefore insists that the said conveyance was upon a good and valuable consideration and that this defendant is advised by counsel and therefore insists that the consideration expressed in the said deed to have been paid to them for said conveyance was a full and adequate consideration for all the property, title and estate which passed to and vested in her, under and by virtue of the said conveyance.
This defendant further answering, from his best information and belief denies that the said Joseph Smith ever had any title, claim or interest in and to the said premises except what he may have derived therein as trustee as aforesaid by virtue of the said conveyance of himself and his said to himself as trustee as aforesaid.
And this defendant from his best information and belief denies that the said Joseph Smith ever purchased the said premises of the said or paid directly or indirectly any part of the purchase money therefor or that he procured the said deed from the said and his to be made to the said to defraud the complainants, as the creditors of the said Smith or any other creditors of the said Smith or to delay or hinder them in the collection of their debts, but that the purchase of the said premises was made by and for the use of the said , and the consideration was wholly paid by her in the manner herein before stated and that no part of the said consideration therefor paid, was paid by or received of or in any way furnished by the said Joseph Smith.
And this defendant further from his best information and belief denies that the said deed of the said Joseph and to the said Joseph Smith as trustee as aforesaid and the said deed from the said and as trustees as aforesaid or either of them were so made to defraud the Complainants as the creditors of the said Joseph Smith or any other Creditors of the said Smith, or to hinder, delay or defraud the Complainants or others as the creditors of the said Smith in the Collection of their debts, or that the said Joseph Smith ever directly or indirectly paid any part of the purchase money mentioned in the said conveyances.
This defendant further answering says:—
That whether or not the said Joseph Smith ever at any time had the possession of the said premises as is alledged in the said bill either in person or by his tenants before his death, this defendant has no knowledge or information except as he is informed by the said bill and can therefore neither admit nor deny the allegations of the complainants’ [p. 633]