Respondants further answering say that he purchaseed the said several premises before mentioned without notice or knowledge or information of the indebtedness of the said Joseph Smith deceased or of his having or holding any interest in the said, then and there believing in good faith that he, the respondant was thereby obtaining the fee simple absolute title of said several premises free and discharged from all claims whatsoever and paid therefor in good faith, all the said several premises were then reasonably worth, that he paid for the same a good and valuable consideration in good faith, that he had no knowledge or information of said judgement against said Smith deceased as set forth in said bill
Respondant further denies all and all manner of combinations or confederacies wherewith he is charged for any purpose.
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 says that as to lot 3 in Block 138 aforesaid that if the said Joseph Smith deceased ever had any title to the same he conveyed the same to one by deed dated the 13th. day of September A. D. 1842 for the good and valuable consideration of $[blank] and in good faith, and not to hinder delay or defraud the creditors of the said Joseph Smith deceased,
Which said deed was recorded in the Office of the Recorder’s office of Illinois on the 2nd. day of June A. D. 1846 a certified copy of which will be produced as this honorable Court may direct.
And now the said respondant having fully answered the said complainants’ bill of complaint and the interrogatories prays that he may be discharged with his reasonable costs and charges to be adjudged to him &c
Luke P. Prentice.
Solicitor
United States of America)
ss [scilicet]:
District of )
Luke P. Prentice who made and signed the within answer being by me duly sworn says that the same so far as stated on his knowledge is true and so far as stated on [p. 602]