Transcript of Proceedings, , Sangamon Co., IL, ca. 17 July 1852, U.S. v. Joseph Smith III et al. (United States Circuit Court for the District of IL 1852); U.S. District Court for the District of Illinois, Complete Records, 1837–1856, vol. 4, pp. 486–697; handwriting of ; Records of District Courts of the United States, Record Group 21, National Archives at Chicago, Chicago.
But cannot state whether she did so or not, and now positively denies that said conveyance if ever signed by her knowledge or consent or with any intention on her part to convey the same or that said conveyance in law or equity operates as a conveyance of said premises or that she ever intended to convey said premises except to said Joshua Ward, as first aforesaid.
Respondant further positively denies that said Joseph Smith deceased purchased said premises or paid the purchase money or any part thereof or procured the same to be done or that said conveyance was made to her by his procurement or to hinder, delay or defraud his creditors.
And here positively states that said premises were purchased by Respondant for her own use with money presented to her by one and one or two other persons whom respondant does not now recollect, that said money was presented to her for her use and benefit and not for the use of said Smith.
And now positively denies that said Joseph Smith deceased ever had any interest in said premises.
And Respondant further says that all the conveyances herein before stated to have been made by her were made in good faith and for a valuable consideration, when of property of which she supposed she held title.
And respondent prays that the same may be sustained and the title thereto be adjudged to pass to the grantees thereof respectively.
Respondants further deny all and all manner of combinations and confederations wherewith they are charged.
And now having fully answered said bill and in answering said Bill fully responded to all of the interrogatories therein propounded
Respondants are ready to aver and prove the facts stated in this answer as the Court may direct, and pray that they may be discharged with their reasonable costs and charges herein expended.