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.
mentioned and set forth they and each of them for himself say that so far as said purchases were made by them respectively as shown by the deeds and exhibits herein before in this answer mentioned and described the same were made bona fide, and that the valuable consideration mentioned in said deeds to them respectively were then paid and without any knowledge or information or belief of any judgement lien, encumbrance or debt in favor of complainants and against any of the premises in said bill described or against said Joseph Smith deceased or his estate in any manner whatever or in favor of any other person or persons and without any knowledge, information or belief of any fraudulent conveyance, device, trust or any other matter or thing whatever made, intended or done to defraud delay or hinder the said complainants or any other person or persons in the collection of any judgement, , Debt or other thing whatever in any manner or for any fraudulent purpose whatever
And each for himself says:—
That the same is strictly true as to the premises mentioned and conveyances named in the paragraph above to which his name appears opposite in the margin written, “with the words “this paragraph relates to respondant.”
And all of Respondants are informed and believe the same to be true as to each and every of them Respondants and as to the premises mentioned and conveyances named in each of the paragraphs in this answer above written, and to which Respondants’ names are severally in the margin written as above stated.
And these Respondants deny so far as they have any knowledge, information or belief that any of the conveyances in this their answer mentioned or alluded to or referred to, were made for the purpose of hindering, delaying or defrauding the complainants or any other person or persons in the collection of any judgements, executions or debt whatever, or for any fraudulent purpose.
And each for himself postively denies any knowledge, information or belief of any such fraudulent conveyance or conveyances as in said complainants Bill alleged, at the times of their said purchases, respectively in this answer set forth and charge that so far as they are concerned their said purchases, respectively, were made in good faith and without any such notice or knowledge as is in said Bill alleged and without any other notice of any fraud whatever and for the valuable considerations actually paid indicated and mentioned in the said several conveyances to them respectively made and before herein mentioned.
These Respondants further states, each for himself that the conveyances from said Joseph Smith now deceased named in the paragraph severally opposite to which their names are written [p. 529]