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.
That said John Seller, on the 10th. day of May A. D. 1849 by his deed of that date, conveyed the same portion of said premises and in said deed described to Respondant Louis Stuts which deed is herewith filed marked “U” and made a part of this answer.
Whereby as respondants are advised all interest of said Joseph Smith to said lots 4 in Block 121 and lot 4 in Block 116 became divested out of him.
These Respondants further answering say:—
That at the several times of their several purchases in this answer 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 bonafide.
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, incumbrance, 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, divers, 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, execution, debt, or other thing whatever in any manner, or for any other 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 these 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 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 Judgement, or debt whatever or for any other fraudulent purpose.
And each for himself positively denies any knowledge, information, [p. 541]