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.
or belief of any such fraudulent conveyance or conveyances, as in said complainants’ bill alledged, at the time 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 in said Bill alledged, 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 state, each for himself that the conveyances from said Joseph Smith now deceased named in the paragraphs, severally, opposite to which their names are written on the margin with these words, “This paragraph relates to Respondant,” they verily believe were made bonafide to bonafide purchasers in said deeds respectively named as the grantees thereof, and for the valuable considerations actually paid at the several times thereof in said deeds respectively mentioned and without any fraudulent intent, design or purpose whatever or to hinder, delay or defraud the complainants, or any other person in the collection of any debt whatever.
And they further answer each for himself, that under the grantees in said deeds from Joseph Smith mentioned in said paragraphs to which their names are respectively written opposite, as aforesaid.
They respectively claim the premises in such conveyances described as indicated in such paragraph, by divers rights and conveyances bona fide obtained, all interest which said Joseph Smith deceased had in such premises; but which are too numerous and complicated to make exhibits of, and set forth in this answer.
These Respondants deny that said Joseph Smith deceased, at the time of his death, had any interest whatever in said South East qr. of section 2 Town 6 North Range 9 West of or in any of the premises in this answer mentioned and set forth.
These Respondants further state that their said purchases in this answer mentioned from, through and under said , while sole as aforesaid, and from through and under said and her said husband Lewis C. Bidamon after her said marriage with him, were made in good faith and for valuable considerations as before herein stated bonafide
That said purchases were made on account and by reason that the said conveyance in complainants Bill mentioned from said Joseph and , to said Joseph Smith as Trustee of [p. 542]