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.
execute sundry deeds for portions of Land or Lots to divers persons and said Joseph Smith did together with said convey.
And said after the decease of the said Joseph did also convey sundry of said lots to divers persons
That said Smith as such trustee or agent did to some extent as such trustee or agent, control the sale of said town lots, but not otherwise,
Respondants deny that said conveyances or either or any of them were made for the purpose of hindering, delaying or defrauding the complainants or any other of the creditors of said Joseph Smith in the collection of their debts or in any fraud of the rights of the said complainants or of any other person, or persons.
Respondants admit as they are now informed, that said conveyances are recordered as in said bill alledged,
These respondants do not know nor can they state as to their belief or otherwise as to any other of the matter in said 7th. Interrogatory referred to.
And these respondants further answering as to Interrogatory No. 8 in said bill proupounded saith:—
That they do not know nor can they state as to their belief or otherwise as to any of the matter and things therein in said bill referred to.
And these respondants further answering as to interrogatory No. 9 say:—
That they do not know nor can they state as to their belief or otherwise, whether the said of the premises in the said bill described or any part thereof is entitled to be endowed thereof other than the premises herein before described as owned by these respondants and as to these premises respondants deny that she is entitled to be endowed therein or any part thereof.
And charge that since the death of said Joseph Smith that she has conveyed by deed in fee to these respondants all of said premises in said deeds from her described and which said deeds are herein this answer before referred to and made a part of the same.
These respondants deny all fraud, combination or collusion whatever of which he stands charged in the bill of Complainants.
Respondants pray that they may have the same benefit and advantages of any defence herein set forth the same as if such matters had been specialed pleaded.
And as to any and all matters in said bill contained and not herein fully answered, respondants do not know [p. 546]