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 information of said bond except from said complainants’ Bill.
And respondants are informed and believe and charge the facts to be that said Joseph Smith never paid any thing whatever of the consideration money for said land or caused or procured the same to be paid and never had any equitable interest therein
But that the consideration money was wholly paid and contributed by and other member of said religious Society intending thereby to purchase the same for the sole benefit of the said and her children or them and said religious society.
That the said Joseph Smith was at the time and long after continued to be the sole agent and trustee of said religious society.
That said tract of land was laid out into town lots at the time in said bill alledged by said Smith and others while acting as such Trustee or Agent.
That said Joseph Smith did as such Trustee or agent execute sundry deeds for portions of land or lots to divers persons and said Joseph Smith together with said did convey to divers persons.
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 to some extent did 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 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 any other person,
Respondants admit as they are now informed that said conveyances are recorded 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 propounded saith:—
That they do not know nor can they state as to their belief for knowledge or otherwise as to any of the matter and things therein, in said bill referred to.
And these Respondanats 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 other than premises herein before described as owned by these respondants [p. 559]