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.
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 hindering, delaying or defrauding the complainants or any other person or persons in the collection of any judgement, s or debts whatever or for any other fraudulent purpose,
And each for himself positively denies any knowledge, information or belief of any such fraudulent conveyance or conveyances as is in said complainants bill alledged at the time of their said purchases respectively in this answer set forth,
And charges 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 consideration 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 on the paragraph severally opposite to which their names are written in the margin with these words “This paragraph relates to respondants.”
They verily believe were made bonafide to bonafide purchasers in said deeds respectively named as theseGranters <Grantees> thereof and for the valuable consideration <actually> paid at the several times thereof in said deeds respectively mentioned and without any fraudulent intent, design, or purpose whatever, or to hinder or delay or defraud the complainants or any other persons in the collection of any debts whatever.
And they further answer each for himself that under the grantees in said deeds from Joseph Smith mentioned in said paragraph 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 bonafide obtained all interest which said Joseph Smith deceased had in such premises, but which are too numerous and complicated to make exhibit of and set forth in this answer.
These respondants deny that said Joseph Smith decd. at the time of his death had any interest whatever in said South East qr. of section two town 6 N. Range 9 West or of or in any of the premises in this answer mentioned and set forth. [p. 569]