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 he has no knowledge of any indebtedness of the said Joseph Smith deceased to the Complainants or any other persons, except as he is informed of the same by the said Complainants’ bill, nor has he any knowledge of the renedition of the said judgement, the issuing the s and the returns thereon, nor of said judgement remaining due and unpaid except from information derived from Complainants said bill, nor had he any knowledge, information or belief whatever of any of the matters in said Interrogatory mentioned and referred to, nor of any such indebtedness until within the last past three months, since which time he has learned only from said bill and rumor, that said indebtedness existed, and this is all the knowledge or information has has upon the subject and therefore requires proof of the same.
And further answering as to the 2nd. interrogatory in said bill propounded saith:—
That this defendant has no knowledge personally, of the matters and things mentioned and referred to but has been informed and believes that said Smith, di<e>d as in said bill alledged and left him surviving his and heirs as in said bill alledged, and that the Marriages took place as in said bill is alledged, that said infants named as defendants are such infants, and therefore admit the same to be true.
But this defendant has no knowledge and cannot state as to his belief or otherwise, what interest they have in the premises in said bill described, except as to Lot No. 1, 2 and 3 in Block 127 and Lot No 2 in Block 139 in the said City of mentioned and situate on said South East of sect No. 2 and as to which said lots this respondant answering saith: that the following are the facts thereto:
Respondant removed to said Illinois some time in November 1846, then being a stranger and having no knowledge of title to real estate in said City of , that one Caleb J. Thomas was then in possession claiming title in fee of the following of said premises to wit:
The North West 1/4 the South West 1/4 and the South East 1/4 of said lot No. 1 in Block 127 aforesaid,
That he then purchased of said Thomas said premises for the consideration of seven hundred dollars, which he then paid said Thomas therefor and obtained a deed from him of said premises and the possession thereof,
Which said deed of conveyance is hereto attached and marked “A” and made a part of this answer.
That said Joseph Smith and his wife on the 2nd. day of February in the year 1842, by their deed of conveyance duly executed, conveyed said premises for the consideration of three hundred and thirty seven dollars to , which said deed was [p. 575]