Martin Huber for the valuable consideration in said deed named, which said deed is herewith filed marked exhibit “D” and made a part of this answer.
And that afterward on the 1st. day of April A. D. 1850 the said Martin Huber by his deed of that date conveyed the same premises to respondant Anna Maria Ritter by the name of Maria Ritter for a valuable consideration in said deed named, which said deed is herewith filed marked exhibit “E” and made a part of this answer, by means of which said several conveyances, respondants are advised that all interest of the said Joseph Smith deceased became divested out of him, and all title of the said (now Bidamon) to said North half of lot 1 Block 117, became vested in respondant Ann Maria Ritter and she claims the same in fee.
These respondants further answering say:—
That at the several times of the several purchases in this answer mentioned and set forth say, that so far as said purchases were made by them as shown by the deeds and exhibits herein before in this answer mentioned and described the same were made bonafide and that the valuable consideration mentioned in said deeds to them respectively were then paid and without any knowledge, or information or belief of any judgement, lien, incumbrance or debt in favor of complainant and against any of the premises in said bill described or against said Joseph Smith decd. or his estate in any manner whatever or in favor of any other person or persons, and without any knowledge, information or belief of any fraudulent conveyance, device, trust or any other matter or thing whatever made, intended, or done to defraud, delay or hinder the said complainant or any other person or persons in the collection of any judgement, , debt or other thing whatever in any manner or for any fraudulent purpose whatever.
And these respondants deny so far as they have any knowledge, information or belief, that of any of the conveyances in this their answer mentioned or alluded to or referred to were made for the purpose of hindering, delaying or defrauding the complainants or any other person or persons in the collection of any judgements, executions or debt whatever or for any fraudulent purpose and positively deny any knowledge information or belief of any such fraudulent conveyance or conveyances as in said Complainants bill alledged at the time of the said purchase respectively in this answer set forth and charge that so far as they are concerned these said purchases respectively were made in good faith and without any such notice or knowledge as is 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 state, that the conveyance from said Joseph Smith now decd. they verily believe was made bona fide to bona fide purchases in said deed named as the grantee [p. 584]