Your Orators further state that the said Joseph Smith deceased in his lifetime and while he was so indebted as aforesaid to your Orators purchased from one John Cleveland the following property situated in Illinois to wit;
The North half of the North West qr. of section No. four.
Also the North West qr. of the North East qr.
Also the West half of the South half of the North West quarter and the North West qr. of the South West qr. of the North East qr. of said section No. four in township No. two South of Range eight West of the four principal meridian in , containing about two hundred acres of land.
And caused the same to be conveyed to said defendant by the name of then Wife of said Joseph Smith deceased,
That afterwards in the lifetime of said Joseph Smith deceased, the said Joseph Smith and said his wife made a pretended deed of said premises to said Joseph Smith as sole trustee of said Church of Jesus Christ of Latter day Saints,
That upon the purchase of said premises by said Smith as aforesaid said Smith went into possession of said premises and continued in possession thereof until his death.
And that said widow of said Joseph continued in possession of said premises until the year 1846.
That about the year 1845, and Trustees of said Church of J. Ch. of L. D. S. as the same pers in office of said Joseph Smith deceased as such trustee, made a pretended deed of conveyance of said premises to the said .
All of which said several pretended conveyances your Orators are informed are recorded in the Recorder’s Office of the County of in the State of , and were made as aforesaid without any consideration passing from said Church to said or from said to said Church, and for the fraudulent purpose of hindering, delaying and defrauding your Orators in the collection of their said debt.
That afterwards and about the year A.D. 1846 the said in the name of , conveyed said premises to said defendant Joshua Ward who is now in possession of said premises, claiming title thereto,
And your Orators charge that said Ward purchased said premises with full notice of the interest aforesaid of said Joseph Smith deceased in said premises or with a knowledge of the aforesaid several conveyances which were sufficient to put him upon [p. 501]