inquiry, and that upon such inquiry he would have learned that the said Joseph Smith deceased was the real owner of said premises. and that they were conveyed as aforesaid to said for the purpose of defrauding the creditors of said Joseph Smith deceased
Your Orators further state that they are informed and believe that Noah Butler, J. C. McIntosh, and Jacob Jones citizens of the State of Solon Stark and James H. Mulholland citizens of the State of , David T. Le Baron, , and citizens of , William Tames and S. J. Holliness head citizens of the State of , William H. H. Mulholland, a citizen of the State of and Richard M. Mills a citizen of the State of all non-residents of the State and District of , claim some interest in the aforesaid premises but to what part your Orators are not informed and cannot state and pray that they may severally and respectively be made parties to this bill and required to answer the same, whenever they shall be found within the jurisdiction of this Court.
Your Orators further state that they are informed and believe that the said defendants and Lewis C. Bidaman, claim that the said is entitled to be endowed of the one third of all the lands of which the said Joseph Smith deceased died seized and also wherein the said deceased had an equitable estate at the time of his death and also of all the lands herein described, of her right to which you Orators are not informed and cannot state.
Your Orators further state that they are remidiless at law, that there is no personal estate of the said deceased out of which to make their said debt, and that the title of the real estate of which the said deceased died seized has been by the several acts above stated, so clouded that it could not be sold for its fair value or to advantage to the said estate.
Your Orators therefore pray that this Court will take jurisdiction of this cause and grant unto your Orators a writ of Subpoena herein to the said defendants, , and Infants, and Lewis C. Bidaman her husband, and Elisha Dixon her husband, John M. Ferris as administrator of the estate of said Joseph Smith deceased, Solomon Krine, James Downing, Mr. Shifkin, John Tillson, Sophus K. Holstein, Henry Swank, Michael Baegel, C. Witsel, N. Perry, Silas G. Strong, Isabella Hickox and Leonard Hickox, her husband, Anton Wittick, J. L. Hanna, W. Hanna, George Smith, The unknown heirs of J. Bixler, deceased, Mary Egan and John M. Egan her husband, Michael [p. 502]