Your orator further states and cha[r]ges that said Joseph Smith jr in his lifetime about the year AD 1841, contracted with one Erie Rhod[e]s now deceased for certain real estate of which the said Erie Rhods was seized in fee to wit the Northeast quarter of section No eight in township six north of Range eight west of the fou[r]th principal meridian except thirty seven acres out of the southwest corner of the same and described as follows being the south seventy five rods wide of the west half of said quarter section containing one hundred and twenty nine & one half acres, also twenty four acres out of the southwest corner of the Northwest quarter of section No nine in said township range and meridian for the consideration of the sum of fifte[e]n hundred and thirty five dollars, and the said Erie Rhodes then executed to the said Joseph Smith his obligation in writing to the said real estate to the said Joseph Smith in fee simple on the payment of the consideration mony aforesaid and your orator charges that the said Joseph Smith did pay the consideration mony aforesaid for said land and was thereon in his lifetime duly entitled to a deed of conveyance to him & his heirs from said Rhods thereupon and your orator chargs that the said Joseph Smith then being indebted to your orator for the debt aforesaid and then being largely in debted to other persons and wholly insolvent & continuing & intending fraudulently to place the same beyond the reach of his creditors to delay and hinder them in the collection of their said debts and to save the same to his own use [p. [6]]