Denehy

Plaintiff is a judgment creditor of "John Stewart and brings the action to set aside a deed made by said Stewart and wife to their codefendant, Mary E. Wickliffe, conveying to her certain land described in the complaint. It is alleged in the complaint that, at the time said deed was executed, to wit, December 22,1915, defendant Stewart was wholly insolvent and “the consideration named in said deed was the sum of ten dollars,” and that the land so conveyed was then and is now “reasonably worth the sum of five thousand dollars. ” It is further alleged, on information and belief, that said deed was executed “for a grossly inadequate consideration, with intent to hinder, delay, and defraud the creditors of the said John Stewart, including this plaintiff, and that the said defendant Mary E. Wickliffe accepted and received the said deed with knowledge of said fraudulent intent on the part of the said John Stewart and with the intent upon her part to assist the said John Stewart in his said fraudulent purpose, and to hold the said lands as a secret trust for the said John Stewart in order that he might occupy the same and receive benefits therefrom, regardless of his said creditors and…