(b) That the said bill of sale to this defendant was executed by the said Grochala in the form of a separate instrument from the said Grochala's land contract, under which he, the said Grochala, was purchasing said farm.

(c) That because of the fact that this defendant had not paid to the said Grochala the full purchase price of said farm, the latter had not assigned to him the said Grochala's contract of purchase of his said farm, which assignment was not to be made until the full purchase price of said farm was paid by this defendant.

(d) That at the time of the exchange between the parties hereto of their respective properties, as aforesaid, on the 20th day of June, 1917, this defendant had not paid to the said Grochala the balance of the latter's equity in said farm, for which reason the said Grochala had not given to the said defendant an assignment of the said Grochala's contract; that because of that fact this defendant informed the said plaintiffs that the said farm contract would be assigned to them by the said Grochala instead of being assigned to them by this defendant; that at the time of closing of said deal with the said plaintiff, Teofil Banski, one Jacob Gaffke and this defendant, together with the said real estate agents, Buczynski, and the said Wrybicki, all went together in an automobile to a bank in the Village of Richmond, Michigan, which is in the vicinity of said farm property, where they met the said John Grochala and thereupon completed an exchange of said property; that in making said exchange, this defendant paid to the said Grochala a certified check for $1,000, and $50.00 in cash; that upon receipt of that amount from this defendant, the said Grochala assigned his said land contract upon said farm direct to the said plaintiffs, which was done at the request of this defendant for the purpose of avoiding the execution of an unnecessary assignment of said contract, which would have been necessary had the said Grochala assigned the same to this defendant, and the latter assigned the same to the said plaintiffs; that upon receiving an assignment of said farm contract, the said plaintiffs delivered to this defendant an assignment of their property in said Village of Hamtramck and referred to in paragraph one hereof. That at the time of closing said deal, all of the parties hereto well understood and were perfectly satisfied with the terms and conditions thereof; that after said deal had been closed, all of the parties hereto, with the exception of the said Banski's wife, drove in said automobile to the said farm at the request of the said Teofil Banski, so that the latter could make certain arrangements regarding the necessary care of said farm and the live stock thereon; that thereafter, the parties hereto returned to the said village of Hamtramck, and the said plaintiff, Teofil Banski, repeatedly expressed himself as satisfied with the said purchase.

8. In answer to paragraph eight of said bill of complaint, this defendant denies that he ever stated to the said plaintiffs that he was related to the said Grochala, or that at the time of closing said deal the said plaintiff, Teofil Banski, expressed any dissatisfaction therewith. This defendant admits, however, as previously stated that after closing said deal, the parties hereto visited said farm property, but denies that at the time of so doing any inquiries were made regarding the value of said property.

This defendant also denies that he had no interest in said farm property, and denies that the live stock and farm implements on said farm were not worth over the sum of $100.00, but on the contrary, avers that the same was worth approximately $400.00.

9. In answer to paragraph nine of said bill of complaint, this defendant denies that he has ever, at any time, made any false representations to the said plaintiffs or any one else regarding said farm property or that the said plaintiffs were in any wise deceived or mislead by any statements which the said defendant made regarding said farm, and denies that the said plaintiffs have been defrauded or wronged in any way whatsoever. This defendant denies that the said farm is not worth more than $2,600, but on the contrary avers that the same, together with the personal property thereon, is worth approximately $5,000, and denies that the said defendant's interest therein were not over $600.00, but on the contrary, avers that the same was worth approximately $2,650, and this defendant denies that the equity of the said plaintiffs in the contract assigned by them to this defendant exceeded this defendant's Interest in said farm in any amount whatsoever, but on the contrary, avers that the interest of this defendant in said farm, and the personal property thereon was worth equally as much as the said plaintiff's interest in their said property, which was assigned to this defendant.

10. In answer to paragraph 10 of said bill of complaint, this defendant denies that the said plaintiff, Apolonia Banski, executed said assignment against her will, and denies that she had no voice in making said deal, but on the contrary avers that she had equally as much to say In arranging said deal as any of the other parties hereto. This defendant, however, avers that he has no knowledge regarding any statements made by the said plaintiff, Teofil Banski, to the said wife, or regarding the amount of money or property which she may have received from her said husband for executing her said assignment.

11. In answer to paragraph 11 of said bill of complaint, this defendant denies that the assignment of said contract for the sale of said farm by the said Grochala to the said plaintiffs was irregular or illegal in any respect, and on the contrary, avers that the same was in all respects properly executed and valid.

12. In answer to paragraph 12 of said bill of complaint, this defendant admits that some time after said deal had been closed, that the said plaintiffs tendered to him a small sum of money and requested a return of the assignment of their said property in the Village of Hamtramck, which was refused by this defendant as wholly uncalled for and unjustifiable, and for the further reason that this defendant had paid a consideration of $2,650 for the said plaintiffs' interest in their said property, which would be a total loss on his part if he should be required to re-assign to said plaintiffs their said land contract.