Joseph Smith and Sidney Rigdon fled Kirtland, on horseback to escape possible arrest there. Before leaving, the prophet dictates a revelation "concerning the trying of the First Presidency" which requires three unimpeachable witnesses and ratification of the decision by a majority of the church's stakes.
[Source: Broadhurst, Dale R., Mormon Chronology, http://olivercowdery.com/history/morchrn2.htm]
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