We have caselaw previously cited in the Amicus Brief basically holding:
1) Courts are not to disregard fraud/fraud on the court, even if the aggrieved party did not exercise diligence in bringing it up.
2) Once it is established that a party has committed fraud/fraud on the court, that party is equitably estopped from any claim for relief.
This how we will defeat the meek "why wasn't this issue raised earlier?" defense. We cite cases and principles of law that nullify their sniveling nonsense.
It's not astrophysics. It's called The Law. And the law is about to become a stark, concrete reality for those who have broken it.