Well stated, alm. And that is where we are going. Interestingly, the cases are legion holding that perjury in and of itself is usually insufficient for Rule 60 relief on grounds of fraud. But with the cropped table angle, we have fraud by officers of the court, which brings the argument very much into play.
And even if the Court is not inclined to grant Rule 60 relief on basis of the fraud/fraud on the court, we have the grounds of mistake. Hopefully by pointing out the statistical defects in the application and reliance upon Kurbayashi and Mori, the Court can grant Rule 60 relief on the grounds of mistake.
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