1. The "Fraud on the Court" Circuit Split: Whether
the United States Court of Appeals for the Second
Circuit's restrictive interpretation of "fraud on
the court" under Federal Rule of Civil Procedure
60(d)(3)—which strictly limits relief to instances of
bribery or fabrication of evidence and categorically
excludes the intentional, strategic concealment of
dispositive documents by an officer of the court during
discovery—creates an untenable conflict with the
broader integrity-based standards adopted by the
Third, Sixth, and Ninth Circuits, and contravenes this
Court's foundational holding in Hazel-Atlas Glass Co.
v. Hartford-Empire Co. , 322 U.S. 238 (1944).

2. The Integrity of Voluntary Dismissals: Whether a
voluntary dismissal with prejudice pursuant to Federal
Rule of Civil Procedure 41(a)(1)(A)(ii) constitutes
a binding waiver of rights when it was induced
by the opposing counsel's fraudulent affirmative
representations of full discovery compliance, made
while simultaneously withholding "smoking gun"
evidence of whistleblower retaliation—specifically, a
defamatory "Security Alert" blacklisting campaign—
that was only revealed years later through collateral
litigation.

3. The Scope of the Saving Clause: Whether the "saving
clause" of Rule 60(d), preserving the judiciary's
inherent power to set aside judgments for fraud,
requires a showing that the fraud literally "defiled"
the court in a manner that the court itself could not
detect (the Second Circuit view), or whether it extends
to egregious misconduct by counsel that prevents
the opposing party from fairly presenting their case
and renders the judicial machinery an instrument of
injustice (the majority view).

Whether the Second Circuit's restrictive interpretation of 'fraud on the court' under Rule 60(d)(3) creates an untenable circuit split and contravenes Hazel-Atlas Glass Co. v. Hartford-Empire Co.