On the question of if the dismissal was premised on deception #LyingToTheJudge

• There is no requirement that a party
disclose or attach a settlement when it dismisses an action (p. 8) except the duty of candor to the court who was left very confused with the lack of even mention of a settlement (Doc 62)
• They point to Dominion v. Herring to prove that you can indeed close a case without a settlement of record — when one party is dying of Alzheimer's (pp. 8–9) — this was intended as a dig at the #SusmanGodfrey law firm, one of the firms resisting Trump's extortionate Executive Orders, was also on that case.
• The judge's pointing out there was no settlement of record is proof we didn't defraud the court and at that same time the judge was fully aware of the circumstances (p. 12) even though filing parties usually only consent to their requested dismissal with prejudice when they are getting something for it in a settlement.

On the question of whether the case should be reopened because the Court was the “victim of a fraud.” #FraudUponTheCourt

• You can't defraud the court if you hide everything the court needs to make a reasoned decision (p. 12)
• 'Sides even if we did mention we were about to get control of almost $2 billion in tax payers' dollars, what could the court do about it? (p. 8)
• Even if the court is a victim of a fraud, reopening the case can only lead to the closing of the case, no harm, no foul. (pp. 11–12, 13–14)