On December 12, 2019, the Virginia Supreme Court entered an unpublished opinion about “fraud on the court,” delineating intrinsic and extrinsic fraud, and emphasizing the need to plead fraud “allegations that would rise to the level of clear and convincing evidence”. The case is McClung-Logan Equip. Co. v. Harbour Constructions, Co., No. 181633, an appeal from Spotsylvania County Circuit Court.
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