Law Lessons from Grinbaum v. Wolf, App. Div., A-4305-09T2, December 9, 2011:
Fraud upon the court is not a tort giving rise to a civil action for damages and trial by jury; it is an equitable remedy that affords relief from a judgment that may be accompanied by imposition of sanctions, such as attorney’s fees, that the judge has inherent authority to award. Triffin v. Automatic Data Processing, Inc., 394 N.J. Super. 237, 251-53 (App. Div. 2007); see also Triffin v. Automatic Data Processing, Inc., 411 N.J. Super. 292, 309-11 (App. Div. 2010).
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