While I am sure that Matsch's rulings on that point may make a differece in it's possible application in other matters before courts, I'm wondering if that issue may not profitably be raised in such matters as defense against debt collection. Let me put it into clearer context. GIVEN: A collection agency lawyer goes into court and because motions for summary judgement are pretty muchly a rubber stamp process, some lawyers get pretty sloppy and make serious errors simply because they can get away with it knowing that the debtor isn't likely to show up or know the difference anyway. But later down the road, the debtor gets some education and goes looking for such errors as a means to reopen and possibly reverse the judgement. Let's say that the debtor does find maybe 3 or 4 reverseable errors and files his own motion for summary judgement or maybe quiet title on a repossessed property because they used shortcuts in the original process. As a specific example, let's specify that one of the errors was that they took the original mortgage contract and whipped off a copy on their office copier and filed that as is instead of having it certified as a true and accurate copy nor did they present the original as evidence of the debt. Then lets throw in maybe 3 or 4 other serious errors as well. And let's say that they figured that the debtor would never be able to pay up anyway on the judgement, so they filed Lis Pendens instead of going for the full judgement. The debtor waits for the 5 years SOL on the Lis Pendens and the bank don't renew because after 5 years they just forgot about it. So the debtor "lies behind the log" for the 5 years and goes into court with a quiet title action based on the errors. Could one of his arguments or filings be that the creditor perpetrated a fraud upon the court and where could he logically or legally go with that if he wanted to carry it to it's extremes? Could the rulings of Matsch have any impact upon it's use in such matters as I am talking about here?