Denise G. Callahan, "Insufficient evidence of extrinsic fraud leads to reversal in W." Daily Record and the Kansas City Daily News-Press, October 7, 2005, found at Find Articles website. "In the best interest of a child, the state of Missouri defended a mother who fooled a man into thinking he had fathered a son. In State of Missouri ex rel. Misty Lowry v. Richard Carter, the Department of Social Services, Family Support Division appealed Jackson County Judge Sandra Carol Midkiff's ruling that set aside a 1993 default paternity judgment against Carter. The Western District Court of Appeals sided with the state." Retrieved September 15, 2008.
jstor.org
"Equity Jurisdiction: Enjoining Execution of Criminal Judgment: Extrinsic and Intrinsic Fraud", California Law Review, Vol. 11, No. 4 (May, 1923), pp. 279-282, found atJSTOR website. Retrieved September 15, 2008.
Ellett v. Ellett, No. 0824-00-2, Virginia, (Cir. Ct. Richmond City 2001), with cases cited therein, found at Virginia state courts website. Retrieved September 15, 2008.