In Postill v. Postill, 116 Mich. App. 578; 323 N.W.2d 491 (1982), after the entry of a divorce judgment, the defendant husband received a judgment in his favor in a libel suit that had been pending during the marriage. Three years and eight months after the divorce judgment was entered, the plaintiff moved to have the divorce judgment set aside and to have half of the judgment in the libel suit awarded to her. Id. at 580. The trial court denied the plaintiff's motion. On appeal, the Court noted that the plaintiff's motion for relief from judgment was based on GCR 1963, 528.3(6) and was not timely made under that rule, which required that a motion for relief from judgment be made within one year after the judgment was entered. Postill, supra at 580. However, this Court then commented that a party seeking relief from a final divorce judgment entered several years earlier is ordinarily required to establish fraud on the court. Id. The Court noted that the plaintiff did not allege fraud in her motion, but held that, because the libel cause of action was known to both parties and was a matter of public record, the trial court did not abuse its discretion in concluding that no reason justified the setting aside of the divorce judgment more than three years after it was entered. Id. at 581.