c. Defense is mistaken about the motion being late under 60B(2). The original decision by this court was appealed to the court of Appeals. The court of Appeals did not issue it’s mandate until August of 2012, so the plaintiff has a year since the mandate, until August of 2013, therefore she is not late filing her motion for reconsideration.
The rules are clear
A motion under Rule 60(b) must be made within a reasonable time—and for reasons (1), (2), and (3) no more than a year after the entry of the judgment or order or the date of the proceeding.