fraud alleged must be of an extreme nature, that goes to one of the essentials of marriage.”); Stegienko v. Stegienko, 295 Mich. 530, 295 N.W. 252, 254 (1940) (noting fraud must be “of a nature wholly subversive of the true essence of the marriage relationship” to support annulment of marriage). Several courts have held that the nondisclosure of a prior marriage and divorce does not qualify as an extreme enough fraud to annul a marriage. See Attor, 894 A.2d at 88 (citing Gerard v. Distefano, 84 N.J.Super. 396, 202 A.2d 220 (1964) (“The nondisclosure of a prior marriage and divorce is not such a fraud, for it in no way impedes the carrying out of the marital obligations and does not go to the fundamentals of the relationship.”)); Hess v. Pettigrew, 261 Mich. 618, 247 N.W. 90, 92 (1933) (<HOLDING>). However, at least one jurisdiction has held
recognizing that basis for deportation was aliens misrepresentation about his marriage not the validity of his marriage holding that the law to be applied in determining the validity of  an outofstate marriage is the law of the state in which the marriage occurred holding concealment of prior marriage is generally not fraud justifying annulment holding that denial of leave to amend is error in the absence of justifying reasons holding husband could not have marriage annulled because wife was pregnant by him at time of marriage