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So was thinking about the red rain rule for Maelstrom of Gore, and I came to a bit of a realisation. If I'm not missing something horribly here, the out-of-sequence attacks get around death frenzy, which requires the death to happen in the fight sub-phase. Could this be something of a counter to wulfen for armies that both rely on cc, and have access to such attacks? IIRC the orks start collecting bundle has a similar ability.

Possibly. The issue is, you still have to actually hurt the Wulfen significantly in that one out-of-turn phase.