Well you could make a header rule to look for a time in the date field between 20-24 or 0-6 and give them some points. But I would score it small and see how it pans out. I might try it for kicks this week.
I wouldn't use the Date: field; that can easily be forged. Instead, I'd probably write an eval function to check the Received: headers, to see when this host or this mail network *actually* got the mail.
--Kai MacTane
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