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innocent spouse issues and a trial memorandum to respondent by
June 24, 1994. The parties agreed to file status reports with
the Court by July 11, 1994. The Court accepted the parties'
settlement. After the settlement and Attorney Riley's agreement
to cooperate in the trial preparations, the Court vacated its
oral direction granting respondent's motion to partially dismiss
and deemed both respondent's motion to dismiss and petitioners'
motion to set aside the default to be moot. The Court issued an
order dated June 10, 1994, requiring petitioners to provide the
documents relating to the innocent spouse issues and trial
memorandum to respondent, and for the parties to file status
reports with the Court as agreed. That order expressly provided
that "all documents relating to the innocent spouse issues in
this case must be furnished to counsel for respondent by
petitioners on or before June 24, 1994." Respondent's motion to
compel production of documents, including those documents on the
innocent spouse issues, had been granted by the Court in October
of 1993, and petitioners still had not complied with the Court's
1993 orders.
On or about June 24, 1994, Attorney Riley provided
respondent with copies of various documents. Many of the copies
were illegible and many were items that petitioners previously
had denied possessing. Respondent ascertained that Attorney
Riley had other documents in his possession that had not been
provided, documents that petitioners had earlier denied
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