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possessing. Attorney Riley agreed to produce the additional
documents by July 15, 1994. Respondent also wished to review the
original documents from which the illegible copies had been made.
On July 11 and 12, 1994, the parties filed their status
reports with the Court, indicating they had not resolved the
innocent spouse issues. By order dated July 12, 1994, the Court
officially calendared the cases for trial during a special trial
session of the Court in Philadelphia, Pennsylvania, beginning on
August 22, 1994, and ordered that all exhibits not stipulated to
be exchanged on or before August 8, 1994.
On July 15, 1994, Attorney Riley's law clerk (the law clerk)
arrived at respondent's office with six boxes of records for
respondent's review. Respondent's counsel was able to review
only three boxes in the time the law clerk made himself
available. The law clerk declined to leave the remaining
documents with respondent's counsel, but agreed to return on
August 5, 1994. On August 2, 1994, Attorney Riley sent a letter
to respondent's counsel indicating the documents would be
available for review only in his office, a 2-hour drive from
respondent's office in Philadelphia. In a conference call on
August 3, 1994, the Court directed Attorney Riley to have the
remaining boxes delivered to Philadelphia for respondent's
review; this delivery occurred on August 5, 1994. On August 19,
1994, Attorney Riley provided respondent with documents relating
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