Clyde E. Owens and Marie W. Owens - Page 10

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          Court's standing pretrial order was attached to the Court's                 
          orders setting the cases for trial.  It provides that any                   
          documents or materials which a party expects to use at trial                
          (except to impeach), but which are not stipulated, shall be                 
          identified in writing and exchanged by the parties at least 15              
          days before the first day of the trial session.  The standing               
          pretrial order also notified the parties that the Court may                 
          refuse to receive in evidence any document or material not                  
          stipulated or exchanged, unless otherwise agreed by the parties             
          or allowed by the Court for good cause shown.                               
               Shortly before trial, petitioners moved for a continuance to           
          give them more time to get records from third parties.                      
          Petitioners' motion was granted.  The Court again served the                
          standing pretrial order on the parties on November 29, 1994, and            
          reset these cases for trial at the session beginning May 1, 1995.           
          On April 21, 1995, petitioners filed a second motion to continue.           
          Petitioners' motion was granted.  In their second motion to                 
          continue, petitioners alleged that respondent's agents had acted            
          improperly during the audit.                                                
               The Court again served the Court's standing pretrial order             
          on August 24, 1995, and reset the cases for trial at the session            
          beginning on January 29, 1996.  Respondent proposed stipulated              
          findings of fact to petitioners.  Petitioners did not respond.              
          Respondent filed a motion for the Court to order petitioners to             
          show cause why respondent's proposed stipulation of facts should            

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