Investment Research Associates - Page 147




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         much like a registered agent and a document repository, but                   
         existing primarily for the Kanters' benefit.  Gallenberger knew               
         that most of the documents held by Principal Services were                    
         related to Kanter entities.  The District Court concluded that                
         Gallenberger's sampling of documents did not discharge her duty               
         to make all reasonable efforts to comply with the court's order.              
         Finding a "glaring deficiency in her compliance," the District                
         Court held Gallenberger in contempt of court and granted her                  
         until July 1, 1994 to comply fully with the court's order.  Id.               
         at 5258, 94-2 USTC �50,480 at 85,770.  Gallenberger complied with             
         the District Court's order of June 22, 1994, but appealed the                 
         order to the Court of Appeals for the Seventh Circuit.  The Court             
         of Appeals affirmed the District Court's order in United States               
         v. Administrative Enters., Inc., 46 F.3d 670 (7th Cir. 1995).43               
              The trial of these cases commenced on June 13, 1994.  At the             
         start of the trial, respondent's counsel indicated that subpoenas             
         duces tecum had been served on various entities for documents                 
         that were to be produced at that time.  Counsel for IRA and                   
         Kanter informed the Court that the subpoenas requesting documents             
         from IRA, BWK, Inc., Carlco, and TMT had been served on                       
         Gallenberger, but that Gallenberger was not the custodian of the              

          43                                                                           
               The Court of Appeals stated: "It is apparent that the                   
          Government is interested in transactions in which Kanter and his             
          family and their investment vehicles are involved and not just in            
          the terms of the custodianship arrangement."  United States v.               
          Administrative Enters., Inc., 46 F.3d 670, 673 (7th Cir. 1995).              





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