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of frivolous and tax-protester arguments, of noncooperation and
delay. Ms. Sluyter abetted that strategy by reiterating and
multiplying those frivolous and tax-protester arguments (see the
discussion infra in sec. III.B.3.b). We believe that there is
ample evidence that Ms. Sluyter conducted this litigation in bad
faith.8
b. Unreasonable and Vexatious Multiplication of
Proceedings
In sum, the following actions, among others, lead us to
believe that Ms. Sluyter unreasonably and vexatiously multiplied
the proceedings before the Court:9
Petitioners’ motions for protective order were made on
April 10, 2000, the day Ms. Sluyter entered her appearances. The
motions were signed by Ms. Sluyter. Those motions were made in
response to respondent’s discovery requests. We ordered
respondent to respond and, after considering that response,
denied the motions. In essence, the memoranda that accompany the
motions state that, until respondent proves that he has
8 Rule 201 (a) provides: “Practitioners before the Court
shall carry on their practice in accordance with the letter and
spirit of the Model Rules of Professional Conduct of the American
Bar Association.” (Model Rules.) Our finding that Ms. Sluyter
conducted this litigation in bad faith brings into question her
conduct under the Model Rules. See, e.g., Model Rules 3.1, 3.2,
and 3.3.
9 In relevant part, the term “vexatious” means to cause or
create, or intended to cause or create, vexation or annoyance.
The American Heritage Dictionary 1915 (4th ed. 2000).
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