-218-
F.3d 670 (7th Cir. 1995); Exh. 9047--Mem. Op. and Ord. of June
22, 1994, at 3-4.
During the June 22, 1994, hearing, Gallenberger explained to
the court that she produced very few documents because very few
of PSAC’s documents related to transactions between the subject
entities and PSAC. The District Court rejected Gallenberger’s
narrow interpretation of the summons and concluded the summons
fairly encompassed all the documents in the possession of PSAC in
any manner related to the Kanters or Kanter-related entities.
The District Court also 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, by order dated
June 22, 1994, held Gallenberger in contempt of court and granted
her until July 1, 1994, to purge herself of contempt by fully
complying with the court’s order. United States v.
Administration Co., 74 AFTR 2d 94-5256, at 94-5258, 94-2 USTC
par. 50,480, at 85,772; Exh. 9047--Mem. Op. and Ord. of June 22,
1994, at 4-5.
Gallenberger appealed the District Court’s order of June 22,
1994, holding her in civil contempt, to the Court of Appeals for
the Seventh Circuit. The Court of Appeals affirmed the District
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