His Honor Big Julie, better known as His Honor Judge Julian I Jacobs, hereinafter HHBJJJIJ, reaches back for a State Court remedy and finds it in Rule 104(e)(3).

Amnesty National, Docket No. 4570-17, filed 4/26/18, isn’t a first-timer at 400 Second Street, NW, although it’s been years between appearances.

IRS claims the documents it seeks are necessary to prepare a defense for the trial. HHBJJJIJ buys it, especially as Amnesty has been ducking IRS’ counsel.

So here are the sanctions HHBJJJIJ will lay upon Amnesty if the documents aren’t forthcoming: “…the issues to which respondent’s discovery request pertain shall be taken as established in this case as set forth in (and petitioner will be prohibited from offering evidence to rebut the determinations made in) the notice of deficiency issued to petitioner, …the assignments of error set forth in the petition will be struck, and … such other and further relief as the Court deems proper.” Order, at p. 2.

Of course, in the days of my youth such a drastic remedy was rarely if ever imposed in State Court.