It was either a sorority famed on The Hill Far Above in my youth for its parties (ah, my misspent youth! I spent it studying law), or my shorthand for subpoena duces tecum (which I called by a rude, schoolboy name). But it was well to know that discovery device, and Judge Christian N. (“Speedy”) Weiler has a short course in how to respond, and what happens if you don’t.

Of course, Green Valley Investors, LLC, Bobby A. Branch, Tax Matters Partner, et. al., Docket No. 17379-19, filed 9/19/23, are back to illustrate, bringing with them those well-known appraisers V and W (names omitted), who’ve often appeared in this my blog when Dixieland Boondockery is on the menu.

V and W each was served with a SDT, and neither moved to quash nor asserted defenses. But IRS claims they didn’t cough up. So Judge Speedy Weiler lays down the law.

Let each provide “proof that he has produced the documents requested by respondent in accordance with the subpoena… or with an explanation for why he has failed to respond or otherwise does not have possession, custody, or control of the requested documents.” Order, at p. 2.

But if contumacious, “failure to adequately respond to this order may cause the Court to exercise its power to compel his deposition or hold him in contempt of court. See I.R.C. § 7456(c).” Order, at p. 2.

Now both Messrs. V and W are represented by counsel, upon whom Judge Speedy Weiler directs service of this order.

And whom else would you want when confronted with “ten runs to make and a match to win, a bumping pitch and a blinding light, an hour to play and the last man in”? The Jersey Boys, of course. And Frantic Frank Agostino, Esq., the last man in.

Just his kind of case.