OPINION
KAPLAN, Justice.
This mandamus proceeding involves a discovery dispute resulting in the imposition of "death penalty" sanctions. The issue before the trial court was whether the document production on July 19, 1990, complied with the trial court's order dated October 31, 1989. Without hearing any evidence, the trial court determined that the defendants had abused the discovery process and entered an order establishing their liability to plaintiffs...
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