- (a) take as established, to the disadvantage of the recalcitrant party, specified facts related to the matter at hand;
- (b) prohibit the recalcitrant party from introducing the evidence concerning which the discovery request was made; or
- (c) take such other action as may be proper in the circumstances.
If a party fails or refuses to comply with a directive to disclose material, or renders incomplete or substantially misleading responses, the presiding officer may: