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EFTA01333221
cites Ramil v. Keller, 68 Haw. 608, 726 P.2d 254 (1986), and }loves, v. Elliott, 167 U.S. 409, 17 S. Ct. 841 (1897), in support of his argument. In Ramil, the Supreme Court of Hawaii upheld litigation-ending sanctions after the defendants refused to comply with discovery orders. 68 Haw. at 621, 726
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