A District Court in Puerto Rico entered default against the Commonwealth for repeatedly failing to produce a full and accurate copy of the administrative record, as required by the IDEA. The First Circuit held that: “Although the question is close, we uphold the entry of sanctions against all defendants. The Commonwealth defendants’ argument that the IDEA does not specify a schedule for the delivery of the administrative record misses the point. What matters is that the district court twice ordered them to produce the record by a certain date and that they failed both times to come into full compliance with the court’s order. As to their argument that they did not act in bad faith, Rule 37(b)(2) allows for sanctions if a party ‘fails to obey an order to provide or permit discovery,’ and nothing in the rule requires that the failure be on account of bad faith. All of the defendants violated discovery orders either by missing clearly established deadlines or by representing to the court that they had complied fully with their obligations, even when their submissions (timely or otherwise) were incomplete, vague, or evasive. The court’s discovery orders explicitly warned defendants that failure to comply fully and on time would result in sanctions, including the striking of pleadings and the entry of default. Under these circumstances, the district court was within its discretion in imposing sanctions.” Diaz-Fonseca v. Puerto Rico,451 F.3d 13 (1st Cir. 2006).