To establish civil contempt for failure to comply with a court order, it is not necessary to prove a specific intention to disobey the order. A deliberate commission or omission in breach of an order constitutes contempt unless it is casual, accidental or unintentional. The party alleging contempt bears the burden of proving beyond reasonable doubt that documents within the scope of a production order were in the alleged contemnor's possession, custody or power at the relevant time; proof of prior possession may found an inference of ongoing possession, but the alleged contemnor bears only an evidentiary onus to raise the issue that documents have been lost.
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