Professional Seminar Consultants, Inc., a Corporation v. Sino American Technology Exchange Council, Inc., and G.Y. Lin

EUGENE A. WRIGHT, Circuit Judge:

Professional Seminar Consultants, Inc. (PSC) sought sanctions against Sino American Technology Exchange Council (SATEC) and G.Y. Lin because they had produced falsified documents in this suit for conversion and libel. We find that the magistrate did not abuse his discretion when he entered a default judgment and punitive damages for PSC.

PSC conducts professional seminars abroad. In 1980, PSC paid SATEC to make tour arrangements for a doctor’s group *1472traveling to Hong Kong and China. G.Y. Lin, the owner of SATEC, agreed to handle all land arrangements, including…