12.35—Consequences of a party's failure to comply with a discovery order.
         If a party fails to comply with an order compelling discovery, or an order issued pursuant to  § 12.34, the official assigned to render the decision in the case may, upon motion by a party or on his own motion, take such action in regard thereto as is just, including but not limited to the following:
    
    
    
        
        (b) 
         Rule that for the purposes of the proceeding the information in or contents of the documents or things not produced be taken as established adversely to the party;
    
    
        
        (c) 
         Rule that the party may not be heard to object to introduction and use of secondary evidence to show what the withheld documents or other evidence would have shown;
    
    
        
        (d) 
         Rule that a pleading, or part of a pleading, or a motion or other submission by the party, to which the order for production related, be stricken;
    
    
        
        (e) 
         Dismiss the entire proceeding with prejudice to matters alleged in the complaint, but without prejudice to counterclaims; and
    
    
        
        (f) 
         Issue a default order and render a decision against the party, whose rights shall thereafter be determined by  §§ 12.22 and 12.23 of these rules.