The Court of Session said the Scottish government repeatedly missed dates to disclose information requested by FOI.
It comes after leader Kenny MacAskill told members that the pro-independence party was in a "perilous financial position".
The Scottish Labour leader claims the government has a "dangerous obsession with secrecy and cover-up".
Scottish Information Commissioner David Hamilton says written evidence he requested by 15 January was not handed over.
The Scottish government has been ordered to publish some of the written evidence from an investigation into whether Nicola Sturgeon broke the ministerial code.
Insolvency firm Begbies Traynor has named a trustee in sequestration to handle the former first minister's estate.
The former first minister's estate is seeking sequestration, the Scottish legal equivalent of bankruptcy.
The Alba Party said it had discovered "a number of internal financial and administrative irregularities".
The former first minister's relatives are seeking a reported £3m in damages and loss of earnings from the Scottish government.
