Behind the Mask (1946). Not sure if this one has been posted online before. I saw it mentioned on the forum once and tracked it down. Quality is poor as you can see from the still and it's not a classic scene by any means, due to the horribly dingy lighting & rather hidden placement of the spankees behind railings - but the fact there are two women being spanked at least marks it as unusual. According to bostnbob's list, the spankers/spankees are: Kane Richmond/Barbara Read and George Chandler/Dorothea Kent.
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http://we.tl/SVQJZdQ7lw (4mb)
http://we.tl/SVQJZdQ7lw (4mb)