Hmm... I believe there may be a distinction here. Decrypting to the false virtual contents would be more like presenting a copy of the bank records that were co

Hmm... I believe there may be a distinction here. Decrypting to the false virtual contents would be more like presenting a copy of the bank records that were correct, but the file had been corrupted and the data was unusable. However, the corrupted but true records had been created before the subpoena (not trying to obstruct) and were handed over in good faith. You wanted the contents of this drive? Here they are! The owner of the drive is definitely in a legal and moral grey area, but it would be supremely difficult to prove mens rea in this case. Interesting thought experiment: What happens when someone fills a hard drive with junk data and then encrypts it, then gets subpoena'd for the unencrypted contents of the drive?