It's often argued that disclosure of the knowledge of the existence and location of the subject of a discovery demand is itself testimonial. Sometimes, a court

It's often argued that disclosure of the knowledge of the existence and location of the subject of a discovery demand is itself testimonial. Sometimes, a court will partly agree and require accommodations to discovery, such as production through the deponent's attorney and precluding any disclosure of where the item or information came from. Perhaps a more likely outcome is sanctions, such as an adverse inference, costs, or even a directed verdict.