“The law says you have to hand over requested documents or risk default judgment.”
So if I demand that you hand over non-existent documents and you don’t, then I win?
If the documents are non-existent then you can tell the court that. Discovery has existed for the entire history of our country. Not responding isn't the solution.
Had that happen in a case against the State of RI I litigated about 10 years ago. RI Superior Court Judge Sara Taft Carter put my client under Conditional Default for not producing documents that didn’t exist. Not appealable. Case settled later so no harm, no foul anyway