"I don't recall"
Moveon.com
Here's what will happen. First they'll ignore the court. Maybe file a challenge to the ruling. Basically stonewalling.
Then, if and when they eventually do get around to answering, you don't really expect them to say/write anything incriminating? {snort} They may be a-holes but neither they nor their lawyers are stupid.
The response, if any, will be some combination or variation of bland nothingness, or "I don't recall" or "gee we had that information, but it was lost in the fire at our home in Jan of '18."
Remember that one? I said at the time that was a convenient excuse to never produce any evidence ever again. Well, here's a perfect opportunity. Anything they are ever asked for will have been stored in that one room and irretrievably lost. Guaranteed.