Not clear what the specifics of the order here is, but the catch is he could risk being found in contempt of court or guilty of obstruction of justice depending on the circumstances. A subpoena is a court order compelling either testimony or the production of evidence. If you then go and make up a bunch of new stuff for the purposes of frustrating that court order you could find yourself in some difficulties.

That said, there is such a thing as "malicious compliance" ie complying with an subpoena by supplying the evidence requested in as unhelpful a format as possible. One that I heard of is in a suit related to the Madoff case, Madoff was compelled to produce records of phone calls made from his company and personal phones, so provided thousands of pages of very blurry scanned image pdfs in order to make it difficult for prosecutors (and the trustees, who were working to recover the funds) to OCR them and decipher who he had called. In the end they managed to do this nontheless.