A handwriting exemplar, in contrast to the content of what is
an identifying physical characteristic which falls outside the
protection of the
Fifth Amendment. It is not testimonial or communicative in nature.
Gilbert v. California, supra. The government may
evidence the fact that the suspect refused to provide an exemplar
directed to do so by a court. United States v. Askew, 584
F.2d 960, 963
(10th Cir. 1978), cert. denied, 439 U.S. 1132 (1979);
United States v.
Nix, 465 F.2d 90 (5th Cir.), cert. denied, 409 U.S. 1013
government may also introduce evidence that the individual
distorted his/her handwriting when giving the exemplar. United
Stembridge, 477 F.2d 874 (5th Cir. 1973).|