A review of the issue of court-ordered exemplars as a non-testimonial encompasses non-handwriting cases that support authority to compel handwriting exemplars, privilege against self-incrimination in handwriting exemplars, issues of search and seizure in handwriting exemplars, cases that address other constitutional issues, and cases not stating specific constitutional ground. Other cases surveyed have held that it is proper to request specific types of exemplars. Issues considered are exemplars obtained at different speeds and with the opposite hand and with a specific style. Other court cases surveyed deal with contempt of court and obstruction of justice, other consequences to a refusal or disguise of exemplars, and the propriety of expert testimony as to disguise in exemplars. An inference from this survey is that the courts, in upholding the compelling of handwriting exemplars, also uphold the reliability of the expert handwriting identification that will be made based on these exemplars. An index of cases cited