That's what I remember. It would be unusual, especially in view of precedent (I think) but who knows?
No-one knows what the actual allegation is when it comes to non-cooperation, of course, so it's impossible to judge, really.
I have stated before that, personally, I think the non-cooperation will be around external witnesses and evidence, for the reasons I set out at the time, and so it becomes a question of whether the panel thinks the club were required by the rules to provide the information when it suited the PL (ie the investigation) or could wait until it suited the club (ie the panel).
Anybody's guess, that one.