An anecdote, an activist had a document in their Google Drive. It was not something people high up wanted being distributed. It was deleted not just from their account, but platform wide. Guess how they did that? Its hash.
It's not inconceivable, but you need to source it.
But let's not pretend this isn't a subtle backdoor that can invalidate the entire "E2E" implementation. I believe that in the US, having the filename and/or hash/checksum is most of what is necessary to trigger the Foregone conclusion doctrine and force the person to lose their 5th amendment protection and be compelled to decrypt their data to be used against themselves.
I'd like if someone with legal knowledge could comment if my understanding is correct.
Then again, they already have everyone's address books and iMessage traffic, so I guess they already have that data for most of the industrialized world. I wonder who else will preserve copies?