This is sort of a follow-up to Is there a way to force apache to return 404 instead of 403? which suggested RedirectMatch to 404 to accomplish this.
RedirectMatch
It
Just after I posted my question, I came to a solution towards the following:
<Files>
.ht
Works like this:
<Files ~ "^\.ht"> Order Deny,Allow Allow from all Satisfy All Redirect 404 / </Files>