Docket entry 51, 17 October 2025 · source · PDF · 19 pages
Docket text. RESPONSE filed by Defendant Christian Eptingto Order to Show Cause,,, 46 (Attachments: # 1 Declaration of William J Becker Jr in support of response)(Becker, William) (Entered: 10/17/2025)
Cal. 2025) (imposing monetary sanctions where counsel denied using AI, refused to admit that the case was non-existent despite knowing it was non-existent, and where counsel had five opportunities to acknowledge error). In light of this guidance, we Case No.
In Hayes, the court imposed a $1,500 sanction where counsel submitted a fabricated case and quotation in a motion, then knowingly and persistently misrepresented the origin of those citations to the court.
Aug. 14, 2025), the court sanctioned counsel after the court discovered that in an “opening brief,” “well over the majority” of citations were either fictitious or misquoted. The court found a systemic failure of oversight in the firm’s brief-writing process, including reliance on AI without verification and failure to heed prior judicial warnings.
Cal. July 31, 2025), the plaintiff’s motion to remand cited a non-existent case, raising suspicion of AI use. Despite the filing’s defects and failure to disclose AI involvement as required by the court’s Standing Order, the court issued no sanctions, opting instead for an admonition and warning regarding future compliance.
Cal. July 31, 2025), counsel cited another fictitious case in support of a motion to remand. The court noted non-compliance with its AI disclosure rules but again imposed no monetary sanctions, instead cautioning that any further use of AI without disclosure would trigger further inquiry.
Jan. 22, 2025), where a motion contained multiple non-existent citations, likely AI-generated. The court declined to sanction the filer, emphasizing instead the need for future caution.
Id. (“The court cautions defendant that any further filings with citations to non-existent cases may result in sanctions”). Similarly, in Gibralter, LLC v.
Sept. 19, 2025), a court discharged an order to show cause without imposing sanctions because counsel conceded that a fictitious case reference “likely was the result of her use of AI-assisted research and drafting tools in drafting her opposition brief”, counsel acted with candor to the court admitting to using various research sources including AI, and counsel represented that she would implement “precaution to prevent future similar errors”. The court found an admonition was sufficient, and admonished counsel “to Case No.