The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.
Docket entry 38, 15 December 2025 · source · PDF · 13 pages
Docket text. MOTION for Sanctions by Beth Gellman Beer, Gadi Beer. Attorney Marc John Randazza added to party Gadi Beer(pty:dft). (Randazza, Marc) (Entered: 12/15/2025)
6(b)(2)(A), and 28 U.S.C. § 1927, for misrepresentations of fact and authority cited in Plaintiff’s pending Motion for Sanctions, which is itself frivolous. 1.0 INTRODUCTION AND FACTUAL BACKGROUND The Plaintiff filed a frivolous motion for sanctions that misrepresents the facts and that relies on case law that does not exist at all and nonexistent quotes from cases that do exist. It has the hallmarks of AI generated work, which is the most innocent explanation for it.
77.2 regarding extrajudicial statements concerning pending civil proceedings by issuing a press release about this Court’s order granting Defendants’ motion to dismiss. The Frivolous Motion relies on factual misrepresentations and hallucinated AI case law, which is not tolerated in Florida. See, e.g., Russell v.
The Motion certainly has violated § 1927, and should be sanctioned as such. Case 1:25-cv-23202-JB Document 38 Entered on FLSD Docket 12/15/2025 Page 2 of 13 - 3 - 3.0 ARGUMENT Courts despise the use of AI to produce inaccurate or fictitious case citations in a legal brief. See Russell v.
LEXIS 9332, at *12 (Fla. 2d DCA 2025) (referring lawyer for bar discipline for using hallucinated cases); Park v. Kim, 91 F.4th 610, 615 (2d Cir.
Ill. 2025) (imposing sanctions on attorney citing hallucinated cases and noting that claimed ignorance of how generative AI worked did not excuse attorney’s misconduct); Kohls v. Ellison, No.
Oct. 17, 2025) (“[t]he Court will not tolerate pleadings riddled with hallucinated citations masquerading as legitimate legal authority. This conduct undermines the integrity of the judicial process and disrespects and wastes the Court’s and Defendants’ time and resources”).
Id. at *5-6. “Courts in this District have found that sanctions are appropriate where counsel repeatedly used artificial intelligence to cite hallucinated cases and quotations.” Id. at *7 (citing ByoPlanet Int’l, LLC v. Johansson, 792 F.
P. 11 by “submitting a fake hallucinated case citation which allegedly supported a principle of law for which they were advocating”). The Papazian Court found that sanctions were appropriate against the attorney who signed a response to a motion to dismiss containing hallucinated cases and quotations because it was the signing counsel’s “duty to ensure that all legal contentions are supported by existing law.” Papazian, 2025 U.S.
Docket entry 37, 12 December 2025 · source · PDF · 35 pages
Docket text. RESPONSE in Opposition re 32 Plaintiff's MOTION for Sanctions and to Disqualify Defendants' Counsel for Extrajudicial Statements filed by Beth Gellman Beer. Replies due by 12/19/2025. (Randazza, Marc) (Entered: 12/12/2025)
The motion is based on demonstrably false assertions about what this Court ruled, what defense counsel said publicly, and what governing law permits. Even worse, every case that Plaintiff cites to support the request for sanctions for anything more substantial than an uncontested legal standard is either nonexistent or cites to hallucinated quotes. If we view this with charity, it means that the brief was AI generated and Plaintiff’s counsel did not check the cites.
In a bit of unexpected irony, by filing the Motion, Plaintiff and her counsel engaged in sanctionable conduct. The Motion’s legal argument is based primarily on fictitious cases or Case 1:25-cv-23202-JB Document 37 Entered on FLSD Docket 12/12/2025 Page 7 of 35 - 8 - quotations that are either hallucinations of generative artificial intelligence or deliberate attempts to mislead the Court. Either way, such conduct is sanctionable.
Either way, such conduct is sanctionable. Mere weeks ago, this Court dealt with the circumstances under which sanctions may be imposed for using AI to produce inaccurate or fictitious case citations in a legal brief. See Dubinin v.
Id. at *5-6. It noted that “Courts in this District have found that sanc tions are appropriate where counsel repeatedly used artificial intelligence to cite hallucinated cases and quotations.” Id. at *7 (citing ByoPlanet Int’l, LLC v. Johansson, 792 F.
P. 11 by “submitting a fake hallucinated case citation which allegedly supported a principle of law for which they were advocating”). The Papazian Court found that sanctions were appropriate against the attorney who signed a response to a motion to dismiss containing hallucinated cases and quotations because it was the signing counsel’s “duty to ensure that all legal contentions are supported by exis ting law.” Papazian, 2025 U.S.
Id. at *9-10. The following citations in Plaintiff’s Motion are either hallucinated or are deliberate attempts to mislead the Court: On page 5 of the Motion, Plaintiff quotes the following language from Florida Bar v. Norkin, 132 So.
2d 465 (Fla. 1992), claiming the Florida Supreme Court sanctioned a lawyer for comments that carried “ethnic and religiously charged overtones,” and that such statements violated Rule 4 - 8.4(d) because they “create prejudice and hostility inconsis tent with the standards of our profession.” This entire case appears to be hallucinated. The citation provided resolves to Dowling v.
6 Every other case citation is provided only for basic, uncontroversial propositions of law such as that courts have inherent authority to impose sanctions, that courts need to exercise restraint in imposing sanctions, that an attorney’s First Amendment rights are not unlimited, and that case-ending sanctions should rarely be imposed. Every single authority cited to explain specifically how Defendants’ alleged conduct is sanctionable is either hallucinated or egregiously misrepresented. Maybe this was due to reckless use of artificial intelligence, without realizing that it is prone to hallucinations.