Docket entry 87, 4 February 2026 · source · PDF · 9 pages
Docket text. ORDER ADOPTING MAGISTRATE'S REPORT AND RECOMMENDATION; (Show Cause Response due by 2/25/2026.); granting in part and denying in part 71 Motion for Attorney Fees; Adopting 75 Report and Recommendations. Certificate of Appealability: No Ruling Signed by Judge David S. Leibowitz on 2/4/2026. See attached document for full details. (nan)
Finding none, the Court adopts the R&R. 1 In addition, the Court must acknowledge what appears to be Plaintiffs’ frequent use of artificial intelligence (“AI”) to generate hallucinated citations and quotations. To the Court’s count, Plaintiffs cited non- existent authorities, misquoted cases, and misrepresented court orders over fifty times.
Case 0:24-cv-60911-DSL Document 87 Entered on FLSD Docket 02/04/2026 Page 2 of 9 3 and citations are accurate” [ECF No. 75 at 5], Plaintiffs continue to put forth nonexistent and mischaracterized authority before this Court. It is well-settled that Rule 11 of the Federal Rules of Civil Procedure “applies equally to pro se litigants.” Grimshaw v.
The timeline of events makes this abundantly clear. The first time Defendant and this Court noticed Plaintiffs’ potential hallucinated citations was in Plaintiffs’ response to Defendant’s Motion for Attorneys’ Fees. (For the sake of brevity, the Court highlights just a few of the countless examples from this submission.) In that response, Plaintiffs cited Parekh v.
But none of the cases contain the quoted material that Plaintiffs cited. Moreover, Plaintiffs cited several cases that simply do not exist: Lopez v. Bank of Am., N.A., No.
75 at 4–5]. She correctly underscored that Plaintiffs cited several non-existent cases and misattributed quotes to others like Parekh. [ Id. at 4].
Although Judge Augustin- Birch did not recommend sanctions at the time, as this was ostensibly pro se Plaintiffs’ first time having their citations called into doubt, Her Honor instructed Plaintiffs to “ensure that all of their caselaw quotations and citations are accurate.” [ Id. at 5]. Plaintiffs utterly failed to heed that warning and continued to misrepresent the Court using hallucinated citations. Indeed, i n their objections to the R&R , Plaintiffs doubled down on providing fake and hallucinated case citations and quotations.
[See id.]. Plaintiffs do this with numerous other citations in their objections and continue to deceive the Court with fabricated authority and quotations. [Compare, e.g., ECF No.
1994). Case 0:24-cv-60911-DSL Document 87 Entered on FLSD Docket 02/04/2026 Page 5 of 9 6 that “[c]ourts must exercise extreme restraint in awarding attorneys’ fees against pro se litigants ,” which does not exist in the case)]. It gets much worse.