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 34, 2 March 2026 · source · PDF · 5 pages
Docket text. MOTION for Judgment [Defendants' Joint Motion for Entry of Final Money Judgment Pursuant to Order Granting Payment of Attorneys' Fees by James Martin Paul] by Jared Knecht. Responses due by 3/16/2026. (Attachments: # 1 Exhibit A - Email, # 2 Exhibit B - Assignment, # 3 Exhibit C - Proposed Final Judgment)(Bast, Jeffrey) (Entered: 03/02/2026)
6. On July 15, 2025, the Court entered an order (the “ Sanctions Order”) imposing sanctions on Attorney James Martin Paul (“Paul”), counsel for Plaintiffs, following Paul’s reliance on artificial intelligence (“ AI”) when generating court filings, leading to hallucinated cases and quotations. See Case No.
7. In addition to dismissing the Lawsuits, the Court ordered Paul to pay the attorneys’ fees for Defendants’ counsel for the time spent responding to any filing in which generative AI was used to develop hallucinated cases and fabricated quotations. See Sanctions Order at 21.
Docket entry 30, 2 December 2025 · source · PDF · 3 pages
Docket text. ORDER: Being fully advised, it is hereby ORDERED AND ADJUDGED that the parties shall, no later than December 22, 2025, confer in a good faith attempt to reach agreement on a reasonable payment plan and submit the same to the Court for review. In the event that the conferral is unsuccessful, the parties shall separately submit proposed payment plans by that date. No extensions shall be granted. The Court RESERVES JUDGMENT on 27 Defendants' Motion. Signed by Judge David S. Leibowitz on 12/2/2025. See attached document for full details. (wce) (Entered: 12/03/2025)
0:25 -cv-60646 unless otherwise stated. Case 0:25-cv-60646-DSL Document 30 Entered on FLSD Docket 12/03/2025 Page 1 of 3 responding to filings in which generative artificial intelligence (“AI”) was used to develop hallucinated cases and fabricated quotations. [ Id. at 20].
Docket entry 23, 25 July 2025 · source · PDF · 63 pages
Docket text. NOTICE REGARDING DISPUTED FEE AMOUNTS AND PROPOSED PAYMENT PLAN by Byoplanet International, LLC (Paul, James) (Entered: 07/25/2025)
Reduced to .00. 0 $0.00 Agree 0 $0.00 5/14/2025 JB Work on response to motion for protective order, including review of all cases cited by O'Shea, including fabricated cases 2.6 $825.00 $2,145.00 Objection - double billing. Reduced to a total of 2.00 from a combine 3.90 between JB and TMW.
Reduce to 1.50. 1.5 $427.50 Detailed review of response required extensive time to uncover, confirm and brief fabricated case law 5.7 $1,624.50 5/20/2025 MD prepare hearing materials on motion for protective order; 0.5 $275.00 $137.50 Agreed. 0.5 $137.50 0.5 $137.50 5/20/2025 JB finalize edits to ECI reply in support of motion to dismiss; preparation for hearing on motion for protective order, including review of discovery, response, cases cited, outline argument for same 1.9 $825.00 $1,567.50 Agreed.
Reduce to .80. 0.8 $228.00 Extensive review of fabricated case law required additional time to confirm serious allegations 0.8 $228.00 5/22/2025 JB Review and revise reply in support of J. Knecht motion to dismiss; correspondence with client group and further revise same for filing 0.9 $825.00 $742.50 Objection - duplicative billing with KT on 5.22.25.
Reduce to .40. 0.4 $330.00 Extensive review of fabricated case law required additional time to confirm serious allegations 0.4 $330.00 5/22/2025 MD Revise and file reply in support of J. Knecht's motion to dismiss in ByoPlanet district case 0.4 $275.00 $110.00 Agreed.
This task required extensive time to compile. 6.2 $1,891.00 6/20/2025 KT Strategize with team regarding supplemental brief and analysis of fabricated caselaw 0.1 $285.00 $28.50 Agreed. 0.1 $28.50 0.1 $28.50 6/23/2025 TMW Review and revise supplemental brief; review and revise affidavit of attorneys' fees 2.8 $305.00 $854.00 Objection - vague - which supplemental brief?
Gibson: 52.3 hours at $610 = $31,903 (23.3 hours and $14,213 for this case) Elizabeth Coutu: 2.6 hours at $330 = $858 (1.2 hours and $396 for this case) Totals: $40,804 Total Specific to Case # 0:25-cv-60647-DSL: $18,026 Case 0:25-cv-60646-DSL Document 23 Entered on FLSD Docket 07/25/2025 Page 43 of 63 6 EXHIBIT C Case 0:25-cv-60646-DSL Document 23 Entered on FLSD Docket 07/25/2025 Page 44 of 63 AI Hallucination Cases This database tracks legal decisions in cases where generativeAI produced hallucinated content – typically fake citations, butalso other types of arguments.
Click to Download CSV State Australia (17)Brazil (6)Canada (18)Germany (1) India (1)Ireland (2)Israel (21)Italy (1) Netherlands (2)New Zealand (2)South Africa (3) Spain (1)Trinidad & Tobago (1)UK (10)USA (140) Zimbabwe (1) Party Expert (3)Federal Defender (1)Judge (3) Lawyer (107)Paralegal (2)Prosecutor (1) Pro Se Litigant (113) From period: Q2 2023 Monetary sanction Disciplinary Referral Case Court /JurisdictionDate ▼PartyUsing AIAI ToolNature ofHallucination In Re CorMedixD.C.
DunnN.D. Alabama(USA) 23 July2025 LawyerChatGPTFabricatedcitations Damien Charlotin 1 2 Case 0:25-cv-60646-DSL Document 23 Entered on FLSD Docket 07/25/2025 Page 45 of 63 Case Court /JurisdictionDate ▼PartyUsing AIAI ToolNature ofHallucination McCarthy v. DEA3rd Circuit CA(USA) 21 July2025 LawyerUnidentifiedFabricatedcitation(s),misrepresentedprecedents In re Boy Illinois AC(USA) 21 July2025 LawyerUnidentifiedFabricatedcitation(s),misrepresentedauthorities In re Marla C.Martin N.D.
Docket entry 22, 17 July 2025 · source · PDF · 21 pages
Docket text. ORDER Dismissing Case / Closing Case. (Without Prejudice) . Any pending motions are DENIED as moot. All pending deadlines are TERMINATED. Signed by Judge David S. Leibowitz on 7/15/2025. See attached document for full details. (ar24) Modified text on 7/17/2025 (ar24). (Entered: 07/17/2025)
When a lawyer presents false information to a court, that lawyer violates his duties. This case presents an important issue (unfortunately one that is occurring more often): what sanctions should a court impose on a lawyer who repeatedly uses false, fake, non-existent, AI-generated legal authorities in the drafting of complaints, motions, and other filings ? Here, Plaintiffs’ counsel repeatedly regurgitated such “hallucinated” authority in eight separate but related cases.
However, AI is not yet a match for an actual litigator. Employing the euphemism-du-jour, AI regularly “hallucinates” entire cases and “hallucinates” quotations from real cases. See Sara Merken, AI ‘hallucinations’ in court papers spell trouble for lawyers , Reuters, https://www.reuters.com/technology/artificial-intelligence/ai-hallucinations-court-papers-spell- trouble-lawyers-2025-02-18/ (noting AI’s “penchant for generating legal fiction in case filings[.]”).
Timeline of Events 2 Beginning in March of 2025, James Martin Paul, Esq. (“Paul”), counsel for the Plaintiffs in the above-captioned cases and four other related cases filed in Florida courts (eight cases in total) , repeatedly used AI to hallucinate cases and quotations in his filings . Indeed, Paul admitted to using generative AI and not checking its outputs in each of the eight related cases.
On March 12, 2025, Paul filed a Complaint in the Circuit Court of the Seventeenth Judicial Circuit in and for Broward County, Florida (“the O’Shea Complaint”), Case No. CACE -25-003491, on behalf of Richard Patrick Michael O’Shea (“O’Shea”).3 In the O’Shea Complaint, Paul used AI to 2 The following timeline is a non- exhaustive recitation of counsel’s uses of AI that generated hallucinated cases and quotations. 3 To be clear, this Court’s Order refers to various cases in Florida state court only for background on Paul’s actions.
The Court is not sanctioning Paul for any actions taken in Florida state court. Case 0:25-cv-60646-DSL Document 22 Entered on FLSD Docket 07/17/2025 Page 4 of 21 5 generate at least two hallucinated cases. [Richard Patrick Michael O’Shea v.
CACE-25-003582, on behalf of Debt Dynamics, LLC (“the Debt Dynamics Complaint”). In the Debt Dynamics Complaint, Paul used AI to generate at least two hallucinated cases. [Debt Dynamics, LLC v.
Fla.)]. Paul used AI to generate hallucinated cases and quotations in the Third Federal Case Complaint. [ See id.
1-3]. As a Case 0:25-cv-60646-DSL Document 22 Entered on FLSD Docket 07/17/2025 Page 5 of 21 6 brief example of Paul’s use of hallucinated cases, he cite d “Merrill Lynch v. Hagerty , 808 So.
Docket entry 14, 30 May 2025 · source · PDF · 3 pages
Docket text. RESPONSE, RESPONSE TO ORDER TO SHOW CAUSE by Byoplanet International, LLC. (Paul, James) (Entered: 05/30/2025)
Counsel’s Inadvertent Reliance on Drafted Language The specific citations and quotes in question were inadvertently derived from internal draft text prepared using generative AI research tools designed to expedite legal research and brief drafting. These tools, while commonly used by legal practitioners, have known limitations, including the possibility of producing fictitious citations. Unfortuna tely, those limitations materialized in the instant response, and proper cross-verification was not conducted prior to filing.
Case 0:25-cv-60646-DSL Document 14 Entered on FLSD Docket 05/30/2025 Page 1 of 3 2 3. No Intentional Misrepresentation At no time did undersigned counsel knowingly or intentionally fabricate, misrepresent, or distort legal authority to the Court. The errors in the brief were the result of negligence in proofreading and citation verification, not a calculated attempt to deceive the Court.