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 104, 17 June 2026 · source · PDF · 7 pages
Docket text. REPLY in Support re 100 MOTION for Sanctions and MOTION for Contempt /to Certify Facts to the District Judge for Contempt, as to Defendant's Counsel Filing Confidential Information on the Public Docket, 102 Memorandum in Opposition, filed by Alyssa Mercante. (Green, Remy) (Entered: 06/17/2026)
Coleman has now admitted he used two LLMs to draft the letter at ECF No. 88: Westlaw’s, to get case names and summaries, and Claude to draft and apparently hallucinate the entirety of the citations. Mr.
Docket entry 103, 16 June 2026 · source · PDF · 21 pages
Docket text. REPLY in Support re 99 Memorandum in Opposition, Order on Motion for Leave to File, 96 Appeal of Magistrate Judge Decision to District Court,, filed by Alyssa Mercante. (Attachments: # 1 Declaration Reply Declaration of Remy Green, # 2 Exhibit Green Reply Ex. 1 - Email Thread, # 3 Exhibit Green Reply Ex. 2 - Westlaw AI Report, # 4 Exhibit Green Reply Ex. 3 - Westlaw AI Sources Tab, # 5 Exhibit Green Reply Ex. 4 - Westlaw AI Warning to "Never" Use AI Research Without Reading the Cases) (Green, Remy) (Entered: 06/16/2026)
3 iii. Counsel admits his representation to the Magistrate Judge that the citations were non-hallucination human errors was incorrect. ....................................................................... 4 iv.
4 iv. Counsel admits he cited A.M. without review and the LLM summary of A.M. was hallucinated. ............................................................................................................................ 4 b.
It offers a false account of how Westlaw’s AI offerings work, to attempt to explain away the fashion in which counsel used two LLMs to fabricate the case citations themselves, apparently deciding at the end that they needed no review because “Claude that supplied citation numbers that were plausible in form but wrong in fact[.]” Id. at 1.
2 As explained in more depth below, the Opp.’s denial that there were “hallucinations” rests on a fundamental misunderstanding of what a hallucination is. For now, suffice to say, Claude’s LLM inventing a citation from whole cloth, in a form that looks plausible, is exactly what the term of art “hallucination” refers to. 2 citations out of a Westlaw AI summary, plugged those into Claude’s chatbot, and had Claude generate briefing that invented the citations for those case names from whole cloth.
Before the Magistrate Judge, Mr. Coleman claimed the hallucinations in his papers were human-generated: He said, “I made mistakes when recording citations for four of the cases.” ECF No. 90 at 1.
He also — at least now — admits that “[v]erifying them was the undersigned’s obligation, and he accepts responsibility for failing it, without qualification.” Id. iii. Counsel admits his representation to the Magistrate Judge that the citations were non-hallucination human errors was incorrect. Next, counsel admits he now needs to “correct[] the record … in order to be entirely candid with the Court.” Opp. at 2.
Counsel was already confronted with this problem and the implausibility of his initial representation, and declined to correct the record in front of Judge Eshkenazi. As Plaintiff’s counsel pointed out at the conference, given the nature of the mistakes, that was simply and completely implausible that human error could have introduced the kinds of hallucinated citation at issue: “We have these citations where what he's saying is he transposed some numbers. … Like[, ‘]2008 West[l]aw’ [followed by a] string of numbers. But the two strings of numbers look nothing like one another.” 2026-05-11 Tr. at 35-36.
However, in the Opp. itself, counsel did not directly explain where they came from. As discussed further below, that is likely because the answer is far more damning that silence: Counsel dropped case names into Claude’s chatbot and Claude hallucinated the citations from whole cloth. iv. Counsel admits he cited A.M. without review and the LLM summary of A.M. was hallucinated.
Docket entry 89, 9 May 2026 · source · PDF · 6 pages
Docket text. MOTION for Order to Show Cause re: AI Citations and fact misrepresentations in ECF No. 88; asking the Court to disregard ECF No. 88 on the substance in light of the violation of the deadline and confidentiality order by Alyssa Mercante. (Green, Remy) (Entered: 05/09/2026)
To the extent the Court is inclined to give Defendant another last chance, Plaintiff Page 6 of 6 asks the Court to set a time for her to respond substantively. And in either event, since the last warning was not enough, it should issue an order to show cause about the continuing mis-citation and factual hallucination issues in Defendant’s papers, and award one additional hour of time on the fee application, to reflect the time Plaintiff had to spend dealing with the mass mis-citation in the letter at ECF No. 88.