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 73, 31 March 2026 · source · PDF · 36 pages
Docket text. ORDER that the Defendant's Partial Motion to Dismiss (Doc. 16 ) is GRANTED in part and DENIED in part. IT IS FURTHER ORDERED that Count VII is DISMISSED without prejudice. IT IS FURTHER ORDERED that Defendant's Motion to Strike (Doc. 18 ) is DENIED. IT IS FURTHER ORDERED that Defendant's Motion for Sanctions (Doc. 49 ) is GRANTED. The Court issues the following sanctions: Defendant shall file, within two weeks from the date of this order, its request for reasonable attorneys fees incurred in discovering the non-existent citations and quotations and briefing the Rule 11 motion for sanctions. The Court will then issue its awardholding Ms. Wright, Ms. Walters, IBF Law Group, PLLC, and The Law Office of Cortney E. Walters, PLLC jointly liableonce it has Defendant's cost figures.Within seven (7) days of the date of this order, Plaintiff's counsel shall serve a copy of this order on Plaintiff and file a Notice of Proof. Within sixty (60) days of the date of this order, Plaintiff's counsel shall file on the docket a declaration identifying and certifying their participation in a Continuing Legal Education course of at least one hour regarding the ethical use of artificial intelligence in the practice of law. The Clerk of Court shall serve a copy of this order on the State Bar of Arizona, of which Ms. Wright is a member, the State Bar of New Mexico, of which Ms. Wright is a member, and the Florida Bar, of which Ms. Walters is a member. The Clerk of Court shall serve a copy of this order on all the district judges and magistrate judges in this district. See document for complete details. Signed by Senior Judge G Murray Snow on 3/31/2026. (ALR) (Entered: 03/31/2026)
18). And third, Defendant seeks the imposition of Rule 11 sanctions on Plaintiff’s counsel—Sheree Wright and Cortney Walters—for citing to fabricated cases generated by artificial intelligence (“AI”) in multiple pleadings filed with the Court. (Doc.
49 at 3). On April 18, 2025, Plaintiff’s counsel signed and filed the initial complaint in this action and cited to a fabricated case: “E.E.O.C. v. Maricopa County Cmty.
Even though this case does not exist,11 Plaintiff’s counsel included the following detailed parenthetical describing the purported “holding” in the “case”: (denying motion to dismiss Equal Pay Act claim where plaintiff alleged that female employees performed substantially equal work under similar conditions and received lower pay than male employees, despite differences in job titles and descriptions; court held that “factual plausibility” under Twombly was satisfied by identifying c omparators and alleging disparity based on sex) (Id. at 21-22 n.2).
The Court thus will not strike the allegation. 11 The Court considers a case fictitious in the scenario where the Court inputs Plaintiff’s provided reporter number into a legal database and either (1) no result is found or (2) the given reporter number corresponds to a different case or authority. - 18 - Motion to Dismiss. (Doc.
20). In the reply, counsel again cited purported holdings from fictitious cases: No. Pleading Purported “Citation” Purported “Holding” 2 Doc.
21). That pleading, too, contained multiple fictitious citations: No. Pleading Purported “Citation” Purported “Holding” 5 Doc.
App. 5th 1069, 1091 (2016) Cited in support of Plaintiff’s assertion that “Courts consistently reject prejudice claims where defendants know the plaintiff’s identity and enjoy full discovery access.” - 20 - Defendant brought these fabricated citations to the attention of Plaintiff’s counsel through responsive filings. (Doc.
Plaintiff’s counsel subsequently signed and filed a Notice of Errata (Doc. 27) to amend the fictitious citations in the reply in support of Plaintiff’s Motion to Proceed Anonymously (Doc. 21) but did not simultaneously file any similar notice for the fictitious cases in the initial complaint (Doc.
Docket entry 50, 5 September 2025 · source · PDF · 27 pages
Docket text. RESPONSE in Opposition re: 49 MOTION for Sanctions filed by Jane Doe. (Attachments: # 1 Exhibit Exhibit A, # 2 Exhibit Exhibit B, # 3 Exhibit Exhibit C, # 4 Exhibit Exhibit D, # 5 Exhibit Exhibit E, # 6 Exhibit Exhibit F, # 7 Exhibit Exhibit G, # 8 Exhibit Exhibit H, # 9 Exhibit Exhibit I, # 10 Exhibit Exhibit J, # 11 Exhibit Exhibit K, # 12 Exhibit Exhibit L, # 13 Exhibit Exhibit M, # 14 Exhibit Exhibit N, # 15 Exhibit Exhibit O, # 16 Exhibit Exhibit P, # 17 Exhibit Exhibit Q, # 18 Exhibit Exhibit R)(Wright, Sheree) (Entered: 09/05/2025)
(Exhibit A-B). Citations labeled “case does not exist” in the served version, were recast in the filed motion as “case does not exist as cited,” conceding that the authorities exist but pivoting to a new argument based on misquotation. This is not a clerical correction; it is a substantive shift in legal theory.
It abandoned the core theory of its served motion. The motion served on Plaintiff accused counsel of citing non-existent and fabricated cases. When Defendant later filed its Rule 11 motion, it retreated from that rhetoric, acknowledging the cases exist and instead reframing the issue as one of AI-fabricated citations or quotation errors.
(Exhibit A-B). In the version served on July 30, 2025, the chart claimed “case does not exist” for each challenged citation. In the version filed with the Court, five of those entries were changed to read “case does not exist as cited.” That shift from nonexistence to misquotation is a categorical change.
Defendant’s Rule 11 Motion Now Accuses Plaintiff Counsel of Deception And Document Fabrication (Document 21) In its Rule 11 Motion filed with this Court, Defendant casts Doc. 21—the Reply in Support of Motion to Proceed Anonymously—as the centerpiece of its sanctions request, alleging it contained six fabricated case citations in the body and a sixth in the table of authorities. Defendant claims these citations either do not exist, contain falsified courts, dates, or citations, or misrepresent the actual holdings.
Specifically, Defendant also seizes on deeply personal matters, suggesting that counsel’s account of the sudden death of her dog was false or manufactured as a litigation tactic. In sum, Defendant accuses Plaintiff’s counsel of filing fake cases, fabricating evidence to this Court, providing shifting and implausible explanations, and even inventing personal tragedies, all to advance what they characterize as a pattern of deception. Defendant attempts to manufacture an issue out of a routine metadata difference between drafts.
The Complaint provides a factual and legal foundation for Plaintiff’s Equal Pay Act and § 1981 claims. The citation issue raised by Defendant—namely, that the case “does not exist”—is not true. Although the initial citation to E.E.O.C. v.
IV. No Fabricated Quotations Were Submitted to This Court Defendant’s claim that Plaintiff’s counsel submitted “fabricated quotations.” This is not true. The disputed language arose during the drafting process, which was handled by Plaintiff’s former law clerk, Karen Angulo.
In contrast to the extreme misconduct underlying those rulings, Plaintiff’s counsel conducted a good-faith, Lexis-based pre-filing investigation. The record reflects clerical citation errors—not fraud, fabrication, or reckless disregard for truth. A.
Docket entry 49, 26 August 2025 · source · PDF · 19 pages
Docket text. MOTION for Sanctions by Suns Legacy Partners LLC. (Attachments: # 1 Appendix A, # 2 Appendix B, # 3 Appendix C, # 4 Appendix D, # 5 Appendix E, # 6 Appendix F, # 7 Declaration of Jennifer L. Bryant, # 8 Exhibit 1, # 9 Exhibit 2, # 10 Exhibit 3, # 11 Exhibit 4, # 12 Exhibit 5, # 13 Exhibit 6, # 14 Exhibit 7, # 15 Exhibit 8, # 16 Exhibit 9)(Heinicke, Malcolm) (Entered: 08/26/2025)
They cited made-up cases and quotations in their filings to this Court, made implausible representations to the Court about how the fabricated authorities wound up in their filings, and falsely represented a cases ruling when purporting to correct a prior issue.
The only plausible explanation for these recurring issues is that Plaintiffs counsel used artificial intelligence tools without verifying their outputs. Courts routinely impose Rules 11 sanctions on attorneys who submit AI-fabricated authoritiesespecially where, as here, the attorneys fail to take responsibility for their conduct. Because Plaintiffs counsel have not adequately availed themselves of Rule 11s 21- day safe harbor, their misconduct is subject to Rule 11 sanctions even though the Court has now denied Plaintiffs motion to proceed anonymously, to which some of the filings related.
11(c)(2). For example, where Plaintiffs counsel had falsely attributed made-up language to a case, the purported correction only deleted the quotation marks. See Doc.
See id. In addition, Plaintiffs counsel have continued to offer shifting and implausible explanations for their submission of fabricated authorities. Defendant brings this Motion because it believes Plaintiffs counsels conduct must be acknowledged and addressed, and because counsels continued pattern of fabricated authorities and false representations to the Court is untenable, but defers to the Courts judgment on the form of appropriate sanction.
B. Fabricated Case in Complaint Plaintiffs counsel first submitted fabricated authority to this Court on April 18, 2025, when they signed and filed the Complaint in this case. The Complaint contained a citation to E.E.O.C. v.
C. Fabricated Cases in June 12 Filings The misconduct continued on June 12, 2025, when Plaintiffs counsel signed and filed (1) an opposition to a motion to dismiss, Doc. 20, and (2) a late reply brief in support of Does motion to proceed anonymously, Doc.
21. Both briefs contained fabricated citations to non-existent cases. The first brief, Plaintiffs opposition to Defendants motion to dismiss, contained two fabricated cases.
Doc. 20 at 12 n.11, 15 (citing the non-existent District of Arizona cases Pizzo v. City of Chandler and McIntyre v.