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 566, 24 October 2025 · source · PDF · 15 pages
Docket text. MOTION for Reconsideration re; 562 Order on Motion for Sanctions, Order on Motion for Conference,,,,,,,, . Document filed by Susan Chana Lask. (Attachments: # 1 Supplement Memo of Law, # 2 Supplement Declaration).(Lask, Susan) (Entered: 10/24/2025)
2 The pattern persists in the October 9 order, which falsely accuses Lask of “fabricating law,” “inventing quotations,” and “vexatiously protracting” litigation by filing a sanctions motion and other intemperate remarks, without citing a single factual finding and without notice.
“misrepresentations and fabrications ”; 2. “invents quotations that do not exist”; 3. “vexatiously protracting this litigation” by her sanctions motion; 4.
Next, regarding Lask’s chart in DE 553 citing Robert Lewis Rosen Assocs., the Court asserts Lask deserves sanctions because she listed it as “Plaintiff inserted quotation marks around words that don’t exist in the case.” That was a harmless formatting error that does not constitute fabrication.
Kim Misstates the Law and Distorts the Record The Court mischaracterizes Lask’s argument for the Second Circuit’s Park v Kim as if she said sanctions are “mandatory” for AI Generated fake cases, and quotes her as Park “left no doubt that district courts must sanction fabricated citations.” However, her point was grounded squarely in Park that made clear: “A fake opinion is not ‘existing law’ and citation to a fake opinion does not provide a non-frivolous ground for extending, modifying, or reversing existing law, or for establishing new law.
Kim, 91 F.4th 610, 615 (2d Cir. 2024) Thus, fabricated citations constitute sanctionable misconduct under an attorney’s Rule 11 duties as a matter of principle because they violate the basic obligations of counsel. Id.
That was precisely Lask’s point. The Court’s strained interpretation of the word “must” transforms an accurate description of Park’s holding into a fabricated claim that Lask never made - namely, that sanctions are automatic in every scenario. Lask’s statement reflected Park’s clear principle, 6 not a mechanical rule.
Oct. 29, 2002), that, based on a Westlaw search of the given cite, appears not to exist.” Plaintiff never disputed that, nor did the Court in its October 9 Order identify any basis to treat those fabricated citations as acceptable, harmless, or ethically neutral. Instead, the Court redirected fault to the party who exposed the violation, labeling Lask’s accurate representation of Park as “incorrect” and accusing that “Lask’s own assertion of the law is fabricated.” That remark is unsupported by the record.
Further, that sanctions motion made clear that it was filed at that time exactly for the reason to avoid piecemeal filings as Plaintiff’s sanctionable conduct continued up to August, 2025. Cataloguing and researching law 8 for the continuing conduct was ongoing - including for the fabricated cases occurring in Plaintiff’s July and August filings. The October 9 Order also incorrectly asserts that sanctions were required to be filed by September 2024.
Docket entry 558, 25 September 2025 · source · PDF · 36 pages
Docket text. MOTION for Sanctions against Plaintiff Karn and her counsel Dollinger. Document filed by Susan Chana Lask. (Attachments: # 1 Supplement Memo of Law, # 2 Affidavit Susan Chana Lask, Esq., # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D, # 7 Exhibit E, # 8 Exhibit F, # 9 Exhibit G, # 10 Exhibit H, # 11 Exhibit I, # 12 Exhibit J).(Lask, Susan) (Entered: 09/25/2025)
25 1 I. INTRODUCTION This case has been defined by Plaintiff and her counsel Dollinger’s relentless obstruction: fabricating evidence, citing fake AI-generated cases, smearing counsel and Defendant as a “stalker,” and turning conferences into sideshows. On July 24, 2023, Dollinger detonated an eleventh-hour time bomb—accusing Defendant and her counsel of fabricating Exhibit 6.
Kim, 91 F.4th 610 (2d Cir. 2024) directs that sanctions are mandatory when fabricated cases or citations are submitted. Here, Plaintiff has submitted not one but dozens.
This cumulative approach is especially fitting in a multi-year case like this one. Indeed, the Court only recently—on August 26, 2025—addressed Plaintiff’s fabricated citations and meritless arguments. DE 551, 552.
Serial Fraudulent Filings (July–August 2025) i. Fictional Cases and Holdings (DE 526) and Refusal to Cease False Filings On July 30, 2025, Plaintiff moved to amend the judgment with contradictions and fictional citations—attributing quotes and holdings to nonexistent or inapposite authorities. DE 526-2.
Fabricated/misrepresented authorities, including: • Schipani (fake quote - “Where state law governs the underlying claim, post-judgment interest is also governed by state law,”; opposite holding); • Nken (immigration; unrelated to Rule 62(a), false quoted holding “the Court has discretion to lift or shorten that stay [62(a)]”-); • Briggs (about omission of interest, not calculating it), PCH Assocs.
Continued Fake AI-Generated Cases (DE 532-1) On August 4, 2025, Plaintiff again manufactured citations/holdings in her motion filings: • Harrison v. Brookhaven (nonexistent; fabricated holding in quotes- “(failure to appeal earlier adverse ruling waives right to relitigate under Rule 59(e)))” 4 • Karmely (fabricated holding as “(declining to consider issues not preserved through direct appeal).”, and a fake • Vesco (not about motions, fake quote of “A court may treat as a motion any written request for relief which calls for judicial action.” See Exhibit A for a table of Plaintiff’s fake citations. iii. False Attributions to the Court Record 1.
LAW AND ARGUMENT: AI-GENERATED FRAUDS Defendant’s opposition (DE 542 at 3) explained: “These distortions are not isolated. Defendant has repeatedly documented Plaintiff’s pattern of citing cases in previous filings that either do not exist or do not say what she claims—suggesting she is relying on AI-generated text known for its hallucinations … Courts sanction attorneys for these fraudulent filings. Citing Benjamin v.
DE 500 at 4. Defendant also showed at summary judgment that Plaintiff fabricated a proposition from G Investors Holding LLC, 2012 WL 446818 and misquoted Nw. Mut.