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Cojom v. Roblen
(2025)
Case details
Full caption
CONNECTICUT MILTON ROBINSON TELETOR COJOM v. : : ROBLEN, LLC
Country
United States
Jurisdiction
Connecticut (CT)
Court
Connecticut Supreme Court
Decided
2025
Majority
Hall (Justice)
1
UNITED
STATES
DISTRICT
COURT
DISTRICT
OF
CONNECTICUT
MILTON
ROBINSON
TELETOR
COJOM,
:
CIVIL
CASE
NO
.
Plaintiff,
:
3:
23
-
CV
-
1669
(JCH)
:
:
v.
:
:
ROBLEN,
LLC.
f/d/b/a
VICOLO
PIZZA
:
NOVEMBER
17,
2025
RESTAURANT,
and
VIKTOR
BERISHA,
:
Defendan
ts
.
SANCTIONS
ORDER
I.
INTRODUCTION
In
the
instant
action,
plaintiff’s
counsel
David
P.
Stich
submitted
a
Memorandum
in
Opposition
to
Defendant’s
Motion
to
Set
Aside
Default
(Doc.
No.
46)
(“Opposition
Brief”)
containing
multiple
fabricated
citations
to
legal
authority
resulting
from
the
use
of
Descrybe.AI,
an
artificial
intelligence
based
legal
research
tool.
See
Declaration
of
David
P.
Stich,
Esq.
In
Response
to
Court’s
Order
to
Show
Cause
(“Stich’s
Response”)
(Doc.
No.
52).
In
doing
so,
Attorney
Stich
abdicated
his
responsibilities
under
Rule
11
of
the
Federal
Rules
of
Civil
Procedure.
The
court
must
now
consider
what
sanctions
are
proper
for
an
attorney
who
submits
a
pleading
containing
“hallucinated,”
i.e.
,
fake,
citations
to
the
court
in
violation
of
Federal
Rule
of
Civil
Procedure
11
.
II.
FACTUAL
&
PROCEDURAL
BACKGROUND
The
court
assumes
familiarity
with
the
general
factual
background
of
the
instant
action,
focusing
instead
only
on
the
events
pertinent
to
the
papers
containing
fabricated
citations.
Plaintiff
commenced
this
action
on
December
23,
2023,
alleging,
inter
alia
,
that
defendant,
in
his
capacity
as
owner
and
operator
of
a
pizza
restaurant,
willfully
failed
to
pay
minimum
wage
and
overtime
to
the
plaintiff
in
violation
of
the
Fair
Labor
Case
3:23-cv-01669-JCH
Document
54
Filed
11/17/25
Page
1
of
7
2
Standards
Act,
29
U.S.C.
§
201
et.
seq.
(“FLSA”)
and
the
Connecticut
Minimum
Wage
Act,
Conn.
Gen.
Stat.
§§
31
-
68
(“CMWA”).
See
Complaint
(“Compl.”)
(Doc.
No.
1).
The
defendant
was
served
with
the
Summons
and
Complaint
on
January
8,
2024,
but
thereafter
did
not
appear,
answer,
or
otherwise
defend
against
the
lawsuit,
culminating
in
a
Default
Judgment
entered
on
April
11,
2025.
See
Certificate
of
Service
(Doc.
No.
9)
;
Default
Judgment
(Doc.
No.
36).
Defendant
thereafter
moved
for
vacatur.
See
Motion
to
Set
Aside
Default
Judgment.
(Doc.
No.
39).
Plaintiff
opposed
the
Motion
to
Set
Aside
Default
Judgment,
submitting
the
Memorandum
at
issue
in
this
Order.
In
preparing
its
Ruling
on
the
Motion
to
Vacate,
the
court
identified
certain
citations
to
legal
authorities
in
the
plaintiff’s
Opposition
Brief
that
were
nonexistent.
Upon
suspicion
that
the
defective
citations
were
the
product
of
artificial
intelligence
(
“AI”),
the
court
issued
an
Order
to
Show
Cau
se
addressed
to
Attorney
Stich.
See
Order
to
Show
Cause
(Doc.
No.
49).
In
that
Order
to
Show
Cause,
the
court
identified
three
cases,
purportedly
from
this
District,
which
the
court
could
not
locate
despite
its
best
efforts.
Id
.
A
Show
Cause
Hearing
was
set
for
September
9,
2025.
1
Id
.
On
July
28,
2025,
Attorney
Stich
filed
a
Declaration
in
response
to
the
Order,
admitting
to
the
use
of
an
AI
tool
in
generating
the
defective
citations.
See
Stich’s
1
The
court
is
aware
that,
in
a
separate
proceeding
in
this
District
before
Judge
Stefan
R.
Underhill,
Davila
v.
Roblen,
LLC
et
al.
,
3:23
-
cv
-
00512
-
SRU
,
Attorney
Stich
is
also
subject
to
another
Order
to
Show
Cause
for
filing
a
brief
containing
AI
generated,
nonexistent
legal
authority.
See
3:23
-
cv
-
00512
-
SRU
,
Order
to
Show
Cause
(Doc.
No.
81).
In
his
Affidavit
in
response
to
the
Order,
Attorney
Stich
admitted
to
use
of
the
same
tool
at
issue
in
this
action,
Descrybe.AI.
See
3:23
-
cv
-
00512
-
SRU
Declaration
of
David
P.
Stich,
Esq.
In
Response
to
Court’s
Order
to
Show
Cause
(Doc.
No.
83)
at
¶
3.
A
Show
Cause
Hearing
has
been
scheduled
in
that
case
for
October
28,
2025.
See
3:23
-
cv
-
00512
-
SRU
Notice
of
E
-
Filed
Calendar
(Doc.
No.
82).
That
brief
was
filed
on
the
same
day
as
the
brief
at
issue
in
the
instant
matter.
Case
3:23-cv-01669-JCH
Document
54
Filed
11/17/25
Page
2
of
7
3
Response
(Doc.
No.
52).
Stich
expressed
“sincere
and
unreserved
apology”
for
the
nonexistent
citations
and
explained
that
it
was
his
first
use
of
an
AI
tool.
Id
.
at
¶
1.
Stitch
stated
that
,
in
using
the
AI
tool,
he
recognized
certain
cases
it
referenced
from
his
prior
exposure
to
vacatur
motions
and
that
this
familiarity
provided
“a
false
sense
of
confidence
in
the
AI
tool’s
accuracy.”
Id
.
at
¶
5.
He
assumed
that
the
remaining
citations
and
legal
authorities
were
also
valid
and
admitted
that
such
“assumption
was
mistaken
and
deeply
flawed.”
Id
.
Attorney
Stich
explained
that
he
is
“committed
to
ensuring
that
this
type
of
error
does
not
recur
and
to
maintaining
the
highest
standards
of
acc
uracy,
candor,
and
professionalism
in
[his]
future
conduct
before
this
Court
and
all
others.”
Id
.
at
7.
At
the
Show
Cause
Hearing
on
September
9,
2025,
Attorney
Stich
evinced
similar
contrition
and
acknowledgment
of
responsibility.
He
explained
that
he
learned
of
the
tool
from
his
daughter,
herself
a
practicing
lawyer
of
10
years.
His
daughter
told
Attorney
Stich
that
the
tool
“works
great”
and
is
touted
as
uniquely
effective
for
legal
practitioners.
While
Descrybe.AI
has
both
free
and
paid
functionalities,
Attorney
Stich
had
purchased
a
license
for
the
tool
,
which
he
has
since
canceled
.
As
a
result
of
t
he
hallucinated
citations
in
both
this
matter
and
in
the
separate
proceeding
before
Judge
Underhill,
see
supra
n.1,
Attorney
Stitch
stated
he
would
cease
all
use
of
artificial
intelligence
in
his
legal
practice
.
While
Attorney
Stitch
is
presently
a
solo
practitioner,
he
explained
that
he
will
ensure
no
one
in
his
employ
in
the
future
will
use
AI.
Moreover,
in
the
intervening
time
since
these
hallucinated
citations
were
first
identified,
Attorney
Stich
has
undergone
CLE
coursework
on
the
subject
of
AI
tech
nology
and
its
Case
3:23-cv-01669-JCH
Document
54
Filed
11/17/25
Page
3
of
7
4
risks.
He
offered
no
excuse
for
his
failure
to
check
the
citations
and
stated
this
foray
into
AI
generated
legal
authority
is
his
first
and
will
be
his
last
.
III.
LEGAL
STANDARD
Rule
11(b)(2)
states:
“By
presenting
to
the
court
a
pleading,
written
motion,
or
other
paper
—
whether
by
signing,
filing,
submitting,
or
later
advocating
it
—
an
attorney
or
unrepresented
party
certifies
that
to
the
best
of
the
person’s
knowledge,
information,
and
belief,
formed
a
fter
an
inquiry
reasonable
under
the
circumstances:
.
.
.
the
claims,
defenses,
and
other
legal
contentions
are
warranted
by
existing
law
or
by
a
nonfrivolous
argument
for
extending,
modifying,
or
reversing
existing
law
or
for
establishing
new
law
.
.
.
.”
The
filing
of
papers
“without
taking
the
necessary
care
in
their
preparation”
is
an
“abuse
of
the
judicial
system”
that
is
subject
to
Rule
11
sanction.
Cooter
&
Gell
v.
Hartmax
Corp.
,
496
U.S.
384,
398
(1990).
Rule
11
creates
an
“incentive
to
stop,
think
and
investigate
more
carefully
before
serving
and
filing
papers.”
Id
.
“Rule
11
‘explicitly
and
unambiguously
imposes
an
affirmative
duty
on
each
attorney
to
conduct
a
reasonable
inquiry
into
the
viability
of
a
pleading
before
it
is
signed.’”
AJ
Energy
LLC
v.
Woori
Bank
,
829
Fed.
App’x
533,
535
(2d
Cir.
2020)
(summary
order)
(quoting
Gutierrez
v.
Fox
,
141
F.3d
425,
427
(2d
Cir.
1998)).
IV.
DISCUSSION
Artificial
intelligence
is
a
rapidly
developing
technology
that
continues
to
permeate
more
and
more
facets
of
everyday
life.
The
court
understands
that
,
in
issuing
this
Order,
it
does
so
in
a
proverbial
new
frontier
as
society
begins
to
grapple
with
both
the
power
and
potential
danger
of
this
technology.
Indeed,
state
and
federal
courts
around
the
country
have
begun
confronting
the
phenomenon
of
so
-
called
“hallucinated”
citations
in
court
papers
—
that
is,
citations
to
legal
authority
that
are
either
partly
or
wholly
nonexistent.
See
,
e.g.
,
Sanctions
Order,
Johnson
v.
Dunn
,
No.
2:21
-
CV
-
1701
-
Case
3:23-cv-01669-JCH
Document
54
Filed
11/17/25
Page
4
of
7
5
AMM,
2025
WL
2086116
(N.D.
Ala.
July
23,
2025)
(Doc.
No.
204);
Opinion
and
Order
on
Sanctions,
Mata
v.
Avianca,
Inc.
,
678
F.
Supp.
3d
443
(S.D.N.Y.
2023)
(Doc.
No.
54)
;
Kruse
v.
Karlen
,
692
S.W.3d
43,
52,
54
(Mo.
Ct.
App.
2024)
;
Findings,
Rulings
and
Order
Imposing
Sanctions,
Smith
v.
Farwell
,
No.
2282CV01197,
2024
WL
4002576
(Mass.
Super.
Feb.
15,
2024)
.
See
also
,
Park
v.
Kim
,
91
F.4th
610,
615
-
16
(2d
Cir.
2024)
(referring
counsel
to
court's
disciplinary
committee
for
investigation
for
citation
to
a
non
-
e
xistent
case
in
reply
brief).
The
presence
of
AI
hallucinated
citations
in
court
papers
is
troublesome
for
obvious
reasons.
As
Judge
Castel
stated
in
his
Sanction
Order
in
Mata
:
“M
any
harms
flow
from
the
submission
of
fake
opinions.
.
.
The
Court’s
time
is
taken
from
other
important
endeavors.
The
client
may
be
deprived
of
arguments
based
on
authentic
judicial
precedents.
There
is
potential
harm
to
the
reputation
of
judges
and
courts
whose
names
are
falsely
invoked
as
authors
of
the
bogus
opinions
and
to
the
reputation
of
a
party
attributed
with
fictional
conduct.
It
promotes
cynicism
about
the
legal
profession
and
the
American
judicial
system.
And
a
future
litigant
may
be
tempted
to
defy
a
jud
icial
ruling
by
disingenuously
claiming
doubt
about
its
authenticity.”
678
F.
Supp.
3d
at
448
-
49.
These
concerns
are
distinctly
felt
here
as
Attorney
Stich
was
representing,
in
his
own
words,
“a
young,
scared,
and
vulnerable
immigrant
worker”
against
a
defaulted,
pro
se
defendant.
Opposition
Brief
at
12.
Attorney
Stich’s
client
was
deprived
of
arguments
based
on
legitimate
judicial
precedent
and
his
pro
se
opponent
was
forced
to
contend
with
arguments
based
on
phony
law
without
the
benefit
of
legal
representation.
The
danger
of
Attorney
Stich’s
AI
use
is
especially
felt
he
re
because
his
opponent’s
pro
se
status
meant
that
there
was
not
an
adversary
capable
of
calling
the
attention
of
the
court
to
the
phony
citation
s
.
Furthermore,
this
court
expended
time
and
resources
in
investigating
the
hallucinated
citations,
resources
that
could
have
been
better
spent
adjudicating
the
merits
of
this
underlying
litigation
and
that
Case
3:23-cv-01669-JCH
Document
54
Filed
11/17/25
Page
5
of
7
6
of
other
cases
pending
before
this
court.
The
oversight
in
submitting
fake
citations
is
more
than
just
sloppy
lawyering
:
it
imperils
the
integrity
of
our
judicial
process.
However,
the
court
also
acknowledges
that
our
society
sits
on
the
precipice
of
rapid
technological
development
and
that
the
continued
development
of
AI
will
fundamentally
alter
life
as
we
know
it.
Just
as
the
advent
of
the
Internet
in
the
late
2
0th
century
transformed
the
legal
profession,
and
particularly
legal
research,
so
too
will
artificial
intelligence.
Indeed,
the
two
biggest
legal
research
databases,
Westlaw
and
LexisNexis,
have
developed
and
continue
to
expand
their
own
proprietary
AI
tools
to
as
sist
legal
practitioners
in
finding
case
law.
2
This
Order
should
not
be
construed
as
a
Luddite
attack
on
technology
and
the
efficiency
it
brings
to
the
legal
profession.
Rather,
this
Order
is
an
acknowledgement
that
AI
remains
a
nascent
technology
with
questionable
reliability
at
this
juncture.
Given
the
ethical
obligations
lawyers
must
hono
r
,
it
is
imperative
that
lawyers
use
AI
with
diligence
and
care.
This
technology
is
too
unsophisticated
and
must
necessarily
yield
to
a
lawyer’s
obligation
of
candor
to
the
court.
2
“Likewise,
AI
platforms
can
be
used
for
predictive
analytics
further
enhances
AI's
capabilities,
enabling
lawyers
to
foresee
case
outcomes,
potential
settlement
ranges,
and
the
likelihood
of
success
on
a
given
motion
based
on
historical
data.
Large
law
fi
rms
have
turned
to
AI
companies
to
automate
drafting
and
research.
For
instance,
thousands
of
lawyers
worldwide
are
now
using
Harvey,
a
GPT
-
4
platform
backed
by
OpenAI,
to
save
time
and
money.
Not
to
be
left
behind,
Lexis
and
Westlaw
joined
the
AI
race,
creating
their
own
generative
AI
platforms
.”
Benjamin
R.
Syroka,
You
Just
Can't
Beat
the
Machine:
A
Lawyer's
Duty
to
Adapt
in
the
Age
of
Artificial
Intelligence
,
56
U.
T
OL
.
L.
R
EV
.
315,
321
–
22
(2025)
(emphasis
added).
“In
the
21st
century,
the
Thomson
Reuters
(Westlaw)
and
RELX
(LexisNexis)
‘duopoly’
is
no
longer
only
about
legal
research…
The
most
valuable
assets
these
companies
have
are
data.
Both
companies
have
created
new
data
-
driven
law
practice
technology
tools
a
nd
incorporated
those
tools
into
their
research
platforms.
The
newest
versions
of
these
platforms
include
AI
-
assisted
document
review
and
analysis
features,
data
analytics
tools,
and
public
records
databases
.”
Julie
L.
Kimbrough,
Developing
Lawyering
Skills
in
the
Age
of
Artificial
Intelligence:
A
Framework
for
Legal
Education
,
29
J.
T
ECH
.
L.
&
P
OL
'
Y
31,
44
(2025)
(emphasis
added).
Case
3:23-cv-01669-JCH
Document
54
Filed
11/17/25
Page
6
of
7
7
In
failing
to
check
the
citations
the
Descrybe.AI
created
,
Attorney
Stich
did
not
conduct
a
reasonable
inquiry
into
his
pleading
as
required
under
Rule
11.
In
his
own
words,
Attorney
Stich
stated
that
he
is
“really
good
at
doing
Lexis
research.”
Yet,
Attorney
Stitch
conducted
not
even
a
cursory
cite
check
of
f
ake
citations
to
legal
authority
attributed
to
this
District
before
presenting
them
to
this
court.
The
court
finds
itself
in
a
unique
landscape
with
its
need
to
sanction
conduct
which,
if
left
uncheck
ed
,
poses
serious
risk
to
the
integrity
of
the
judicial
system
.
In
determining
what
sanction
is
most
appropriate
for
Attorney
Stich,
the
court
is
mindful
that
Attorney
Stich
has
(i)
canceled
his
license
to
the
AI
research
tool
;
(ii)
resolved
to
never
use
AI
in
his
legal
practice
again
;
(iii)
promised
that
no
lawyer
in
his
employ
will
use
AI
again
;
and
(iv)
completed
CLE
programming
related
to
AI
in
the
legal
profession.
Balancing
the
seriousness
of
the
conduct
with
Attorney
Stich’s
instant
acknowledgement
of
his
error,
his
recognition
of
the
seriousness
of
his
miscondu
ct,
the
steps
Attorney
Stich
has
taken
to
prevent
future
error,
and
his
clean
record,
the
court
determines
that
the
most
appropriate
sanction
is
$500.
V.
CONCLUSION
For
the
reasons
discussed
above,
the
court
orders
a
monetary
sanction
in
the
amount
of
$500.
SO
ORDERED.
Dated
at
New
Haven,
Connecticut,
this
17th
day
of
November
2025.
/s/
Janet
C.
Hall
___
______
Janet
C.
Hall
United
States
District
Judge
Case
3:23-cv-01669-JCH
Document
54
Filed
11/17/25
Page
7
of
7
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