Deutsche Bank Nat'l Bank v. LeTennier (Jan. 8, 2026)

Case details
Full caption
Deutsche Bank National Bank v. Jean LeTennier
Country
United States
Jurisdiction
New York (NY)
Court
New York Court of Appeals
Decided
Jan. 8, 2026
Disposition
Affirmed
Panel
Ceresia (J.); McShan (J.)
Opinion
Per curiam
DEUTSCHE BANK NATIONAL TRUST COMPANY, as..., --- N.Y.S.3d ---- (2026) © 2026 Thomson Reuters. No claim to original U.S. Government Works.12026 WL 53120Only the Westlaw citation is currently available.Supreme Court, Appellate Division,Third Department, New York.DEUTSCHE BANK NATIONAL TRUSTCOMPANY, as Trustee, Respondent,CV–23–0713|Decided and Entered: January 8, 2026Before: Aarons, J.P., Reynolds Fitzgerald, Ceresia, Fisher andMcShan, JJ.Attorneys and Law FirmsJoshua A. Douglass, Millerton, for appellant.Hinshaw & Culbertson LLP, New York City (Ellis M. Osterof counsel), for respondent.OpinionFisher, J.*1 JEAN LeTENNIER, Also Known as OPINION ANDORDERJEAN MICHEL LeTENNIERCalendar Date: October 16, 2025(1) Appeal from an order of the Supreme Court (Brian Burns,J.), entered March 31, 2023 in Delaware County, which,among other things, denied defendant Jean LeTennier'smotion to vacate a prior order, (2) appeal from an order of saidcourt, entered August 16, 2024 in Delaware County, which,among other things, granted plaintiff's cross-motion to requiredefendant Jean LeTennier to file all future applications to thecourt by an order to show cause, (3) appeal from an order ofsaid court, entered September 24, 2024 in Delaware County,which, among other things, declined to sign an order to showcause, and (4) motion to dismiss the appeal, strike certainportions of the briefs, record and appendix, and for sanctions.In August 2006, defendant Jean LeTennier (hereinafterdefendant) executed a note to borrow a certain sum fromNexus Financial LLC. Such note was secured by a mortgageon real property located in Delaware County. Defendantdefaulted on his obligations under the note and plaintiffcommenced this mortgage foreclosure action in March2018. Defendant answered and asserted numerous affirmativedefenses and counterclaims, notably challenging plaintiff'sstanding to commence this action. Both parties then movedfor summary judgment, and Supreme Court (Northrup Jr.,J.), finding that plaintiff established standing by physicaldelivery of the note prior to commencement of this action anddefendant failed to demonstrate any bona fide defense to thisforeclosure, granted plaintiff's motion and denied defendant'scross-motion. Defendant appealed from such order and thisCourt affirmed (189 AD3d 2022, 2025 [3d Dept 2020] ).Thereafter, defendant filed several pro se motions to renew,reargue or vacate the order granting summary judgmentto plaintiff, as well as to compel certain disclosure fromplaintiff. Supreme Court (Burns, J.) denied these motions,and ultimately issued an order confirming the referee's reportand granting a judgment of foreclosure and sale to plaintiff.Defendant filed at least four additional motions seekingsimilar relief, the last of which sought vacatur pursuant toCPLR 5015, claiming that newly discovered evidence andalleged fraud used by plaintiff to procure the prior orders/judgment warranted dismissal of the complaint. SupremeCourt denied such motion in March 2023, finding thatdefendant had engaged in frivolous conduct and warninghim that continued frivolous conduct may result in financialsanctions (hereinafter the March 2023 order). Defendant thenmoved to meet with Supreme Court ex parte in chambersand for a forensic accounting,1 and plaintiff cross-moved tostrike certain documents filed by defendant and for otherrelated relief. Supreme Court denied defendant's motion andgranted plaintiff's cross-motion in an August 2024 decision,striking over 20 documents filed by defendant,2 finding himto be a vexatious litigant that must bring future motions byorder to show cause, and awarding costs and legal fees toplaintiff for defendant's frivolous conduct (hereinafter theAugust 2024 order). Defendant filed three more motions forpreviously sought relief; Supreme Court denied each motionin September 2024, with the last being September 24, 2024(hereinafter the September 2024 order). Defendant appealsfrom the March 2023 order, the August 2024 order and theSeptember 2024 order.*2 Initially, the merits of this appeal are unremarkable innature. Relating to defendant's challenge of the March 2023order, “[a] trial court may relieve a party from a judgmentor order on the basis of newly-discovered evidence whichwould probably have produced a different result and which
DEUTSCHE BANK NATIONAL TRUST COMPANY, as..., --- N.Y.S.3d ---- (2026) © 2026 Thomson Reuters. No claim to original U.S. Government Works.2could not have been discovered in time [before disposition] oron the basis of fraud, misrepresentation, or other misconductof an adverse party” (HSBC Bank USA, N.A. v. Sage, 143AD3d 1214, 1215 [3d Dept 2016] [internal quotation marks,ellipsis and citations omitted] ). In doing so, “[a] partyseeking relief from a judgment upon the ground of newlydiscovered evidence bears the burden of demonstrating thatsuch proof could not have been discovered sooner throughthe exercise of due diligence” (Matter of Romine v. NewYork Pub. Serv. Commn., 209 AD3d 1197, 1198 [3d Dept2022] [internal quotation marks and citations omitted], appealdismissed 39 NY3d 1060 [2023] ). Here, defendant offeredcertain evidence from the U.S. Securities and ExchangeCommission (hereinafter SEC) and the agencies associatedwith the Secretary of State in California and New York, butfailed to demonstrate why this evidence was not available orcould not, with due diligence, have been discovered at thetime that he opposed plaintiff's motion for summary judgment(see Wall St. Mtge. Bankers, Ltd. v Rodgers, 148 AD3d1088, 1089 [2d Dept 2017]; HSBC Bank USA, N.A. v. Sage,143 AD3d at 1215). Indeed, the certificate from Californiaindicated it was issued more than a year before summaryjudgment was granted, and the correspondence from the SECindicated the records were also publicly available online –which information proffered by defendant on this motionwas from 2007–2008. As to his allegations of fraud andother misconduct on the part of plaintiff, such contentionsare conclusory and otherwise unsupported by the record (seeCarlson v. Dorsey, 161 AD3d 1317, 1320 [3d Dept 2018];Wells Fargo, N.A. v. Levin, 101 AD3d 1519, 1521 [3d Dept2012], lv dismissed 21 NY3d 887 [2013] ). Nevertheless,the gravamen of defendant's contentions distill to anotherchallenge to plaintiff's standing to maintain this action, whichthis Court has already addressed and remains the law of thecase (see 189 AD3d at 2024–2025).3 Since defendant failedto raise any challenge concerning the August 2024 order orthe September 2024 order in his initial brief, his appeals fromsuch orders are deemed abandoned (see Matter of Shannon,240 AD3d 1021, 1022 [3d Dept 2025]; Amici v. Mazza, 234AD3d 1170, 1172 n 2 [3d Dept 2025], lv denied 44 NY3d 902[2025] ).Where this appeal becomes unconventional, however, is thatdefendant's opening brief cites six cases which do not exist.Plaintiff identified these fabricated cases as possibly beingthe product of artificial intelligence (hereinafter AI), andmoved for an order seeking, among other things, sanctionsagainst defendant and defense counsel. Defendant claimedthe nonexistent cases were citation or formatting errors thathe would correct in his reply brief, and then opposed themotion for sanctions with more fake cases and interpretationsfor existing cases that are at best strenuously attenuated, andat worst entirely inapposite. Defendant's subsequent replybrief acknowledged that his “citation of fictitious cases isa serious error” and that they are “problematic,” but failedto offer any corrections or further explanation as previouslystated. He then proceeded to include more fake cases andfalse legal propositions in two subsequent letters to thisCourt that requested judicial notice of a bankruptcy stay.In examining the propriety of defendant's previously filedpapers, more nonexistent cases were discovered in a motionthat granted affirmative relief to defendant. Defense counselreluctantly conceded during oral argument that he used AI inthe preparation of his papers and, although he told the Courtthat he checked his papers, the filings themselves demonstrateotherwise. In total, defendant's five filings during this appealinclude no less than 23 fabricated cases, as well as many otherblatant misrepresentations of fact or law from actual cases.Although other state and federal courts have had theoccasion to address the misuse of AI in legal papers, thisCourt has not yet had that opportunity. In doing so, werecognize that, as did the shift from digest books to onlinelegal databases, generative artificial intelligence (hereinafterGenAI) represents a new paradigm for the legal profession,one which is not inherently improper, but rather has thepotential to offer benefits to attorneys and the public –particularly in promoting access to justice, saving costsfor clients and assisting courts with efficient and accurateadministration of justice (see Wadsworth v. Walmart Inc.,348 FRD 489, 492–493 [D Wyo 2025]; Mata v. Avianca,Inc., 678 F Supp 3d 443, 448 [SD N.Y.2023] ).4 At thesame time, attorneys and litigants must be aware of thedangers that GenAI presents to the legal profession. Atthe forefront of that peril are AI “hallucinations,” whichoccur when an AI database generates incorrect or misleadingsources of information due to a “variety of factors, includinginsufficient training data, incorrect assumptions made by themodel, or biases in the data used to train the model” (Whatare AI Hallucinations?, https://cloud.google.com/discover/what-are-ai-hallucinations [last accessed Jan. 6, 2026]; seegenerally United States v. Google LLC, ___ F Supp 3d ___,___, 2025 WL 2523010, *15, 2025 U.S. Dist LEXIS 170459,*74 [D DC, Sept. 2, 2025, Nos. 20–cv–3010 (APM), 20–cv–3715 (APM) ] ).5 Hallucinated cases may look like a real casebecause they include familiar-looking reporter information,but their citations lead to cases with different names, indifferent courts and on different topics – or even to no case
DEUTSCHE BANK NATIONAL TRUST COMPANY, as..., --- N.Y.S.3d ---- (2026) © 2026 Thomson Reuters. No claim to original U.S. Government Works.3at all (see Sanders v. United States, 176 Fed Cl 163, 168–169[Fed Cl 2025] ). Even where GenAI provides accurate casecitations, it nonetheless may misrepresent the holdings of thecited cases – often in favor of the user supplying the query(see Green Bldg. Initiative, Inc. v Peacock, 350 FRD 289, 292[D Ore 2025]; Kruglyak v. Home Depot U.S.A., Inc., 774 FSupp 3d 767, 770 [WD Va 2025]; see also Matter of Richburg,671 BR 918, 924 n 11 [Bankr D SC 2025] ).6*3 Courts throughout the country which have beenconfronted with AI-generated authorities have concluded thatfiling papers containing hallucinated cases and fabricatedlegal authorities may be sanctionable (see generally OTGNew York, Inc. v OTTOGI Am., Inc., 2025 WL 2671460,*2–3, 2025 U.S. Dist LEXIS 183358, *7–8 [D NJ, Sept.18, 2025, No. 24–cv–07209 (BRM)(JRA) ] ). This includeswhere the fake citations stand for accurate legal principles(see Ader v. Ader, 87 Misc.3d 1213[A], *2 [Sup Ct, N.Y.County 2025]; see also United States v. McGee, ___ F Supp3d ___, ___, 2025 WL 2888065, at *7, 2025 U.S. Dist LEXIS201350, *19; Johnson v. Dunn, 2025 WL 2086116, *16, U.S.Dist LEXIS 141805, *45–46 [ND Ala, July 23, 2025, No.2:21–cv–1701–AMM] ), as there are many harms associatedwith the submission of fake cases that extend beyond merelywasting the time and money of the opposing party, but alsoin taking up the court's resources to evaluate and resolve thedeception (see Mata v. Avianca, Inc., 678 F Supp 3d at 448).In New York, courts have discretion to award costs or imposefinancial sanctions against an attorney or party for engagingin frivolous conduct (see 22 NYCRR 130–1.1[a], [b]; WFEVentures, Inc. v. GBD Lake Placid, LLC, 197 AD3d 824,836 [3d Dept 2021] ). “[C]onduct is frivolous if: (1) it iscompletely without merit in law and cannot be supportedby a reasonable argument for an extension, modification orreversal of existing law; (2) it is undertaken primarily to delayor prolong the resolution of the litigation, or to harass ormaliciously injure another; or (3) it asserts material factualstatements that are false” (22 NYCRR 130–1.1[c] ). “Indetermining whether the conduct undertaken was frivolous,the court shall consider, among other issues the circumstancesunder which the conduct took place, including the timeavailable for investigating the legal or factual basis of theconduct, and whether or not the conduct was continued whenits lack of legal or factual basis was apparent, should havebeen apparent, or was brought to the attention of counsel orthe party” (22 NYCRR 130–1.1[c]; see Matter of Minister,Elders & Deacons of Refm. Prot. Dutch Church of City ofN.Y. v 198 Broadway, 76 N.Y.2d 411, 414 [1990] ). Moreover,rule 3.3 of the Rules of Professional Conduct provides that“[a] lawyer shall not knowingly ... make a false statement offact or law to a tribunal or fail to correct a false statementof material fact or law previously made to the tribunal bythe lawyer” (Rules of Prof Conduct [22 NYCRR 1200.0] rule3.3[a][1] ). Sanctions may be appropriate for frivolous andmeritless appeals (see Bell v. State of New York, 96 N.Y.2d811, 812 [2001] ), and are a common consequence for misusesof judicial process which unnecessarily divert “the time andattention of ... [the] Judges of this State” (Matter of Minister,Elders & Deacons of Refm. Prot. Dutch Church of City ofN.Y. v 198 Broadway, 76 N.Y.2d at 415; see generally Engel v.CBS, Inc., 93 N.Y.2d 195, 207 [1999]; Mata v. Avianca, Inc.,678 F Supp 3d at 448).Here, defendant submitted at least 23 fabricated legalauthorities across five filings during the pendency of thisappeal.7 He has also misrepresented the holdings of severalreal cases as being dispositive in his favor – when theywere not.8 It is axiomatic that submission of fabricated legalauthorities is completely without merit in law and thereforeconstitutes frivolous conduct (see 22 NYCRR 130–1.1[c][1] ). It cannot be said that fabricated legal authoritiesconstitute “existing law” so as to provide a nonfrivolousground for extending, modifying or reversing existing law(see 22 NYCRR 130–1.1[c][1]; see generally Wadsworth v.Walmart Inc., 348 FRD at 495; Mata v. Avianca, Inc., 678F Supp 3d at 461). Defense counsel acknowledged duringoral argument that the papers were his own, and, nevertheless,“[b]y signing a paper, an attorney or party certifies that, tothe best of that person's knowledge, information and belief,formed after an inquiry reasonable under the circumstances... the presentation of the paper or the contentions therein arenot frivolous” (22 NYCRR 130–1.1a [b][1] ). However, theexcuse for fabricated legal authorities offered by defendantin his papers is incredible. Moreover, during oral argumentdefense counsel estimated that 90% of the citations heused were accurate, which, even if it were true, is simplyunacceptable by any measure of candor to any court (seeRules of Prof Conduct [22 NYCRR 1200.0] rule 3.3[a][1] ). Where we are most troubled is that more than halfof the fake cases offered by defendant came after he wason notice of such issue, whereby his reliance on fabricatedlegal authorities grew more prolific as this appeal proceeded– despite it being apparent to him that such conduct lackeda legal basis (see Ader v. Ader, 87 Misc.3d 1213[A], *1;see also 22 NYCRR 130–1.1[c]; Rules of Prof Conduct [22NYCRR 1200.0] rule 3.3[a][1] ). Rather than taking remedialmeasures or expressing remorse, defense counsel essentially
DEUTSCHE BANK NATIONAL TRUST COMPANY, as..., --- N.Y.S.3d ---- (2026) © 2026 Thomson Reuters. No claim to original U.S. Government Works.4doubled down during oral argument on his reliance of fakelegal authorities as not “germane” to the appeal.9*4 Turning to the appropriate sanction, courts must considerthat sanctions are both retributive, in that they punish pastconduct, but are also “goal oriented, in that they are useful indeterring future frivolous conduct not only by the particularparties, but also by the [b]ar at large” (Levy v. Carol Mgt.Corp., 260 A.D.2d 27, 34 [1st Dept 1999] ). In doing so,courts around the country have imposed sanctions rangingfrom warnings to tens of thousands of dollars to attorneyswho have submitted AI hallucinated legal authorities andfalse propositions (see e.g. Cojom v. Roblen, LLC, 2025WL 3205930, *4, 2025 U.S. Dist LEXIS 225325, *9–10 [DConn, Nov. 17, 2025, No. 3:23–CV–1669 (JCH) ] [involvingthree nonexistent cases; total sanction $500]; Hall v. AcademyCharter Sch., 2025 WL 2256653, *5–6, 2025 U.S. DistLEXIS 152628, *14–16 [ED NY, Aug. 7, 2025, No. 2:24–cv–08630–JMW] [involving three nonexistent cases; warning];Lacey v. State Farm Gen. Ins. Co., 2025 WL 1363069, *5,2025 U.S. Dist LEXIS 90370, *13 [CD Cal, May 5, 2025,No. CV 24–5205 FMO (MAAx) ] [involving nine incorrectcitations and two authorities that did not exist by attorneys intwo law firms; total sanctions $31,100] ). Such broad rangereflects a constellation of factors surrounding the conduct ofthe attorney or party offering such fabricated legal authorities,including the number of fake cases or propositions, whetherthere were fake quotes, if the submitter continued to use orcreate more fabricated authorities across other filings in thesame proceeding after being on notice of the misconduct,there was an admission of the error, there was remorse andthe extent of the impact that the fabricated legal authoritieshad on the proceedings. Considering these factors, courts incases involving comparable misconduct by defense counselhave imposed significant sanctions (see e.g. Noland v. Land ofthe Free, L.P., 114 Cal App 5th 426, 449, 336 Cal Rptr 3d 897,912 [Cal Ct App 2025] [involving 21 fabricated case citationsand quotations by attorney; total sanction $10,000]; Mid Cent.Operating Engrs. Health & Welfare Fund v HoosierVac LLC,2025 WL 1511211, *2, 2025 U.S. Dist LEXIS 100748, *3–4 [SD Ind, May 28, 2025, No. 2:24–cv–00326–JPH–MJD][involving six nonexistent cases across multiple filings; totalsanction $6,000]; Kruse v. Karlen, 692 SW3d 43, 50–54 [MoCt App 2024] [involving 22 fabricated case citations andmultiple statutory misstatements by attorney; total sanction$10,000] ).Accordingly, recognizing this as the first appellate-level casein New York addressing sanctions for the misuse of GenAI,we find the imposition of a monetary sanction on defensecounsel Joshua A. Douglass in the amount of $5,000 to beappropriate under the circumstances, with the further goalof deterring future frivolous conduct by defendant and thebar at large (see Levy v. Carol Mgt. Corp., 260 A.D.2d at34). To be clear, attorneys and litigants are not prohibitedfrom using GenAI to assist with the preparation of courtsubmissions. The issue arises when attorneys and staff are notsufficiently trained on the dangers of such technology, andinstead erroneously rely on it without human oversight. Aswith the work from a paralegal, intern or another attorney, theuse of GenAI in no way abrogates an attorney's or litigant'sobligation to fact check and cite check every document filedwith a court. To do otherwise may be sanctionable, dependingon the facts and particular circumstances of each case.Where most cases involving GenAI would conclude here, weturn to plaintiff's further contentions that the appeal itself isfrivolous. We find this contention to have merit. Defendantfiled no less than seven motions before Supreme Courtchallenging either the decision granting summary judgmentor the judgment of foreclosure and sale – or both. Thegravamen of each application related to the issue of standing.The conduct by defendant continued to escalate, culminatingin multiple warnings of frivolous conduct by Supreme Court.At one point, defendant filed over 20 irrelevant documentswhich had to be stricken and resulted in a sanction. Despitebeing represented by counsel, some of these motions werefiled pro se by defendant. The misuse of GenAI representsan escalation in such unabashed misconduct, and the presentappeal is a “continuation[ ] of the underlying protracted andfrivolous litigation pursued by defendant undeterred by therepeated” warnings and imposition of sanctions by SupremeCourt (De Ruzzio v. De Ruzzio, 287 A.D.2d 896, 897 [3dDept 2001] ). As already noted, defendant's contentions onappeal – which this Court previously considered and rejected(189 AD3d at 2024–2025) – “are not ultimately unpersuasive,yet good-faith, arguments requiring our review of existinglaw, but, rather, part of a continuing effort to delay the[foreclosure] action and harass plaintiff” (De Ruzzio v. DeRuzzio, 287 A.D.2d at 897–898 [internal quotation marksand citation omitted] ). Although defense counsel signed thepapers filed with this Court, which were uploaded through hisNYSCEF account, it is further not unnoticed that the metadataof numerous documents indicate they originated from aprogram in his client's name. Such result would be consistentwith defendant filing papers pro se before Supreme Court, anddefense counsel's apparent unfamiliarity during oral argumentwith certain papers he allegedly filed during the pendency
DEUTSCHE BANK NATIONAL TRUST COMPANY, as..., --- N.Y.S.3d ---- (2026) © 2026 Thomson Reuters. No claim to original U.S. Government Works.5of this appeal. Given the baseless nature of this appeal, andrecognizing that sanctions must be goal oriented to deterfuture conduct to prevent the waste of judicial resources andcontinued vexatious litigation of specific individuals too (seeLevy v. Carol Mgt. Corp., 260 A.D.2d at 34), we conclude thatan additional sanction of $2,500 shall be imposed on defensecounsel Joshua A. Douglass and $2,500 shall be imposedon defendant Jean LeTennier for pursing this appeal.10 Wehave examined the remaining contentions of the parties andhave found them to be without merit, rendered academic orfrivolous.*5 Aarons, J.P., Reynolds Fitzgerald, Ceresia and McShan,JJ., concur.ORDERED that the orders are affirmed, with costs.ORDERED that plaintiff's motion for sanctions is partiallygranted, with costs, to the extent that sanctions in the amountof $7,500 are imposed against defendant's counsel JoshuaA. Douglass and $2,500 are imposed against defendant JeanLeTennier pursuant to 22 NYCRR 130–1.1, in each case tobe paid within 60 days following the date of this order, withproof of payment to be filed with this Court.All Citations--- N.Y.S.3d ----, 2026 WL 53120Footnotes1Defendant was represented by present counsel from this point forward, although it appears defendant continued to movepro se.2Defendant electronically filed various documents with the court, including, among several others, a “Cancellation ofDebt,” “Notice of Cease and Desist Conditional,” “Affirmation of Truth Forma” and a “Notice of Pendency of Action” fromthe “JMLetennier Irrevocable Family Trust” asserting a lien on the subject property due to a purported lawsuit againstdefendant. These were some of the documents stricken by Supreme Court.3Defendant did not seek leave to appeal to the Court of Appeals or otherwise challenge this Court's decision from 2020.4We find this particularly true as it relates to rural access to justice affecting many parts of New York, as well as throughoutthe United States.5It must be recognized that GenAI and AI are not the same thing, and our use of these different terms is intentional (seeUnited States v. Google LLC, ___ F Supp 3d at ___, 2025 WL 2523010, at *9, 2025 U.S. Dist LEXIS 170459 at *52–53[explaining the different types of AI, and that GenAI is a subfield of AI “that uses machine-learning techniques to generatenew data, including text, images, sound, code, and other media”] ).6Such outcome is an inherent product of GenAI, in that such “models are designed to maximize the chance ofgiving an answer, meaning the [model] will be more likely to give an incorrect response than admit it doesn't knowsomething” (Noland v. Land of the Free, L.P., 114 Cal App 5th 426, 442, 336 Cal Rptr 3d 897, 911 [Cal Ct App 2025][internal quotation marks and citation omitted]; see generally United States v. Google LLC, ___ F Supp 3d at ___, 2025WL 2523010, at *15, 2025 U.S. Dist LEXIS 170459 at *71–72; In re Kenney, ___ So3d ___, ___, 2025 WL 2986582, *3n 5, 2025 La App LEXIS 2023, *7 [La Ct App, 5 Cir, Oct. 23, 2025, No. 25–C–389] ).7As one example, defendant submitted the fake case name “Tishman Realty & Construction Co. v Regan,” with anaccompanying citation to a New York court, year and proposition that “clarified” a subsection of CPLR 5015 – the centralissue in the March 2023 order. However, the provided citation leads us to a case with a different name from Illinois, andthe case name is also not found in any reported state or federal case in the United States.8For instance, defendant submits the real case of Wells Fargo Bank, N.A. v. Erobobo (127 AD3d 1176 [2d Dept 2015], lvdismissed 25 NY3d 1221 [2015] ) with the false holding “foreclosure void where trust not properly formed”; the SecondDepartment held the opposite.9The parties were notified that plaintiff's motion for sanctions was to be decided with the appeal.
DEUTSCHE BANK NATIONAL TRUST COMPANY, as..., --- N.Y.S.3d ---- (2026) © 2026 Thomson Reuters. No claim to original U.S. Government Works.610Pursuant to 22 NYCRR 130–1.3, the sanction imposed on defense counsel shall be deposited with the Lawyers' Fundfor Client Protection and the sanction imposed on defendant shall be deposited with the Clerk of the Court for transmittalto the Commissioner of Taxation and Finance.End of Document© 2026 Thomson Reuters. No claim to original U.S.Government Works.
ProvenanceKnow exactly where this document came from.Members see the sourcing behind every authority on DocPost — so you can check the record yourself and cite with confidence.Request access