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 1182, 20 November 2025 · source · PDF · 130 pages
Docket text. MEMORANDUM OPINION And Order Regarding Sanctions Against Cassie D. Preston And Gordon Rees Skully Mansukhani, LLP- Authored by Judge Christopher Hawkins. Entered On 11/20/2025(RE: related document(s)871 Order to Show Cause). (KC) (Entered: 11/20/2025)
843] (the “Debtors’ Response”). Both the DIP Lender Objection and the Debtors’ Response compiled summaries of numerous citations in the Motion to Reconsider that: did not stand for the proposition for which they were cited; did not contain the quotes attributed to them in the Motion to R econsider; or did not exist at all. [Doc.
In these filings, Progressive obdurately clung to the positions it had staked out in the Progressive Payment Motions and the Motion to Reconsider. Moreover, in the Supplemental Brief and Progressive Response, Progressive continued to miscite authorities, and it even recycled a fabricated quote from the Motion to Reconsider. See The DIP Lender’s Motion for Sanctions Regarding Progressive Perfusion, Inc.’s Filings [Doc.
Case 25-30256 Doc 1182 Filed 11/20/25 Entered 11/20/25 15:26:23 Desc Main Document Page 7 of 130 8 THE SHOW CAUSE ORDER, MOTIONS FOR SANCTIONS, AND HEARING A. The Show Cause Order In the Show Cause Order, the Court described the conduct it found problematic, namely the “pervasive inaccurate, misleading, and fabricated citations, quotations, and representations of legal authority in the Motion to Reconsider.” [Doc. 871].
1. The DIP Lender noted that the Motion to Reconsider contained fabrications, mis-citations, and misstatements of existing case law. Id . at pp.
1-2. It also pointed out that even though the DIP Lender and the Debtors had highlighted these problems in their objections to the Motion to Reconsider, Progressive “doubled down” by fil ing the Supplemental Brief and the Progressive Response, which contained “even more mis-citations, misstatements of existing case law, and remarkably used the same fabricated quote, but now attributed to a different irrelevant case.” Id. at p. 2.
In response to a question from the Court, Mr. Giller confirmed that in the past three years, no attorney at the Firm had been sanctioned or reprimanded by any other state or federal court for misciting legal authorities, including, but not limited to, hallucinated cases that may have been generated through artificial intelligence. Id. at p.
3d at 1347. Over the span of about three months, counsel filed over fifteen pleadings containing hallucinated cases and quotations. Id. at 1347-51.
3.1 (2000). Case 25-30256 Doc 1182 Filed 11/20/25 Entered 11/20/25 15:26:23 Desc Main Document Page 19 of 130 20 that his use of generative artificial intelligence was leading to hallucinations. Id . at 1349.
Docket entry 902, 8 September 2025 · source · PDF · 29 pages
Docket text. Motion for Sanctions filed by Derek F. Meek on behalf of Jackson Hospital & Clinic, Inc.. (Meek, Derek) (Entered: 09/08/2025)
Due to this misuse and misrepresentation of case law, and in some cases, fabrication of quotation 1 The Debtors in these cases are Jackson Hospital & Clinic, Inc. and JHC Pharmacy, LLC.
The Supplemental Brief and Joint Response are further evidence of Respondent’s abuse of the judicial system and bad faith. As stated above, even after the Debtors and DIP Lender filed p leadings pointing out the inaccurate, misleading, and fabricated representations of legal authority in the Motion for Reconsideration, Progressive filed the Supplemental Brief and Joint Response in further support of the Motion for Reconsideration —a filing without merit supported by inaccurate representations of authority. Respondent’s repeated conduct exemplifies a blatant disregard towards the truth.
Dunn, et al., In the United States District Court for the Northern District of Alabama, Southern Division, Case No. 2:21 -cv- 1701-AMM, the court issued a show cause order to the four attorneys that signed a pleading on behalf of one of the defendants due to the belief that counsel had fabricated citations generated by artificial intelligence in a motion submitted to the court. As a result of the show cause order, the court entered the Sanctions Order, sanctioning the attorneys responsible for these fabrications.
Fla. July 17, 2025) (imposing Section 1927 sanctions for the use of AI -generated hallucinated cases and fabricated quotations that caused the parties and the court to spend significant resources to determine the accura cy of the citations); Versant Funding LLC v. Teras Breakbulk Ocean Navigation Enters., LLC, No.
48. In this case, although Respondents have seemingly denied the use of artificial intelligence, the Debtors still presume that these citations were generated from “hallucinations,” whether generated from the use of artificial intelligence or some other cause. The misuse of artificial intelligence to generate fabricated case law, quotations, and misrepresentation s of holdings, or reliance on some other outside source of any kind, in an attempt to bolster Progressive’s position has caused an undue cost on the Debtors and their estates.
This case did not hold reach the holding that the Motion for Reconsideration asserts. Case 25-30256 Doc 902 Filed 09/08/25 Entered 09/08/25 16:03:40 Desc Main Document Page 17 of 29 62117140 v1 Fabricated Quotations Cited in the Motion for Reconsideration Case Name Cited in Motion for Reconsideration Record Cite to Motion for Reconsideration Proposition/Quote in Motion for Reconsideration Debtors’ Notes United States v. Vernon Home Health, Inc., 21 F.3d 693, 696 (5th Cir.
Docket entry 898, 5 September 2025 · source · PDF · 14 pages
Docket text. The DIP Lender's Motion for Sanctions Regarding Progressive Perfusion, Inc.'s Filings Under Section 1927 Attorney Liability for Excessive Costs filed by Paul Rosenblatt on behalf of Jackson Investment Group, LLC. (Attachments: # 1 Exhibit A - Declaration of Paul M. Rosenblatt) (Rosenblatt, Paul). Related document(s) 776 Motion to Reconsider filed by Creditor Progressive Perfusion, Inc., 859 Supplemental Motion to Reconsider filed by Creditor Progressive Perfusion, Inc., 860 Response filed by Creditor Progressive Perfusion, Inc., 871 Order to Show Cause. Modified on 9/8/2025 (KC). (Entered: 09/05/2025)
871], the Motion to Reconsider [Docket No. 776] contained fabrications, mis-citations, and 1 The Debtors in these cases are: Jackson Hospital & Clinic, Inc. and JHC Pharmacy, LLC. Case 25-30256 Doc 898 Filed 09/05/25 Entered 09/05/25 17:17:35 Desc Main Document Page 1 of 14 2 misstatements of existing case law.
In reply to the objections, on August 26 Progressive filed a response and supplemental motion [Docket Nos. 859 and 860] that contained even more mis-citations, misstatements of existing case law, and remarkably used the same fabricated quote, but now attributed to a different irrelevant case. 2.
DISCUSSION 15. As detailed in the Objections, sanctions are warranted for the fabrications, mis- citations, and misstatements of existing case law in the Motion to Reconsider. See Objections.
16. In addition, sanctions are also warranted for the mis-citations, misstatements of existing case law, and the re-use of a fabricated quote in the August 26th Filings. To assist the Court in its review of the August 26 Filings, the DIP Lender has identified the sanctionable conduct in the August 26th Filings in the chart below: # What Progressive’s August 26th Filings Claimed What Actually Exists Irregularity 1 In re Visiting Nurse Ass’n of Tampa Bay, Inc., 121 B.R.
12). The legal proposition was a fabricated quote attributed to another case in the Motion to Reconsider. Specifically, the Motion to Reconsider stated: In re Monongahela Valley Hosp., Inc., 446 B.R.
6). The fabricated language is now being re-used and falsely attributed to another case (without quotation marks). The “new” case does not support the legal proposition.
“Lien” is found but only in the context of a sale free and clear. Re-use of fabricated quote; mis- states holding. Case 25-30256 Doc 898 Filed 09/05/25 Entered 09/05/25 17:17:35 Desc Main Document Page 5 of 14 6 # What Progressive’s August 26th Filings Claimed What Actually Exists Irregularity 2 In other words, hospitals are reimbursed only for expenses they have paid or remain obligated to pay to those who furnished said direct patient care [emphasis added].
The case analyzed whether patient days associated with the Medically Indigent and General Assistance/ Unemployable Programs in Washington State should be included in the numerator of the Medicaid fraction of the Medicare Disproportionate Share Hospital (DSH) payment calculation formula. The DIP Lender is unable to locate any case titled "In re Kings Hospital Center, Inc." and believes the case name is hallucinated. Incorrect citation to case; mis- states holding.