Docket entry 23, 17 November 2025 · source · PDF · 6 pages
Docket text. [11232392] Rebuttal formal rebuttal to [22] court's findings filed by Ms. Rashonna Moore. Served on 11/17/2025. Manner of Service: email. [25-6002] [Entered: 11/17/2025 05:40 PM]
PLAINTIFF'S FORMAL REBUTTAL TO COURT'S FINDINGS OF "NONEXISTENT CASES," uAI GENERATION," AND ALLEGED RULE VIOLATIONS I.
This rebuttal demonstrates that (1) the Court's conclusions rest upon erroneous assumptions unsupported by verified fact or authenticated record; (2) the alleged "nonexistence" of cases stems from clerical and cross-jurisdictional inconsistencies, not fabrication or deceit; (3) the Court's language imputing "Al generation" constitutes unlawful prejudgment and prejudicial defamation of Plaintiff's legal credibility; and (4) the Court's order itself violates Rule B(e) and Rule 11(b) of the Federal Rules of Civil Procedure by introducing unverified claims and failing to construe pleadings so as to do justice.
THE COURT'S FINDINGS ARE FACTUALLY AND PROCEDURALLY DEFECTIVE 1. No Verified Evidentiary Basis Exists for a Finding of "Nonexistent Cases." The Court's conclusion that citations were "nonexistent'' was not derived from any authenticated record, certified database, or official judicial source. The Court's reliance on its own inability to locate materials is not probative evidence of nonexistence.
2. Inconsistent or Misattributed Citations Are Not Grounds for Accusations of Fabrication. Citation inconsistencies frequently arise from variations in regional reporters, parallel citations, archival pagination, and electronic indexing errors-none of which constitute misconduct or deceit.
2007)). "If appellant has in fact relied on nonexistent cases ... this appeal may be frivolous as argued." (Finch v. Hughes Aircraft Co., 926 F.2d 1574 (Fed.
Cir.1991)) . The use of nonexistent cases is especially troubling because "[a]n attempt to persuade a court or oppose an adversary by relying on fake opinions is an abuse of the adversary system." Park v. Kim, 91 F.4th 610,615 (2d Cir.
Apr. 2, 2025) (magistrate judge's order imposing sanctions where "six cases were fake and likely the handiwork of a ChatGPT or similar artificial intelligence (Al) program's hallucinations"), aff'd, 782 F. Supp.
The "Al Usage" Accusation Violates Judicial Ethics and Federal Law. The suggestion that Plaintiff's brief reflects "GenAI hallucinations" is unsubstantiated, defamatory, and beyond the Court's authority absent evidentiary support. No motion, hearing, or affidavit substantiates such an allegation.