Docket entry 56, 26 February 2025 · source · PDF · 6 pages
Docket text. RESPONSE re 55 Order,,, Terminate Motions,,, Add and Terminate Parties,,, Add and Terminate Attorneys,, by Diane Nguyen (Sutter, Luther) (Entered: 02/26/2025)
2. In Response, Savage and Wheeler each filed a Motion to Dismiss , which contained arguments that the undersigned counsel and his team has addressed in other states on multiple occasions without resort to fictitious cites. 3.
The young lawyer, other experienced lawyers, and the undersigned worked hand in hand in drafting Complaints and briefs addressing the exact same issues in multiple states, and the young lawyer’s work was more than satisfactory. But the above still does not excuse the filing of filing of a brief containing fictitious cites. 4.
Undersigned checked the brief for content, but did not apparently check the cites. Of note, on review of this matter, Lexis identified some of the fictitious cites but not all of them. Moving forward, the undersigned counsel will manuallycheck the cites for every Brief he files.
Moving forward, the undersigned counsel will manuallycheck the cites for every Brief he files. But the above still does not excuse the filing of a brief containing fictitious cites. 5.
Had a Rule 11 Motion been served, or had defense counsel disclosed the issue, then the Briefing would have been corrected immediately in accordance with the safe harbor. But the above still does not excuse the filing of a brief containing fictitious cites. 6.
After the undersigned read the Reply, he was in the process of researching an appropriate response within the Rule 11 21 day safe harbor, when this Court entered its show cause order. But the above still does not excuse the filing of a brief containing fictitious cites.. III.
Offending passages identified by the Court 1. Although the legal citations at issue here cited to a nonexistent case, each legal proposition was valid, as the Court recognized in its Order denying the Motion to Dismiss. Shockingly, the Brief also contains additional inaccurate citations that were not identified by the Court.
Shockingly, the Brief also contains additional inaccurate citations that were not identified by the Court. But that does not excuse the undersigned filing of a brief containing fictitious cites. IV.