Which source supports this Ave. Capital Group, LLC v. Strum summary?

The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.

HomeCasesAve. Capital Group, LLC v. Strum

Evidence review: primary document verified. The linked primary document was extracted and checked with page-level evidence locators.

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Corpus matter record

Ave. Capital Group, LLC v. Strum

SC New York · Feb 9, 2026

NY / state Editorial impact: medium fake citations fabricated quotes tort trial Ordered To Show Cause

Direct answer

What happened in this matter?

The court ordered defense counsel to show cause why they should not be sanctioned for citing two non-existent cases and including fabricated quotations in a memorandum of law filed in support of a motion to supplement papers.

Why the court cared: Fabricated: Case Law | Court found counsel included a non-existent case citation in his memorandum and ordered show-cause re sanctions. || Fabricated: Case Law | Court found counsel included a non-existent (or incorrectly cited) Risucci decision; plaintiffs located a differently cited Risucci case that did not contain the quoted language. || Fabricated: Case Law | Defendant's memorandum cited a non-existent case 'Kennedy v Kennedy, 192 AD3d 111 (1st Dept 2020)'; court found the case does not exist and ordered counsel to show cause why he should not be sanctioned. || False Quotes: Case Law | Defendant's brief cited 'Risucci v Homayoon, 122 AD3d 700 (2nd Dept 2014)' and quoted language; plaintiffs located a differently cited Risucci (122 AD2d 260 (2d Dept 1986)) and the quoted language does not appear in that opinion, indicating a false quotation or misrepresentation.
Why it matters now: Every cited case must be pulled from Westlaw/Lexis by a human before filing; no AI-generated citation gets a pass.

Why this matter is tracked

In a defamation action, the Supreme Court of New York denied the defendant's motion to dismiss in part but granted it regarding a non-independent cause of action. During the proceedings, the court identified that defense counsel included two non-existent case citations in a memorandum of law supporting a motion for leave to supplement papers. Specifically, the court noted the citation of 'Kennedy v Kennedy, 192 AD3d 111 (1st Dept 2020)' and 'Risucci v Homayoon, 122 AD3d 700 (2nd Dept 2014)', the latter of which also contained fabricated quoted language not present in the actual 1986 decision of the same name. Consequently, the court ordered defense counsel to show cause why sanctions should not be imposed.

Operational lesson

Every cited case must be pulled from Westlaw/Lexis by a human before filing; no AI-generated citation gets a pass.

Record details

New YorkSingle-state evidence scope

Explore NYOpen its source-linked jurisdiction page and related matters.

CourtSC New York

Jurisdictionstate

Circuit2nd Circuit

DateFeb 9, 2026

AI toolAI (implied, unspecified)

Party typeLawyer

OutcomeThe court denied the motion to dismiss in part, granted it in part, and issued an order to show cause regarding potential sanctions for defense counsel.

Known amountNot recorded

Professional sanctionNo

Attribution boundary

What the record establishes about AI use

reported

The court's editor's note mentions unverified citations likely generated by AI tools.

Procedural posture

Order to show cause issued by the Supreme Court of New York on February 9, 2026, regarding defense counsel's conduct in a motion to dismiss and subsequent motion for leave to supplement papers.

Correction behavior

Correction behavior is not separately verified in the current record.

Tracked discrepancy record

4 citation, quotation, or authority issues are recorded in the source dataset.

Fabricated: Case Law | Court found counsel included a non-existent case citation in his memorandum and ordered show-cause re sanctions.
Fabricated: Case Law | Court found counsel included a non-existent (or incorrectly cited) Risucci decision; plaintiffs located a differently cited Risucci case that did not contain the quoted language.
Fabricated: Case Law | Defendant's memorandum cited a non-existent case 'Kennedy v Kennedy, 192 AD3d 111 (1st Dept 2020)'; court found the case does not exist and ordered counsel to show cause why he should not be sanctioned.
False Quotes: Case Law | Defendant's brief cited 'Risucci v Homayoon, 122 AD3d 700 (2nd Dept 2014)' and quoted language; plaintiffs located a differently cited Risucci (122 AD2d 260 (2d Dept 1986)) and the quoted language does not appear in that opinion, indicating a false quotation or misrepresentation.

Questions this record answers

What happened in Ave. Capital Group, LLC v. Strum?: The court ordered defense counsel to show cause why they should not be sanctioned for citing two non-existent cases and including fabricated quotations in a memorandum of law filed in support of a motion to supplement papers.
Why does Ave. Capital Group, LLC v. Strum matter for legal AI risk?: Every cited case must be pulled from Westlaw/Lexis by a human before filing; no AI-generated citation gets a pass.
What does the public record establish about Ave. Capital Group, LLC v. Strum?: Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
Which source supports this Ave. Capital Group, LLC v. Strum summary?: The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.

Related matters

Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.

Cassata v. Michael Macrina Architect, P.C.SC New York · Jan 27, 2026same court · fake citations + fabricated quotes Keefe v. BMakin Film LtdSC New York · Apr 24, 2026same court · fake citations + fabricated quotes Brown v. Real Estate Capital of America et al.SC New York · Aug 7, 2026same court · fake citations + fabricated quotes Rodriguez v. Time Warner EntertainmentSC New York · Jul 22, 2026same court · fake citations + tort Polanco v. Brooklyn Rose LLCSC New York · Jun 16, 2026same court · fake citations + tort Vargas v. MTA Bus Co.SC New York · Jun 12, 2026same court · fake citations + tort

Linked evidence record

Damien Charlotin case archive

Publisher document archive
The recorded document is hosted in the upstream publisher archive.

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Public-record statuspublic record, not an allegation-only entry

Indexing eligibilitypublicly indexable with evidence status disclosed

Evidence-review statusprimary document verified

Published and maintained byManu Ayala · AI VortexIndependent legal AI risk intelligence

Evidence review recorded Jul 27, 2026

Source host classified Attribution boundary stated Limitations disclosed

Corpus checked Sep 10, 2026; latest tracked decision Sep 8, 2026. AI Vortex summarizes public records and does not replace the court document or legal research service.

Use this record

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Evidence boundary

Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.

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