Ave. Capital Group, LLC v. Strum
SC New York · Feb 9, 2026
- Jurisdiction
- state
- Court
- SC New York
- Record ID
- ave-capital-group-llc-v-strum-2026-02-09
- Observed outcome
- The 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 monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
Every cited case must be pulled from Westlaw/Lexis by a human before filing; no AI-generated citation gets a pass.
Failure modes and consequences
- Fake Citations
- Fabricated Quotes
- Tort
- Trial
- Ordered To Show Cause
- AI attribution
- Reported
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- 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.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The court's editor's note mentions unverified citations likely generated by AI tools.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Retain a matter-level record of source checks and corrections.