In re Celsius Network LLC
S.D. New York (Bankruptcy) · Nov 9, 2023
- Jurisdiction
- federal
- Court
- S.D. New York (Bankruptcy)
- Record ID
- in-re-celsius-network-llc-2023-11-09
- Observed outcome
- Expert report excluded as unreliable.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court excluded the expert's valuation report under Rule 702 because it was generated by AI, lacked sufficient factual support, contained numerous errors, and relied on an unverified, non-peer-reviewed methodology. The expert failed to review the underlying source material, and the report included inaccurate descriptions of the token's features.
The court reasoned that the report failed Rule 702 standards because it was not based on sufficient facts or data, lacked citations, contained numerous errors (including duplicated text and incorrect dates), and relied on a personally developed 'fair value' method that was not peer-tested or widely accepted in the industry.
AI-drafted expert reports must be cite-checked and source-anchored before counsel signs off — unreliable reports get excluded under Rule 702.
Failure modes and consequences
- Misrepresented Authority
- Bankruptcy
- Trial
- None Adjudicated
- AI attribution
- Explicitly Recorded
- Recorded tool
- Unidentified
- Known monetary consequence
- Not recorded
- Procedural posture
- Motion to exclude expert report and testimony granted in part.
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 refers to the report as being written by artificial intelligence.
The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify that all expert reports contain sufficient citations to underlying facts and data.
- Ensure expert reports are thoroughly reviewed for factual accuracy and internal consistency before submission.
- Confirm that any valuation methodology used in expert reports is peer-reviewed or widely accepted in the relevant field.