Re Reza Khoshnik
Ontario SCJ (Bankruptcy) · Mar 16, 2026
What happened in this matter?
The court identified that the Bankrupt used generative AI to produce court materials containing fabricated and mischaracterized legal citations. The court required the parties to submit updated Bills of Costs to determine the quantum of an adverse costs order, clarifying that such costs are not provable in bankruptcy.
- Why the court cared
- The court reasoned that the Bankrupt's reliance on AI-generated materials without verification constituted a failure to meet the duty to represent the law faithfully. Citing Ko v. Li and other precedents, the court held that litigants must ensure human review of AI-generated content and that submitting non-existent or mischaracterized authorities is an abuse of process.
- Why it matters now
- This case illustrates the judicial response to pro se litigants using AI to generate court filings. It reinforces the requirement for human verification of AI-generated legal research and confirms that costs arising from such misconduct are not dischargeable in bankruptcy.
Why this matter is tracked
In a bankruptcy motion, the Bankrupt admitted to using generative AI to draft his materials. The court found that the Bankrupt failed to verify the authenticity of cited authorities, resulting in the submission of non-existent or mischaracterized case law. Specifically, the Bankrupt relied on AI-generated content without reading the underlying cases, leading to the inclusion of fabricated propositions and misattributed authority. The court emphasized the fundamental duty of litigants to ensure the accuracy of materials submitted to the court, regardless of the technology used. Consequently, the court ordered the parties to file updated Bills of Costs to facilitate an assessment of adverse costs, noting that such awards would not be compromised by a discharge in bankruptcy.
This case illustrates the judicial response to pro se litigants using AI to generate court filings. It reinforces the requirement for human verification of AI-generated legal research and confirms that costs arising from such misconduct are not dischargeable in bankruptcy.
Record details
What the record establishes about AI use
The Bankrupt admitted to using AI to generate materials.
Motion for leave to lift the automatic stay pursuant to section 69.4 of the Bankruptcy and Insolvency Act.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
3 citation, quotation, or authority issues are recorded in the source dataset.
- Misrepresented: Case Law | Bankrupt quoted and attributed a proposition to Re Fakoori that he later admitted was manufactured by his materials.
- Misrepresented: Case Law | Bankrupt cited Wang v. Wang as if it supported the proposition that bankruptcy courts can routinely decide complex fraud claims during bankruptcy proceedings; court found the cited case unrelated to that proposition.
- Misrepresented: Case Law | Bankrupt relied on Simone v. Daley to support that certain breach-of-trust determinations belong within bankruptcy proceedings; the court found the Bankrupt mischaracterized the authority (appeal reversed the relevant finding).
Questions this record answers
- What happened in Re Reza Khoshnik?
- The court identified that the Bankrupt used generative AI to produce court materials containing fabricated and mischaracterized legal citations. The court required the parties to submit updated Bills of Costs to determine the quantum of an adverse costs order, clarifying that such costs are not provable in bankruptcy.
- Why does Re Reza Khoshnik matter for legal AI risk?
- This case illustrates the judicial response to pro se litigants using AI to generate court filings. It reinforces the requirement for human verification of AI-generated legal research and confirms that costs arising from such misconduct are not dischargeable in bankruptcy.
- What does the public record establish about Re Reza Khoshnik?
- 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.
- Which source supports this Re Reza Khoshnik 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.