Judge Leonie Brinkema of the Eastern District of Virginia is presiding over one of the biggest antitrust cases in history — the DOJ's second case against Google — and her courtroom sits in a district that was among the first to require AI disclosure. Appointed by President Clinton in 1993, she's handled some of the most sensitive cases in the federal system, from the Zacarias Moussaoui terrorism prosecution to massive tech antitrust litigation.

For practitioners: the Eastern District of Virginia started requiring AI disclosure in January 2024, when several judges began issuing scheduling and pretrial orders mandating that parties identify AI use in filings and certify citation accuracy. Judge Brinkema's courtroom — already one of the fastest-moving in the country (EDVA is called the "Rocket Docket") — demands both speed and precision. There's no room for AI-generated sloppiness.

Eastern District of Virginia AI Disclosure Requirements

In January 2024, several EDVA judges — including Judge Roderick Young, Judge M. Hannah Lauck, and Judge David Novak — began issuing scheduling and pretrial orders requiring all parties who use AI to prepare any filing to identify the use of AI in that filing and provide a certification that they have reviewed all citations for accuracy. This makes EDVA one of the earliest federal districts to address AI use in filings. The requirements typically appear in individual scheduling orders rather than as standalone standing orders, meaning the specific language may vary by judge and case. Practitioners before Judge Brinkema should review all scheduling and pretrial orders carefully for AI-specific provisions.

The Google Antitrust Case: Tech Litigation at the Highest Level

Judge Brinkema is presiding over United States v. Google LLC — the DOJ's second antitrust case against Google, focused on the company's dominance in digital advertising technology. This case involves enormous volumes of technical data, expert testimony on algorithmic systems, and complex market analysis. The trial began in 2025 and involves some of the most sophisticated technology litigation in federal court history. For AI compliance, this case is instructive: when dealing with technically complex material at this scale, the temptation to use AI tools is high but the risks of error are catastrophic. Judge Brinkema's courtroom demands the accuracy these high-stakes cases require.

Judge Brinkema's Background: National Security, Tech, and the Rocket Docket

Judge Brinkema has one of the most remarkable case histories in the federal judiciary. She presided over the Zacarias Moussaoui prosecution — the first federal terrorism case after 9/11 — where she managed classified evidence and held the government accountable for discovery violations. She's handled the Ed Snowden litigation and other national security matters requiring the highest security clearances. In handling classified material, Brinkema has consistently prioritized defendants' Sixth Amendment rights while employing protective mechanisms for sensitive information. EDVA's reputation as the "Rocket Docket" — the fastest federal civil court in the country — means her cases move quickly. Attorneys must be prepared from day one.

Practical Compliance Steps for Filing Before Judge Brinkema

Step 1: Review every scheduling and pretrial order for AI disclosure provisions. EDVA's requirements typically appear in case-specific orders rather than standalone standing orders. Step 2: If AI was used in any filing, disclose it and certify that all citations were reviewed for accuracy. Step 3: In the Google antitrust case or similar tech litigation, be especially careful with technical accuracy. AI-generated analysis of algorithmic systems or market data must be independently verified by experts. Step 4: Do not input classified or confidential case material into public AI tools. Judge Brinkema's national security experience means she takes information security seriously. Step 5: Prepare for EDVA's fast pace. The Rocket Docket means deadlines are tight — build AI verification into your workflow so it doesn't become a bottleneck.

Virginia has been active on AI legislation. The Virginia General Assembly passed the High-Risk Artificial Intelligence Developer and Deployer Act (HB 2094) in February 2025, which would have been the second comprehensive state AI law. However, Governor Youngkin vetoed it in March 2025, calling the framework too burdensome for smaller firms. At the court level, Virginia's state bar has issued guidance requiring AI use to comply with existing rules of professional conduct. The combination of aggressive federal court AI requirements in EDVA and the state's evolving legislative landscape means practitioners in Virginia need to track both federal and state developments.

The Bottom Line: EDVA is one of the first federal districts to require AI disclosure in filings. Before appearing before Judge Brinkema, review all scheduling and pretrial orders for AI provisions, certify citation accuracy, and never input classified or confidential material into public AI tools. The Rocket Docket moves fast — build compliance into your workflow from day one.

AI-Assisted Research. This piece was researched and written with AI assistance, reviewed and edited by Manu Ayala. For deeper takes and the perspective behind the research, follow me on LinkedIn or email me directly.