An attorney for Michael Cohen, Donald Trump’s former fixer and lawyer, asked a Manhattan federal judge on Wednesday not to sanction him for filing court papers that included fake case citations generated by artificial intelligence.
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David Schwartz apologized to U.S. District Judge Jesse Furman for citing the made-up cases and said he took responsibility. Cohen said last week that he inadvertently created the cases using the AI program Google Bard and provided them to Schwartz.
Schwartz said he had relied overly on Cohen rather than communicating directly with another lawyer on the case, E. Dayna Perry. He said that when he cited the cases he reasonably believed that Perry, not Cohen, had been responsible for researching them.
Cohen, who is expected to be a star witness against Trump at one of the former president’s criminal trials, told the judge last week he did not realize the citations he generated were fictitious.
The cases were cited in court papers backing Cohen’s bid to end his term of supervised release following his imprisonment for campaign finance violations.
Schwartz and Perry “were using Cohen as a conduit to funnel papers back and forth,” Schwartz’s lawyers said in Wednesday’s filing. “As it turns out, this was not a good idea in that certain issues fell through the cracks, most notably the source of the case citations.”
Perry, in her own letter filed last week, claimed Schwartz had no reason to believe that she and not Cohen had been the source of the cases. She said Schwartz “appears to have a history in this matter of inattentiveness to detail.”
Schwartz in Wednesday’s filing said he would “not respond in-kind to the various personal comments she has made about me.”
Schwartz, represented by retired New York state judges Barry Kamins and John Leventhal, declined to comment. Perry did not immediately respond to a request for comment.
Cohen was recently a witness in New York state Attorney General Letitia James’ civil fraud case against Trump.
He is expected to also testify in the state’s criminal case against Trump that accuses him of falsifying business records to hide reimbursements to Cohen for a $130,000 payment to silence porn star Stormy Daniels before the 2016 presidential election.
In a case unrelated to Cohen, two New York lawyers were sanctioned in June for submitting a legal brief that included six fictitious case citations generated by ChatGPT.
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