Ader v. Ader
Supreme Court of New York, New York County · N.Y. Sup. Ct. (N.Y. Cnty.) · New York bar guidance
Verified May 14, 2026
- Citation
- Ader v. Ader, No. 653917/2024, 2025 N.Y. Misc. LEXIS 7848, 2025 NY Slip Op 51563(U) (Sup. Ct. N.Y. Cnty. Oct. 1, 2025) (Cohen, J.)
- Decided
- October 1, 2025
Summary
Plaintiff Pamela Ader, executor of her late husband Richard Ader's estate, sought sanctions against defendants JS Property Holdings, LLC and Jason Ader, along with their counsel, Michael W.C. Fourte of the Law Offices of Michael Fourte (Verona, NJ). Defendants' summary judgment opposition contained AI-hallucinated citations and fabricated quotations, including one case that did not exist at all and others unrelated to the propositions cited. After plaintiff moved for sanctions, defendants' opposition to the sanctions motion itself contained more than double the original miscites: four citations that did not exist, seven quotations that did not appear in the cited cases, and three that did not support the propositions offered. At oral argument, counsel ultimately conceded that the false citations were AI-generated and unverified, after initially "vehemently den[ying]" the use of unvetted AI in his brief.
- AI tool:
- not named in order
What sanction did the court impose?
Justice Joel M. Cohen granted sanctions under 22 NYCRR section 130-1.1, holding defendants and their counsel jointly and severally liable for plaintiff's reasonable costs and attorney's fees incurred on the sanctions motion and in addressing the AI-fabricated citations in the summary judgment briefing, with the amount to be set on a fees application filed within 14 days. The court further directed plaintiff's counsel to transmit the decision to the Grievance Committee for the Appellate Division, First Department and to the New Jersey Office of Attorney Ethics, and provided a copy to the judge presiding over a separate matrimonial matter in which the same counsel represents Jason Ader.
Why does Ader v. Ader matter for law firms using AI?
Ader v. Ader is notable for two compounding failures by the same counsel: AI-fabricated citations in the underlying summary judgment opposition, and then additional AI-fabricated citations in the brief opposing the resulting sanctions motion, with the second round containing more than double the miscites of the first. The court’s invocation of the judicial reporting mandate at 22 NYCRR section 100.3(D)(2) and its referral to grievance authorities in both New York (First Department) and New Jersey illustrate that a single hallucination episode in a New York commercial case can trigger discipline review in every jurisdiction where sanctioned counsel is admitted.
Sources
Primary sources
Further reading
- https://caselaw.findlaw.com/court/ny-supreme-court/117805834.html
- Document mirror (Damien Charlotin hallucination database, Westlaw printout)
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.
- Specific dollar amount of the fee award not fixed in the October 1, 2025 decision; deferred to a subsequent fees application.