Gutierrez v. Lorenzo Food Group, Inc.
U.S. District Court, District of New Jersey · D.N.J. · New Jersey bar guidance
Verified May 14, 2026
- Citation
- Gutierrez v. Lorenzo Food Group, Inc., No. 24-cv-9173 (EP) (MAH), 2025 WL 3258258 (D.N.J. Nov. 21, 2025) (Padin, J.)
- Decided
- November 21, 2025
Summary
Plaintiff's counsel Geoffrey T. Mott filed an opposition to a motion to dismiss containing a fabricated quotation and several citations the court could not verify. After the motion-to-dismiss opinion flagged the discrepancies, Judge Evelyn Padin ordered Mr. Mott to disclose whether generative AI tools were used in drafting and to show cause why sanctions and a bar referral under Federal Rule of Civil Procedure 11 and New Jersey Rule of Professional Conduct 3.3(a) should not issue. Submissions from Mr. Mott, his paralegal Alyssa Berrent, and former associate Ravit Hiers gave conflicting accounts of who inserted the offending citations and when, prompting the court to set an evidentiary hearing.
- AI tool:
- Unspecified generative AI (use implied; under inquiry)
What sanction did the court impose?
No sanction yet. Judge Padin ordered an evidentiary hearing for December 15, 2025, with Mr. Mott, Ms. Berrent, and Ms. Hiers all to testify, and ordered Mr. Mott to produce by November 26, 2025 the disputed draft emails and attachments, all timesheets for the three timekeepers, and metadata for every draft of the opposition brief exchanged between January 24 and February 4, 2025.
Why does Gutierrez v. Lorenzo Food Group, Inc. matter for law firms using AI?
Gutierrez is unusual among AI-citation cases because the court ordered discovery into the drafting workflow itself, including draft metadata and timesheets, before deciding whether to sanction. For a managing partner, the lesson is that once unverifiable citations surface in a filing, the court’s inquiry can reach paralegals, former associates, and the firm’s internal version-control trail. A clean, contemporaneous record of who drafted, who cite-checked, and what tools touched a brief is no longer an internal hygiene matter; it is potential evidence.
Sources
Primary sources
Further reading
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.
- Whether generative AI was actually used to produce the offending citations is the subject of the ordered hearing; the November 21, 2025 memorandum order does not make that finding.
- Outcome of the December 15, 2025 hearing was not reviewed for this entry.