Kilinc v. PMMUE Eduservices Private Limited
U.S. District Court, Southern District of New York · S.D.N.Y. · New York bar guidance
Verified October 1, 2026
- Citation
- Kilinc v. PMMUE Eduservices Private Limited, No. 25 Civ. 7931 (AT) (GWG) (S.D.N.Y. Nov. 21, 2025) (order)
- Decided
- November 21, 2025
Summary
Pro se plaintiff Ege Kilinc filed a reply memorandum in support of a motion for preliminary injunction (Docket # 49) containing fabricated quotations and citations. Magistrate Judge Gabriel W. Gorenstein identified at least three defective citations, including a quote attributed to Best Van Lines, Inc. v. Walker, 490 F.3d 239 (2d Cir. 2007) that does not appear in that opinion, a quote attributed to Judge Torres in C.S. v. Columbia University that does not appear in any decision on that docket, and a quote attributed to D.D. ex rel. V.D. v. New York City Board of Education, 465 F.3d 503 (2d Cir. 2006) that does not appear in that opinion. The court noted other apparent fabrications throughout the brief.
- AI tool:
- Unspecified generative AI
How did the court address the AI-related conduct?
No monetary sanction imposed at this stage. Plaintiff was ordered to examine every citation in Docket # 49 and file a sworn statement on or before December 3, 2025 attaching two lists: List # 1 of citations he contends are accurate, and List # 2 of citations he now recognizes as improper, with an explanation for each (including the source of the improper citation). The court reserved the option to issue an order to show cause why sanctions should not issue after reviewing the statement. No order to show cause followed: the March 4, 2026 report and recommendation on the preliminary-injunction motion (Doc. 122) does not address the citations.
Why does Kilinc v. PMMUE Eduservices Private Limited matter for law firms using AI?
Kilinc illustrates how courts are now treating pro se filings under the same citation-verification standard articulated in Mata v. Avianca, which Magistrate Judge Gorenstein quoted directly. For managing partners, the case is a reminder that the court’s first move on detecting fabricated quotes is often a compelled audit by the filer, requiring an attorney or party to alphabetize, characterize, and explain every citation in the offending brief before the court decides whether formal sanctions follow.
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.