M.D. Fla.: Case Management and Scheduling Order, paragraphs 11-12 (Soehlig v. Experian In…
Hon. Harvey E. Schlesinger, Senior U.S. District Judge · U.S. District Court, Middle District of Florida, Jacksonville Division
Verified May 10, 2026
- Citation
- Case Management and Scheduling Order, paragraphs 11-12 (Soehlig v. Experian Info. Sols., Inc.) (Hon. Harvey E. Schlesinger, M.D. Fla.)
- Order date
- December 19, 2024
Summary
Reasonableness inquiry under Rule 11(b)(2) is not satisfied by mere reliance on generative AI; signing a filing constitutes certification of the matters in Rule 11.
What does the order require?
- Reasonableness inquiry under Rule 11(b)(2) is not satisfied by mere reliance on generative AI; signing a filing constitutes certification of the matters in Rule 11.
- Any use of AI for any court filing, with examples including OpenAI's ChatGPT and Google's Bard, requires a mandatory disclosure and certification.
- The certification must (1) identify the AI used, (2) identify the part of the filing drafted by AI, and (3) certify that the AI work product was diligently reviewed by a human for accuracy and applicability.
- Both attorneys and pro se litigants are subject to the rule (paragraph 11 expressly addresses both groups).
Practice areas: federal civil
What the rule requires
Senior Judge Schlesinger’s CMSO addresses generative AI in two consecutive paragraphs at the end of the case management order, paragraphs 11 and 12, both signed and entered as part of the operative case management framework. Paragraph 11 frames the AI rule as a Rule 11 reasonableness clarification: a party’s signature on a filing constitutes certification under Rule 11(b)(2), and “[p]arties should not assume mere reliance on generative artificial intelligence (‘AI’) will be reasonable inquiry.” Paragraph 12 imposes a mandatory disclosure and certification regime for any AI use in any filing, with three required elements: identification of the AI used, identification of the AI-drafted portion of the filing, and certification of human review for accuracy and applicability.
Three features distinguish this rule from the more common chambers-AI-rule pattern:
The rule’s scope is “any AI,” not just generative AI. Paragraph 12 reads “Using any AI (e.g., OpenAI’s ChatGPT or Google’s Bard),” with the named tools framed as examples rather than the rule’s outer bound. The “e.g.” framing brings non-generative AI tools (legal-research assistants, citation-checkers, predictive-coding software) within the literal scope of the disclosure requirement.
The rule applies to pro se litigants, not just attorneys. Paragraph 11 states that “[a]ll attorneys and pro se litigants appearing before this Court are reminded the reasonableness requirements of Rule 11,” explicitly extending the AI-reasonableness framing to self-represented parties.
The disclosure unit is the filing, not the litigation. Paragraph 12’s “any court filings” requires a fresh certification on every AI-assisted submission, rather than a one-time disclosure at the start of representation.
Quotable language
Paragraph 11: “All attorneys and pro se litigants appearing before this Court are reminded the reasonableness requirements of Rule 11 of the Federal Rules of Civil Procedure. This Court construes all filings as a certification, by the person signing the filed document, of the matters in the rule including the requirements in Rule 11(b)(2) relating to legal contentions. Parties should not assume mere reliance on generative artificial intelligence (‘AI’) will be reasonable inquiry.”
Paragraph 12: “Using any AI (e.g., OpenAI’s ChatGPT or Google’s Bard) for any court filings requires a mandatory disclosure/certification that (1) identifies the AI; (2) identifies the part of the filing drafted by AI; and (3) certifies that the AI work product was diligently reviewed by a human for accuracy and applicability.”
Verification posture
The full CMSO text was retrieved from PACER under the Soehlig docket and is preserved on the free RECAP archive at the storage URL cited above. Senior Judge Schlesinger’s chambers page on flmd.uscourts.gov posts seven publicly available templates (Civil Jury Trial Procedures 2023, Criminal Jury Trial Procedures 2023, Notice of Designation under Local Rule 3.05, Order for Preliminary Pretrial and Scheduling Conference, Pretrial Order Jury, Pretrial Order Non-Jury, Exhibit Labels and List); none contain the AI provisions reproduced above. Whether the AI paragraphs are a per-case addition or a chambers practice that has not been incorporated into the public templates is an open question that would require sampling Schlesinger’s CMSOs in other recent cases to answer.