Michael Cohen, Donald Trump’s former attorney and fixer, claims he unwittingly gave his lawyers fake legal citations generated using artificial intelligence for use in his case, according to newly unsealed court records.
The citations, which were produced by Google Bard, were ultimately included in a motion to a Manhattan federal judge, with Cohen not realizing that his attorney “would drop the cases into his submission wholesale without even confirming that they existed,” he insisted in a sworn declaration.
Cohen, who is set to be a key witness in one of Trump’s upcoming criminal trials, added that he “did not realize that Google Bard was a generative text service that, like ChatGPT, could show citations and descriptions that looked real but actually were not.”
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The motion with the bogus citations was part of Cohen’s bid to end his supervised release after completing his prison sentence for campaign finance violations.
Federal District Court Judge Jesse M. Furman said he was unable to find three decisions cited by lawyer David M. Schwartz in the motion and ordered him to provide copies of the decisions in a Dec. 12 court order.
If Schwartz could not provide the copies within a week, the order said, he must give a sworn declaration with an explanation of “how the motion came to cite cases that do not exist and what role, if any, Mr. Cohen played in drafting or reviewing the motion before it was filed,” as well as an explanation for why he should not be sanctioned for providing false material.
“I deeply regret any problems Mr. Schwartz’s filing may have caused,” Cohen said in his latest filing.