Disgraced former Trump attorney Michael Cohen reportedly used artificial intelligence to produce “fictitious citations” for a court case.

“The fictitious citations were used by the lawyer in a motion submitted to a federal judge, Jesse M. Furman,” according to The New York Times.

“Mr. Cohen, who pleaded guilty in 2018 to campaign finance violations and served time in prison, had asked the judge for an early end to the court’s supervision of his case now that he is out of prison and has complied with the conditions of his release.

Former Trump lawyer Michael Cohen did legal research for his own lawyer. He apparently fed his lawyer cases to cite in a filing with a federal court. Turns out the cases were fake ones Cohen got by using Artificial Intelligence. Oof. pic.twitter.com/pCTIABpNpx

— Don Lewis (@DonLew87) December 30, 2023

In a new court filing submitted Friday, Cohen fessed up to having used the fake citations, though he claimed he’d used them unwittingly.

Yet he also admitted that the fake citations originated with Google Bard, an artificial intelligence-driven chatbot similar to ChatGPT, raising the question of why he’d relied on a bot for citations in the first place.

In the filing Friday, he argued he’d simply been unaware that Google Bard produces fake content.

“As a non-lawyer, I have not kept up with emerging trends (and related risks) in legal technology and did not realize that Google Bard was a generative text service that, like Chat-GPT, could show citations and descriptions that looked real but actually were not,” he wrote in the filing, according to CNN.

“Instead, I understood it to be a super-charged search engine and had repeatedly used it in other contexts to (successfully) find accurate information online,” he added.

The filing was submitted Friday in response to Judge Furman demanding earlier in the month that one of Cohen’s attorneys, David Schwartz, explain where the citations came from. At the time, the judge said that, as far as he could tell, “none of these cases [cited by the original motion] exist.”

According to Cohen, when he’d submitted the citations, he’d assumed Schwartz would double-check them first before including them in any filings/motions.

In a declaration signed December 15, Schwartz claimed he didn’t “independently review” the citations because he thought Cohen’s other attorney, Danya Perry, had found them.

“If I had believed that Mr. Cohen had found these cases, I would have researched them,” he said. “It was my belief, however, that Mr. Cohen had sent me cases found by Ms. Perry.”

The problem is that Perry has alleged in a letter that Schwartz’s claim that he’d thought the citations had been reviewed by her was “incorrect and I believe, far-fetched, as I had no involvement in any back-and-forth — not directly with Mr. Schwartz or his paralegal and not even indirectly through Mr. Cohen.”

Because of this, some critics suspect Cohen had purposefully misled Schwartz:

A few weeks back, a federal judge noticed attorneys for Michael Cohen were using fake cases – and demanded an explanation.

It turns out Cohen was using AI to help write his own motions – and was apparently misleading his lawyer about the source of those cases. pic.twitter.com/yGyX6N8VHC

— Techno Fog (@Techno_Fog) December 29, 2023

In fairness to critics, Cohen is a known liar — a “serial” one, in fact, according to his former legal adviser, who testified against his credibility back in March.

“There can be no doubt in anyone’s mind that Michael Cohen has great difficulty telling the truth,” Robert Costello testified. “He is, after all a convicted perjurer, and our track record with Mr. Cohen convinced us that he was a serial liar.”

“As might be expected, Mr. Cohen’s lies were always uttered in a way that was beneficial to himself. When it was in Mr. Cohen’s personal self-interest, he was capable of telling the truth, but those occasions were few and far between,” he added.

Based on Cohen’s past, critics suspect he just committed fraud/perjury, though they’re uncertain whether he’ll face any consequences as he’s one of the left’s star witnesses against former President Donald Trump:

How many times is cohen going to perjure himself and lie to the courts without consequence?

— Sunshine State of Mind ⛅️ (@foundinsunshine) December 29, 2023

Let me see if I understand. This person used a “super charged search engine” and then just copied and pasted the results? Isn’t that plagiarism too?

— AJ (@AJNoiter) December 29, 2023

This is the same KNOWN PURJUROR @TishJames used as her star witness in the fake Trump fraud case! Wonder if Cohen will face new perjury charges?? . Democrat assholes!!

— Jonny Palermo (@badboy1708) December 29, 2023

Fraud against the Court is acceptable & even encouraged if it supports the cause against Trump. Cohen is a convicted serial liar that keeps on lying yet The Left continues to prop him up as credible simply because his lies support their lies.

— Rob⚡USA (@Alpine80s) December 30, 2023

• About
• Latest Posts

Vivek Saxena

Senior Staff Writer
Vivek@bizpacreview.com

V. Saxena is a staff writer for BizPac Review with a decade of experience as a professional writer, and a lifetime of experience as an avid news junkie. He holds a degree in computer technology from Purdue University.

Latest posts by Vivek Saxena (see all)

• Mammoth teacher’s union, NEA shoveling some of the worst woke garbage in history - December 18, 2025
• Vanity Fair’s extreme photo of Karoline Leavitt is shameful by any standard - December 18, 2025
• Middle school celebrates ‘Transgender Awareness Week’ with lessons on binding body parts - December 9, 2025

Comment

We have no tolerance for comments containing violence, racism, profanity, vulgarity, doxing, or discourteous behavior. Thank you for partnering with us to maintain fruitful conversation.