Dubinin v. Papazian

Dubinin v. Papazian, No. 25-CV-23877-RAR (S.D. Fla.), Order Striking Complaint, Entering Sanctions, and Referring Counsel to the Florida Bar and Grievance Committee (Document 14), entered November 21, 2025. Federal district court. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-112-dubinin-v-papazian.pdf`.

Plaintiff's counsel Missiva Tilleli Khacer (Florida Bar) signed and filed a response containing at least ten instances of nonexistent cases and fabricated quotations. She had delegated drafting to attorney Nataliya Gavlin (New York Bar, no pro hac vice admission, no appearance entered), who in turn had delegated drafting to her legal assistant, who used generative AI. Khacer admitted she failed to independently review and verify each citation before filing. The court found a pattern of similar misconduct across Khacer's immigration mandamus cases in the district.

Rule 11, Federal Rules of Civil Procedure; 28 U.S.C. 1927; the court's inherent authority; and S.D. Fla. Local Rules incorporating the Rules Regulating the Florida Bar. Sanctions: the complaint stricken; the case dismissed without prejudice; Khacer ordered to pay the defendant's attorneys' fees of $4,030.90; Khacer referred to the Florida Bar and to the court's Ad Hoc Committee on Attorney Admissions, Peer Review, and Attorney Grievance; Gavlin referred to the Florida Bar and the Grievance Committee for investigation of her conduct in the district.

(a) The signing attorney is responsible: delegating to a non-appearing attorney and a legal assistant does not transfer the duty to verify. (b) Unauthorized practice overlays: letting a non-admitted attorney lead cases in the district multiplied the exposure. (c) Repeated failures to prosecute plus AI hallucinations equal a pattern the court will punish as bad faith, not isolated error.

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