Morgan Cole v. Hobby Town Unlimited, Inc.
Repeat offender (verified in the record)
The case
C.D. Ill., No. 4:25-cv-04217-SLD-RLH: order to show cause July 24, 2026 (2026 WL 2138008); final sanctions order September 2, 2026. OSC order: https://www.damiencharlotin.com/documents/2703/Cole_v._Hobby_Town_USA_24_July_2026.pdf
What happened
Plaintiff's counsel David Baldemar Reyes of Equal Access Law Group PLLC (Brooklyn, NY) filed a motion for default judgment in an ADA website-accessibility case containing several citations that appeared fabricated or did not support the propositions stated.
The rule and the sanction
Final sanctions order September 2, 2026: Rule 11 violation found. Reyes admitted preparing an AI-assisted template that inserted hallucinated citations and filing it without independent verification. Aggravating: similar hallucinations in multiple matters (including Hippe and Pittman), and Reyes had promised another court on January 20, 2026 to verify every authority, then filed the defective motion seven days later. Sanction: $1,000 fine (payable within 60 days), the order to be sent to the Illinois Attorney Registration and Disciplinary Commission, and a compliance status report within 60 days. No attorneys' fees (no timely request).
How it could have been avoided
Default-judgment motions get the same verification as contested briefs, an unopposed motion with fake citations still misleads the court. Out-of-state counsel appearing in a forum should know that forum's AI rules before filing.