Former Trump attorney Michael Cohen admitted in a statement unsealed on Friday that he inadvertently sent his lawyer three nonexistent cases to cite in a court filing after using the artificial intelligence program Google Bard to generate them.
Cohen’s attorney David Schwartz used the three phony citations on Nov. 29 in a letter to a New York federal court requesting that Cohen’s supervised release be terminated early.
Cohen has been under court supervision since 2021, when he concluded his three-year prison sentence for tax evasion and illegal campaign contributions.
Cohen, having been disbarred as a lawyer, blamed the incident on his lack of knowledge about “emerging trends” in the legal world, according to his unsealed statement, which he wrote on Dec. 15.
The former lawyer “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.
Cohen added that he thought Google Bard was a “supercharged search engine” and said he had successfully used it in the past to find true information.
The revelation comes after a judge in the case, who said she could not locate the three cases, ordered the lawyer who submitted the invented citations, David Schwartz, to respond to the court with any reasons why he should not be sanctioned over the matter.
Schwartz said in his response, which was also unsealed on Friday, that he had been under the impression that Cohen’s attorney E. Danya Perry had come up with the cases and that he therefore did not question them when Cohen emailed them to him to use.
“I failed to review what I thought was the research of another attorney,” Schwartz wrote.
“I sincerely apologize to the court for not checking these cases personally before submitting them to the court,” he added.
Cohen, for his part, said Schwartz was a “longtime friend” of his and called the incident an “honest mistake.” However, he also said he was stunned that Schwartz had not caught it.
“It did not occur to me then—and remains surprising to me now—that Mr. Schwartz would drop the cases into his submission wholesale without even confirming that they existed,” Cohen said.