Argument Against Sanctions for Lawyer's Filing of Motion That Contained AI-Hallucinated Cases

The memorandum of law, filed by the lawyer's counsel, is here. It seems quite well argued, though I don't agree with the backup argument (in Part II.E) that the lawyer's reliance on ChatGPT as a source for the supposed text of precedents was not just innocent but "reasonabl[e]." Here's the opening paragraph of the introduction:

In the Order, the Court describes this situation as "unprecedented." We agree. We can find no case where, as here, a lawyer using a new, highly-touted research tool obtained cases that the research tool itself completely made up. The lawyer, Mr. Schwartz, had no idea this was happening, even when opposing counsel brought their inability to locate the cases to his attention. ChatGPT even assured him the cases were real and could be found on Westlaw and LexisNexis, and continued to provide extended excerpts and favorable quotations. Now that Mr. Schwartz and the Firm know ChatGPT was simply making up cases, they are truly mortified; they had no intention of defrauding the Court, and the mere accusation – repeated in hundreds (if not thousands) of articles and online posts – has irreparably damaged their reputations. They have apologized to the Court in earlier submissions and do so again here.