EARL TAKEFMAN
v.
THE PICKLEBALL CLUB, LLC, ET AL.
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The trial court properly denied the motion to disqualify appellees' counsel, and the appellant shall show cause why he should not be sanctioned for citing nonexistent cases and misrepresenting case holdings.
[1] The submission of fake or hallucinated case citations in court filings, particularly when repeated after being identified by opposing counsel, constitutes abusive bad-fai…
Previewing 1 of 1 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“Since the remedy of disqualification strikes at the heart of one of the most important associational rights, it must be employed only in extremely limited circumstances.”
Court's rationale for affirming denial of disqualification motion, citing Coral Reef of Key Biscayne Devs., Inc. v. Lloyd's Underwriters at London, 911 So. 2d 155, 157 (Fla. 3d DCA 2005).
Earl Takefman appealed the trial court's denial of his motion to disqualify the appellees' counsel. In his appellate briefs, Takefman cited cases that…
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Third District Court of Appeal State of Florida
Opinion filed August 27, 2025. Not final until disposition of timely filed motion for rehearing.
________________
No. 3D25-0474 Lower Tribunal No. 23-26281-CA-01 ________________
Earl Takefman, Appellant,
vs.
The Pickleball Club, LLC, et al., Appellees.
An Appeal from a non-final order from the Circuit Court for Miami-Dade County, Lisa S. Walsh, Judge.
Earl Takefman, in proper person.
Nelson Mullins Riley & Scarborough, LLP, and Scott N. Sherman (Atlanta, GA) and Joshua R. Lewin, for appellees.
Before EMAS, LINDSEY and BOKOR, JJ.
PER CURIAM.
2
Earl Takefman appeals the trial court’s denial of his motion to disqualify the appellees’ counsel. We affirm without further discussion. See Coral Reef of Key Biscayne Devs., Inc. v. Lloyd’s Underwriters at London, 911 So. 2d 155, 157 (Fla. 3d DCA 2005) (“Since the remedy of disqualification strikes at the heart of one of the most important associational rights, it must be employed only in extremely limited circumstances.”); Stopa v. Cannon, 330 So. 3d 1033, 1036 (Fla. 2d DCA 2021) (“[I]f Mr. Cannon wants Attorney McGrath’s continued legal services despite a purported conflict, Mr. Stopa has not explained how he, Mr. Stopa, is harmed.”); Pagidipati v. Vyas, 353 So. 3d 1204, 1211 (Fla. 2d DCA 2022) (“In most cases, a stranger to the attorney-client relationship lacks standing to seek disqualification.”).
We write, however, to address an issue of growing concern—the proliferation of fake or hallucinated case citations in court filings. We aren’t the only court in Florida to address this problem. See ByoPlanet Int’l, LLC v. Johansson, No. 25-CV-60630, 2025 WL 2091025, at *5 (S.D. Fla. July 17, 2025) (explaining that repeated citations to hallucinated cases “constitutes repeated, abusive, bad-faith conduct” warranting sanctions); O’Brien v. Flick, No. 24-61529-CIV, 2025 WL 242924, at *6 (S.D. Fla. Jan. 10, 2025) (agreeing that relying on non-existent law in a court filing is an improper purpose). We aren’t even the first panel of this court to address this problem.
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