MOSZKOWSKI
v.
DEEPGULF, INC. AND TOKE OIL AND GAS, S.A.
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The trial court's judgment is affirmed, and the appellant is warned that future use of fabricated or unchecked sources in court filings may result in sanctions.
[1] A pro se litigant's repeated use of fabricated case citations or citations to cases addressing unrelated issues in court filings may subject the litigant to sanctions und…
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Join FLexlaw to unlock all legal intelligence“his future use of fabricated or unchecked sources in court filings may result in sanctions”
Warning issued to appellant regarding improper citations in pro se briefs
Moszkowski appealed a judgment from the Circuit Court for Escambia County against him and in favor of Deepgulf, Inc. and Toke Oil and Gas, S.A.…
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FIRST DISTRICT COURT OF APPEAL
STATE OF FLORIDA
MARC M. MOSZKOWSKI, Appellant, v. No. 1D2025-2912
DEEPGULF, INC. and TOKE OIL AND GAS, S.A., Appellees.
On appeal from the Circuit Court for Escambia County. Jan Shackelford, Judge.
September 14, 2026
PER CURIAM.
AFFIRMED. We additionally warn Appellant that his pro se briefs were replete with case citations that either do not exist or fail to support his arguments. For example, Appellant cited to purported cases such as “Jackson v. Household Fin. Corp., 73 So. 3d 325, 38-29 (Fla. 1st DCA 2011)”; “Uniweld Prods., Inc. v. Indus. Polychemical Serus, Inc., 541 So. 2d 1311, 1314 (Fla. 4th DCA 1989)”; “Meyers v. Shoreline Found., Inc., 17 So. 3d 920, 923 (Fla. 4th DCA 2009)”; and “Pino v. Guetzloe, 995 So. 2d 532, 539 (Fla. 5th DCA 2008),” which don't exist. He cited multiple other cases which exist but address unrelated issues. With this opinion, we put Appellant on notice that his future use of fabricated or unchecked
sources in court filings may result in sanctions. See Fla. R. Gen. Prac. & Jud. Admin. 2.515(d)(2).
OSTERHAUS, C.J., and LEWIS and RAY, JJ., concur.