There has been a lot of back and forth about AI mistakes in case citation, and overly unreasonable reliance on AI in guiding legal arguments. We think that Kleyman Law Group, P.C. v Kaloidis 2026 NY Slip Op 31557(U) April 13, 2026 Supreme Court, Kings County Docket Number: Index No. 502644/25 Judge: Heela D. Capell is the most forceful example of this that we have (ever) seen. The Decision is so long that we can present only snippets. Definitely read through the footnotes to see the fake citations and fabricated call logs that surface.

“Upon the foregoing papers, Kleyman Law Group, P.C. (“Plaintiff’ or “KLG”) moves, in motion (mot.) sequence (seq.) 1, for an order pursuant to CPLR 321 l(a)(l), (a)(2), and (b) dismissing James Kaloidis, as Executor of the Estate of George Kaloidis’ (“Defendant”) affirmative defenses and counterclaims. Plaintiff moves, in mot. seq. 2, for an order pursuant to 22 NYCRR § 130-1.1, awarding it sanctions against Defendant in the amount of $20,000 for allegedly filing an alleged frivolous ethics complaint against Plaintiffs principal attorney, Alex I. Kleyman (“Mr. Kleyman”) and for filing an answer in the instant action which contained alleged frivolous counterclaims and affirmative defenses. Plaintiff further moves for attorney’s fees in the amount of $50,000 for the time it spent defending against the alleged frivolous filings. Plaintiff moves, in mot. seq. 3, for an order, pursuant to CPLR 6201(1), 6201(3), and 6212(a) granting a prejudgment attachment of Defendant’s full ownership interest in Sheepshead Restaurant Associates, Inc. (“SRA”), granting a prejudgment attachment of all proceeds received or to be received by Defendant from the sale of the SRA property, authorizing Plaintiff to file a lien or security interest and to restrain transfer, concealment, or dissipation of all proceeds from the sale of the SRA property, directing Defendant to disclose all entities, accounts, contracts, and distributions related to the SRA property sale, directing Defendant, within 10 days of service of the court’s order, to disclose under oath a complete list of all assets, corporate interests, and proceeds held by Defendant, and requiring Plaintiff to post an undertaking in an amount fixed by the court. 1 Plaintiff also moves, in mot. seq. 4, for an order, pursuant to CPLR 3212, granting it summary judgment under its breach of contract claim and awarding it $1,246,000.00 in damages along with contractual interest at the rate of 18% per year on unpaid balances or, alternatively prejudgment interest at the 9% statutory rate. Defendant cross-moves, in mot. seq. 5, for an order sanctioning Plaintiff/Mr. Kleyman for the filing of an alleged frivolous motion for sanctions and for citing to fictitious cases and/or misrepresenting the holdings of cases in its legal papers (i.e., mot. seq. 2). Plaintiff moves, in mot. seq. 6, for an order continuing the temporary restraints which preclude Defendant from transferring, encumbering, dissipating or otherwise disposing of $2,000,000 of any proceeds received from the pending sale of SRA property or its 50% membership interest therein during the pendency of this action and pending the resolution of mot. seq. 3. In the alternative, Plaintiff seeks an order directing that no less than $2 million in net proceeds from the pending sale of SRA property be deposited and maintained in a segregated, interest-bearing IOLA or escrow account under the control of Defendant’s attorney or a neutral third-party escrow agent. Plaintiff further moves for an order waiving the undertaking requirement under CPLR 6312(b) in light of Plaintiffs
demonstrated financial hardship.”

“In summary, the court rules as follows: (1) Plaintiffs motion, in mot. seq. 1, for an order, pursuant to CPLR 321 l(a)(l), (a)(2), and (b), dismissing Defendant’s affirmative defenses and counterclaims is denied. Plaintiffs motion, in mot. seq. 2, for an order awarding sanctions and attorney’s fees against Defendant is denied. Plaintiffs motion, in mot. seq. 3, for an order, pursuant to CPLR 6201(1), 6201(3), and 6212(a), granting prejudgment attachment and directing various discovery and disclosure is denied.
Plaintiffs motion, in mot. seq. 4, which seeks summary judgment under its breach of
contract claim and summary judgment dismissing Defendant’s affirmative defenses and counterclaims is granted only to the extent that Defendant’s first, second, and fourth counterclaims are dismissed and the motion is otherwise denied. Plaintiffs motion, in mot. seq. 6, which seeks injunctive relief is denied and the temporary restraining order in the court’s June 12, 2025 order is vacated. Defendant’s cross motion, in mot. seq. 5, which seeks sanctions against Plaintiff/Mr. Kleyman is granted and this matter is set down for a hearing before the Court on June 9, 2026 at 10:00 A.M., at which time the amount of sanctions, as well as whether referral of Mr. Kleyman to the AGC is warranted, will be determined.”

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Andrew Lavoott Bluestone

Andrew Lavoott Bluestone has been an attorney for 40 years, with a career that spans criminal prosecution, civil litigation and appellate litigation. Mr. Bluestone became an Assistant District Attorney in Kings County in 1978, entered private practice in 1984 and in 1989 opened…

Andrew Lavoott Bluestone has been an attorney for 40 years, with a career that spans criminal prosecution, civil litigation and appellate litigation. Mr. Bluestone became an Assistant District Attorney in Kings County in 1978, entered private practice in 1984 and in 1989 opened his private law office and took his first legal malpractice case.

Since 1989, Bluestone has become a leader in the New York Plaintiff’s Legal Malpractice bar, handling a wide array of plaintiff’s legal malpractice cases arising from catastrophic personal injury, contracts, patents, commercial litigation, securities, matrimonial and custody issues, medical malpractice, insurance, product liability, real estate, landlord-tenant, foreclosures and has defended attorneys in a limited number of legal malpractice cases.

Bluestone also took an academic role in field, publishing the New York Attorney Malpractice Report from 2002-2004.  He started the “New York Attorney Malpractice Blog” in 2004, where he has published more than 4500 entries.

Mr. Bluestone has written 38 scholarly peer-reviewed articles concerning legal malpractice, many in the Outside Counsel column of the New York Law Journal. He has appeared as an Expert witness in multiple legal malpractice litigations.

Mr. Bluestone is an adjunct professor of law at St. John’s University College of Law, teaching Legal Malpractice.  Mr. Bluestone has argued legal malpractice cases in the Second Circuit, in the New York State Court of Appeals, each of the four New York Appellate Divisions, in all four of  the U.S. District Courts of New York and in Supreme Courts all over the state.  He has also been admitted pro haec vice in the states of Connecticut, New Jersey and Florida and was formally admitted to the US District Court of Connecticut and to its Bankruptcy Court all for legal malpractice matters. He has been retained by U.S. Trustees in legal malpractice cases from Bankruptcy Courts, and has represented municipalities, insurance companies, hedge funds, communications companies and international manufacturing firms. Mr. Bluestone regularly lectures in CLEs on legal malpractice.

Based upon his professional experience Bluestone was named a Diplomate and was Board Certified by the American Board of Professional Liability Attorneys in 2008 in Legal Malpractice. He remains Board Certified.  He was admitted to The Best Lawyers in America from 2012-2019.  He has been featured in Who’s Who in Law since 1993.

In the last years, Mr. Bluestone has been featured for two particularly noteworthy legal malpractice cases.  The first was a settlement of an $11.9 million dollar default legal malpractice case of Yeo v. Kasowitz, Benson, Torres & Friedman which was reported in the NYLJ on August 15, 2016. Most recently, Mr. Bluestone obtained a rare plaintiff’s verdict in a legal malpractice case on behalf of the City of White Plains v. Joseph Maria, reported in the NYLJ on February 14, 2017. It was the sole legal malpractice jury verdict in the State of New York for 2017.

Bluestone has been at the forefront of the development of legal malpractice principles and has contributed case law decisions, writing and lecturing which have been recognized by his peers.  He is regularly mentioned in academic writing, and his past cases are often cited in current legal malpractice decisions. He is recognized for his ample writings on Judiciary Law § 487, a 850 year old statute deriving from England which relates to attorney deceit.