Free template
Sanctions motion template + citation-verification affidavit
A free fillable template for a Rule 11(b) sanctions motion over AI-hallucinated citations, plus a citation-verification affidavit you can attach. Adapted from the structure used in the highest-cited sanctions orders in our sanctions database. Copy the blocks below, fill in the bracketed placeholders, and adapt with counsel before filing.
Not legal advice. Template only. Every jurisdiction, court, and safe-harbor window has its own procedural rules. Do not file without your own counsel reviewing the adapted motion against the local rules and the specific facts of your matter.
1. Motion for sanctions — Rule 11(b)
Copy this block into a fresh document. Replace every bracketed placeholder. Insert your exhibits after paragraph 6.
UNITED STATES DISTRICT COURT
[DISTRICT / DIVISION]
[PLAINTIFF NAME],
Plaintiff,
v. Case No. [CASE NUMBER]
[DEFENDANT NAME],
Defendant.
MOTION FOR SANCTIONS UNDER FEDERAL RULE OF CIVIL PROCEDURE 11(b)
Pursuant to Federal Rule of Civil Procedure 11(b) and 11(c),
[MOVING PARTY] respectfully moves this Court for sanctions
against [OPPOSING COUNSEL NAME] and [OPPOSING PARTY] for
submitting a filing containing legal citations that do not exist
in the primary sources they purport to cite.
1. On [DATE OF OPPOSING FILING], [OPPOSING COUNSEL] filed
[DOCUMENT TITLE] (ECF No. [X]) in the above-captioned matter.
2. That filing relies on the following case citations:
a. [CITATION 1], purporting to stand for [PROPOSITION];
b. [CITATION 2], purporting to stand for [PROPOSITION];
c. [CITATION 3], purporting to stand for [PROPOSITION].
3. [MOVING PARTY] conducted a citation-verification review of
each citation against CourtListener (Free Law Project) and
the primary reporter, on [VERIFICATION DATE]. The results
are memorialized in the attached Citation-Verification
Affidavit (Exhibit A) and the accompanying annotated
verification report (Exhibit B).
4. As set forth in Exhibit A and Exhibit B:
a. [CITATION 1] returns no matching decision in
CourtListener's federal + state case-law database.
b. [CITATION 2] returns a decision whose actual holding
and text differ materially from the pulled quotation
attributed to it by [OPPOSING COUNSEL].
c. [CITATION 3] returns no matching decision.
5. Rule 11(b) requires that, by presenting a filing, an
attorney certifies that "the claims, defenses, and other
legal contentions are warranted by existing law" — a
certification that cannot be satisfied where the cited
authorities do not exist. See [CITE CONTROLLING SANCTIONS
ORDER IN YOUR CIRCUIT — e.g., the reported orders indexed at
citationsafe.com/sanctions-database].
6. Accordingly, [MOVING PARTY] respectfully requests that the
Court:
a. Strike [DOCUMENT TITLE] (ECF No. [X]);
b. Order [OPPOSING COUNSEL] to show cause why sanctions
should not issue;
c. Award [MOVING PARTY] its reasonable attorneys' fees
incurred in identifying, verifying, and briefing this
motion; and
d. Grant such further relief as the Court deems just.
Respectfully submitted,
_____________________________
[MOVING COUNSEL NAME]
[BAR NO.]
[FIRM NAME]
[ADDRESS]
[PHONE / EMAIL]
Dated: [DATE]
Exhibit A: Citation-Verification Affidavit
Exhibit B: Annotated citation-verification report2. Citation-Verification Affidavit — Exhibit A
Attach as an exhibit to the motion above. If Citation Safe generated your annotated report, reference it in paragraph 4 and attach the exported JSON or print-to-PDF as Exhibit B.
AFFIDAVIT OF [AFFIANT NAME] IN SUPPORT OF MOTION FOR SANCTIONS
STATE OF [STATE] )
) ss.
COUNTY OF [COUNTY] )
I, [AFFIANT NAME], being duly sworn, depose and say:
1. I am [ROLE — e.g., counsel of record for Plaintiff in the
above-captioned matter / a paralegal employed by counsel of
record]. I am over 18 years of age and competent to testify
to the matters stated herein. The facts set forth in this
affidavit are within my personal knowledge, except where
stated on information and belief.
2. On [VERIFICATION DATE], I ran a citation-verification check
on every case citation contained in [DOCUMENT TITLE] (ECF
No. [X]), filed by [OPPOSING COUNSEL] on [FILING DATE].
3. The verification was performed against CourtListener (a
product of the Free Law Project, hosted at
https://www.courtlistener.com), which indexes the primary
text of federal and state court decisions. Where a
parallel reporter citation was available, I also
cross-checked against the reporter's primary source.
4. The complete annotated verification report is attached
hereto as Exhibit B and incorporated by reference. In
summary:
a. [N1] of the [TOTAL] citations returned NO matching
decision in the sources checked.
b. [N2] of the [TOTAL] citations returned a decision
whose text does not contain the pull-quote that
[OPPOSING COUNSEL] attributed to it.
c. [N3] of the [TOTAL] citations were VERIFIED — both
existence and quote-match were confirmed against
primary sources.
5. The verification-check timestamps for each citation are
set forth in Exhibit B and were within the same
verification session on [VERIFICATION DATE].
6. Nothing in this affidavit is offered as legal advice or as
a substitute for this Court's own review of the underlying
record.
I declare under penalty of perjury under the laws of the
United States of America that the foregoing is true and correct.
Executed on [DATE], at [CITY, STATE].
_____________________________
[AFFIANT NAME]
[AFFIANT ROLE / TITLE]
Sworn to and subscribed before me
this ___ day of __________, 20__.
_____________________________
Notary Public
My commission expires: ___________Need the annotated report to attach as Exhibit B?
Paste opposing counsel’s brief into Opposition Check — $49, no signup, deterministic verification against primary sources. You’ll get a per-citation annotated report you can attach directly to the motion above.
Digital Empire Holdings LLC · Wyoming · Not legal advice. Template only. Adapt with counsel before filing.