Storylines Global Inc. v. The Smith Family Trust
- Rochon
- 1:25-cv-05419
- U.S. District Court · Southern District of New York
- 2
In Storylines Global Inc. v. The Smith Family Trust, Judge Rochon ordered plaintiffs to explain an erroneous citation after they voluntarily dismissed the case.
The plaintiffs, who were ordered to file an explanatory letter by July 17, 2025, and their counsel, whose filings are the subject of the court’s inquiry.
What happened
Storylines Global Inc. v. The Smith Family Trust began when the plaintiffs sued the defendants and asked to file their complaint under seal. The court could not locate a case the plaintiffs cited in support of that request.
The court ordered the plaintiffs to provide a corrected citation or explain the apparent error by July 7, 2025. Instead, the plaintiffs voluntarily dismissed the case and apologized for the citation, without providing the requested explanation.
Although the case was closed, Judge Rochon ruled that the court could still manage its proceedings and protect its authority. She ordered the plaintiffs to file, by July 17, 2025, a fuller explanation of the citation, including whether artificial intelligence generated the citation or the sealing motion without proper review.
The detailed version
- Storylines Global Inc. v. The Smith Family Trust · No. 1:25-cv-05419
- Rochon
- July 10, 2025
Background
Storylines Global Inc., Storylines Narrative AG & Co KG, and Alister Punton sued The Smith Family Trust and Horace Halsey Smith. The plaintiffs moved to file their publicly filed complaint under seal.
The plaintiffs’ motion cited “Epstein v. Epstein, No. 19 Civ. 5555 (JMF), 2019 WL 3317280 (S.D.N.Y. July 24, 2019).” On July 2, 2025, the court said it could not locate that authority and ordered the plaintiffs to file a letter by July 7 providing a corrected citation or addressing the apparent inaccuracy.
Instead of filing the required letter, the plaintiffs filed a notice of voluntary dismissal under Federal Rule of Civil Procedure 41(a)(1). They apologized for the error and withdrew the filing. They did not comply with the July 2 order by explaining the nonexistent or erroneous citation.
Court’s Authority and Order
The court stated that, although the case was closed, it retained ancillary jurisdiction—the limited authority to manage the case and enforce its orders after the main proceeding ended. The court relied on that authority to require a further filing.
Judge Jennifer L. Rochon ordered the plaintiffs to file a letter by July 17, 2025, providing a more complete explanation for the erroneous citation. The letter must address whether the citation, or the sealing motion overall, was generated through an artificial-intelligence tool without appropriate review. The opinion does not state any further disposition of the underlying claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.