Kilinc v. PMMUE Eduservices Private Limited
- Analisa Torres
- 1:25-cv-07931
- U.S. District Court · Southern District of New York
- 2
In Ege Kilinc v. PMMUE Eduservices, Magistrate Judge Gorenstein ordered a sworn citation review after identifying apparent fabricated quotations and citations.
Ege Kilinc is required to review the citations in Docket No. 49 and submit the specified sworn statement by December 3, 2025. The defendants are not ordered to take any action in this opinion.
What happened
In Ege Kilinc v. PMMUE Eduservices Private Limited et al., the court identified several quotations or citations in Ege Kilinc’s reply brief supporting a preliminary-injunction motion that appeared fabricated or inaccurate. The court gave three examples, including quotations attributed to decisions that did not contain them.
The court directed Ege Kilinc to examine every case citation in the brief. By December 3, 2025, he must file a sworn statement with one list of citations he believes are accurate and another list identifying citations he recognizes as improper, explaining each problem and why it was included. He must also disclose any false or fabricated citations he knows about in other filings.
Magistrate Judge Gorenstein did not impose a sanction in this order. He stated that the court would issue an order requiring the plaintiff to explain why sanctions should not be imposed if, after reviewing the sworn statement, the court believes a sanction may be appropriate.
The detailed version
- Kilinc v. PMMUE Eduservices Private Limited · No. 1:25-cv-07931
- Analisa Torres
- Nov. 21, 2025
What prompted the order
The court said it had identified a number of fabricated quotations or citations in Ege Kilinc’s filing titled “PLAINTIFF’S REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION,” filed at Docket No. 49. The order described three examples:
- A quotation attributed to Best Van Lines, Inc. v. Walker did not appear in the cited case. - A cited case involving Columbia University had the stated case name and docket number, but the docket did not show a decision by Judge Torres containing the quoted language. - A quotation attributed to a Second Circuit decision did not appear in that decision.
The court added that there appeared to be other fabricated citations or quotations in the filing.
Required sworn statement
The court directed the plaintiff to examine every case citation in Docket No. 49 and file a sworn statement by December 3, 2025. The statement must include or attach two alphabetical lists:
1. A list of citations the plaintiff contends are accurate. 2. A list of citations the plaintiff recognizes as improper for any reason, including a fabricated quotation, incorrect case name, incorrect database citation, incorrect docket number, unsupported legal proposition, nonexistent case, or another inaccuracy.
For each citation on the second list, the plaintiff must explain how it was improper or inaccurate and why it was included, including the source of the citation if known. The plaintiff may provide a corrected citation if one exists and must disclose any false or fabricated citations known to appear in documents other than Docket No. 49.
Disposition
The order required the sworn statement but did not decide whether sanctions would be imposed. The court stated that it would issue an order requiring the plaintiff to show why sanctions should not be imposed if it later believed sanctions might be appropriate. The opinion identifies Gabriel W. Gorenstein as the United States magistrate judge who issued the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.