From Judge Kai Scott (E.D. Pa.) today in Bunce v. Visual Tech. Innovations, Inc.:
… Plaintiff … sought reasonable travel costs for a cancelled deposition. In response, Mr. Rajan filed an omnibus motion seeking sanctions and objecting to the Plaintiff's travel costs. Plaintiff responded accordingly, highlighting that although Mr. Rajan was sanctioned previously "for his use of made-up cases and other authorities that did not support his propositions[… ] Rajan has once again used a made-up case and cited to other authorities that don't support his propositions[.]" In his Reply, Mr. Rajan only briefly addressed this issue in a footnote.
On March 11, 2026, this Court Ordered Mr. Rajan to pay Plaintiff all reasonable travel costs, denying his omnibus motion and ordering him to show cause as to why his citations in his omnibus motion did not violate Rule 11(b) or this Court's Standing Order Re: Artificial Intelligence ("AI"). Mr. Rajan filed a response to the Court's Order to Show Cause in which he again responded to the claims of improperly using AI….
Contrary to his assertions, it was patently unreasonable for Mr. Rajan to file his omnibus motion with erroneous citations, at least one of which was made up. In his Response to the Court's Order to Show Cause, Mr. Rajan asserts that "[t]he question is whether a reasonable attorney, under the particular circumstances, would have acted similarly." He answers his own question in the affirmative, stating that a reasonable attorney would have filed the motion with the erroneous citations because the opposing party refused to confer with him on the matter of travel fees.
This is incorrect, both as a characterization of the governing law and what a reasonable attorney would do. As discussed above, the proper question is whether Mr. Rajan should have known that the citations in his filing were incorrect. He should have. As Rule 11 discusses, every attorney and pro se litigant must verify the veracity of their filings before submitting them to this Court. Full stop. It was not enough that Mr. Rajan felt like he had no other choice because opposing counsel refused to meet with him to discuss a matter that the Court already resolved.
