Mehrnaz Mortazavi v. Booz Allen Hamilton, Inc. et al

Filing 27

ORDER TO SHOW CAUSE RE SANCTIONS by Judge Stanley Blumenfeld, Jr. Plaintiff's repeated flouting of court rules and orders is unacceptable. Plaintiff is ordered to show cause at the mandatory scheduling conference on September 27, 2024, why sh e and her counsel should not be sanctioned under: (1) Rule 16(f) for violating the Court's orders; and (2) Rule 11 for filing a motion without performing a reasonable inquiry into whether its legal and factual contentions are supported. (SEE DOCUMENT FOR FURTHER DETAILS.) (rolm)

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

MEHRNAZ MORTAZAVI,

Case No. 2:24-cv-07189-SB-RAO

Plaintiff,
ORDER TO SHOW CAUSE RE
SANCTIONS

v.
BOOZ ALLEN HAMILTON, INC. et
al.,
Defendants.

The Court’s Civil Standing Order requires a party who uses generative
artificial intelligence (AI) in drafting any portion of a filing to provide “a separate
declaration disclosing the use of artificial intelligence and certifying that the filer
has reviewed the source material and verified that the artificially generated content
is accurate and complies with the filer’s Rule 11 obligations.”
After identifying considerable errors in Plaintiff’s motion to remand,
including a citation to a nonexistent case, Dkt. No. 18, the Court ordered Plaintiff
to disclose whether generative AI was used in drafting the motion in accordance
with the Civil Standing Order, Dkt. No. 25. In response, Plaintiff filed a
declaration by her counsel revealing that counsel had used AI tools to draft the
motion without filing a declaration disclosing their use. Dkt. No. 26. Counsel
gives no reason for her noncompliance with the Standing Order and her thin
explanation for the errors in the motion does not demonstrate that she adhered to
her Rule 11 obligations.
This is Plaintiff’s third violation of the Court’s orders. The Court previously
found that Plaintiff (and Defendant Booz Allen Hamilton) did not comply with the
meet and confer requirements under the Local Rules and Standing Order and
warned that further noncompliance could warrant sanctions. Dkt. No. 15. Despite
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this warning, Plaintiff again violated court rules and orders. She filed her motion
to remand on September 11, 2024, after meeting and conferring with Booz Allen
the same day, Dkt. No. 18, contravening both the Court’s order that she file the
motion by September 6, Dkt. No. 14, and Local Rule 7-3, Dkt. No. 19. This late
filing prompted the Court to issue a “final warning” admonishing Plaintiff for her
continued noncompliance. Id.
Plaintiff’s repeated flouting of court rules and orders is unacceptable.
Plaintiff is ordered to show cause at the mandatory scheduling conference on
September 27, 2024, why she and her counsel should not be sanctioned under:
(1) Rule 16(f) for violating the Court’s orders; and (2) Rule 11 for filing a motion
without performing a reasonable inquiry into whether its legal and factual
contentions are supported.

Date: September 26, 2024

___________________________
Stanley Blumenfeld, Jr.
United States District Judge

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