A judge in Manhattan strongly criticized former lawyer David Schwartz, who represented Michael Cohen, for his "embarrassing" and "negligent" mistake of including fictitious cases produced by AI in court documents. The judge, Jesse Furman, stated that although Schwartz's actions displayed "extreme carelessness, " it was an honest mistake and not done in bad faith, therefore, he decided not to impose sanctions on Cohen or Schwartz. Cohen, who previously served as Donald Trump's attorney and "fixer, " confessed to mistakenly providing Schwartz with non-existent cases obtained from AI service Google Bard, which were then submitted to the court. Schwartz is no longer representing Cohen, according to his current attorney, retired judge Barry Kamins, who mentioned that the court acknowledged the mistake was not made in bad faith. The judge's decision also included denying the motion for early release from supervised release for Cohen, citing Cohen's potential perjury during his testimony in Trump's civil fraud trial and his guilty plea for tax evasion. Cohen admitted to the charges of tax evasion, violating campaign finance law, lying to banks, and lying to Congress, specifically regarding payments made on behalf of Trump to former porn star Stormy Daniels and former Playboy playmate Karen McDougal. Schwartz had attempted to utilize Cohen's testimony to support his argument for early release, claiming it demonstrated Cohen's willingness to provide truthful accounts and his commitment to upholding the law.

However, the judge deemed it "perverse" for Schwartz to interpret Cohen's admission to perjury as a commitment to upholding the law. Cohen's lawyer, Danya Perry, considered the judge's decision as an "important win" for Cohen due to the absence of sanctions. Perry disagreed with the judge's inference that Cohen committed perjury, noting that defendants often accept guilty pleas for crimes they did not commit due to coercive plea deals under pressure. Trump's attorney, Alina Habba, praised the judge's decision, stating that it confirmed Cohen's perjury and supported the need for prosecution. Trump's legal team has consistently argued that Cohen's testimony against their client is unreliable due to his alleged dishonesty and prior conviction. The Manhattan US Attorney's Office, responsible for prosecuting Cohen, declined to comment on the matter.