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Victor Kholod v. Nationstar Mortgage LLC

Court: M.D. Pennsylvania
Jurisdiction: USA
Decided: 2025-07-22
AI tool: Implied
Outcome: Warning
Monetary penalty: None reported

What was hallucinated

Fabricated: Case Law | According to Kholod, “PA Partnership Inc. v. XYZ Corp, 2020” “involved the wrongful withdrawal of funds from one company's account by another, resulting in compensation to the aggrieved party.” Doc 1-2 at 4. We have been unable to locate any possible case that might fit the description given for this case. Defendant Wells 5Fargo's brief in support stated that its search for this case was fruitless as well. Doc. 5 at 20. || Misrepresented: Case Law | 2. Per Kholod, in “Levy Baldante Finney & Rubenstein v. Wells Fargo Bank, 2018” “[t]he court held the company liable for failing to prevent unauthorized transactions.”Doc. 1-2 at 4. In its brief, Defendant Wells Fargo Bank points the court to Levy Baldante Finney & Rubenstein, P.C. v. Wells Fargo Bank, N.A., No. 3241 EDA 2016, 2018 WL 847756 (Pa. Super. Ct. Feb. 14, 2018). Doc. 5 at 20-21. This case, however, involved fraudulent endorsements on checks that had been withdrawn from a law firm's IOLTA accounts and business accounts. Levy Baldante Finney & Rubenstein, P.C., 2018 WL 847756, at *3. Neither the facts nor the legal analysis in this case supports Kholod's claim for relief. We were unable to find another case that fit the citation provided by Kholod. || Fabricated: Case Law | 3. Kholod also cites “Chasen v. Littman, 2019” in which, according to Kholod, “[t]he court considered the issue of unauthorized use of funds between companies.”Doc. 1-2 at 4. In its brief, Defendant Wells Fargo Bank provides the following as the proper citation for this case: L. Offs. of Bruce J. Chasan, LLC v. Pierce Bainbridge Beck Price & Hecht, LLP, No. 2:18CV-05399-AB, 2019 WL 1957950 (E.D. Pa. May 2, 2019), aff'd, 792 F. App'x 195 (3d Cir. 2019). Doc. 5 at 21. This case does not support Kholod's claim for relief; it involved an attorney's attempt to recover a contingency fee from an out of state attorney. L. Offs. of Bruce J. Chasan, LLC, 2019 WL 1957950 at *1–2. We were unable to find another case that fit the citation provided by Kholod. || Fabricated: Case Law | 4. Kholod states that in “Brown v. Wells Fargo, 2020” “[t]he court ruled that the bank must compensate the client $8,000 for wrongful withdrawals from their account.”Doc. 1-2 at 5. Construed liberally, this may be referring to Brown v. Wells Fargo Bank, N.A., No. C19-3041LTS, 2020 U.S. Dist. LEXIS 3614 (N.D. Iowa Jan. 7, 2020), or Brown v. Wells Fargo Bank N.A., No. 01-18-01002-CV, 2020 Tex. App. LEXIS 7106 (Tex. App. Sep. 1, 2020). However, these cases are factually unrelated to Kholod's claim. The Northern District of Iowa Brown case concerns alleged violations of the Fair Credit Reporting Act (FCRA), Fair Debt Collection Practices Act (FDCPA), and Iowa Debt Collection Practices Act (IDCPA) regarding a failure to make the required payments under a note and mortgage. Brown v. Wells Fargo Bank, N.A., No. C19-3041-LTS, 2020 U.S. Dist. LEXIS 3614, at *1. The Court of Appeals of TexasBrown case concerns a motion to dismiss the Plaintiff's appeal of a final judgment dismissing the plaintiff's garnishment suit. Brown v. Wells Fargo Bank N.A., No. 01-18-01002-CV, 2020 Tex. App. LEXIS 7106, at *1. Neither of these cases include any legal analysis that is useful for Kholod's claim.*7 || Misrepresented: Case Law | 5. According to Kholod, in “Smith v. First National Bank, 2017” “[t]he court ordered the bank to return $5,000 to the client after evidence showed that the withdrawal was made without the client's authorization.”Doc. 1-2 at 4. Though the year is different, the closest match to this case is Smith v. First Nat'l Bank, 837 F.2d 1575 (11th Cir. 1988). This case is not relevant to Kholod's claim; the case is an appeal of summary judgment in favor of the Defendant concerning alleged violations of the Fair Credit Reporting Act (FCRA).Smith, 837 F.2d at 1576–77. || Fabricated: Case Law | 6. Kholod states that in “Jones v. PNC Bank, 2018” “the court ordered the bank to return $3,750 for unauthorized transactions made by third parties.” Doc. 1-2 at 4. We found two cases that appear to match the named parties, but neither were published in the year Kholod provides: Jones v. PNC Bank, N.A., No. 10-CV-01077LHK, 2010 U.S. Dist. LEXIS 92866 (N.D. Cal. Aug. 20, 2010), and Jones v. PNC Bank, N.A., 630 F. Supp. 3d 959 (N.D. Ill. 2022). These cases do not appear factually related to Kholod's claims. The Northern District of California Jones case involved a dismissal of the Plaintiff's allegations of violations of the Real Estate Settlement Procedures Act (RESPA) due to failure to state a claim. Jones, No. 10-CV-01077-LHK, 2010 U.S. Dist. LEXIS 92866 at *1–2. The Northern District of Illinois Jones case granted the Defendant's motion to dismiss the Plaintiff's allegations of breach of contract regarding Guaranteed Asset Protection (GAP) as part of a retail installment contract (RIC) for a used car purchase. Jones, 630 F. Supp. 3d at 961. There is no legal analysis in either case that would be supportive of Kholod's claim for relief. || Fabricated: Case Law | 7. Per Kholod, in “Miller v. Citizens Bank, 2019” “[t]he court found the bank liable for unauthorized withdrawals amounting to $2,600 and ordered it to compensate the client for all losses.” Doc. 1-2 at 4. We found one case matching the named parties, but not the year: Miller v. Citizens Bank, N.A., No. 23-10563, 2025 U.S. Dist. LEXIS 93011 (E.D. Mich. May 15, 2025), but as this 6opinion was published after Kholod filed his complaint, we assume this is not the case to which he refers. We found no other cases fitting Kholod's description. || Fabricated: Case Law | 8. Kholod also cites “Davis v. TD Bank, 2021” in which, according to Kholod, “[t]he court ordered the bank to pay $4,200 to the client, citing the bank's failure to prevent fraudulent actions.” Doc. 1-2 at 5. The closest possible match is Davis v. TD Bank, N.A. (In re Davis), 447 B.R. 738 (Bankr. D. Md. 2011). Again, the case name matches but the year does not. Furthermore, the subject matter is unrelated to Kholod's complaint; Davis concerns an opposition to a debtors' motion and plan for repaying creditors in a bankruptcy proceeding. Davis, 447 B.R. at 740–41. There are a number of other cases where the named parties are variations of TD Bank USA, N.A. v. Davis throughout the country, none of which were published in the year Kholod cites and none of which appear to be related to Kholod's claim

Sanction teardown · M.D. Pennsylvania, USA · 2025-07-22

Victor Kholod v. Nationstar Mortgage LLC

What happened

In M.D. Pennsylvania, USA, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

Issue

Fabricated: Case Law | According to Kholod, “PA Partnership Inc. v. XYZ Corp, 2020” “involved the wrongful withdrawal of funds from one company's account by another, resulting in compensation to the aggrieved party.” Doc 1-2 at 4. We have been unable to locate any possible case that might fit the description given for this case. Defendant Wells 5Fargo's brief in support stated that its search for this case was fruitless as well. Doc. 5 at 20.
Misrepresented (Case Law)

2. Per Kholod, in “Levy Baldante Finney & Rubenstein v. Wells Fargo Bank, 2018” “[t]he court held the company liable for failing to prevent unauthorized transactions.”Doc. 1-2 at 4. In its brief, Defendant Wells Fargo Bank points the court to Levy Baldante Finney & Rubenstein, P.C. v. Wells Fargo Bank, N.A., No. 3241 EDA 2016, 2018 WL 847756 (Pa. Super. Ct. Feb. 14, 2018). Doc. 5 at 20-21. This case, however, involved fraudulent endorsements on checks that had been withdrawn from a law firm's IOLTA accounts and business accounts. Levy Baldante Finney & Rubenstein, P.C., 2018 WL 847756, at *3. Neither the facts nor the legal analysis in this case supports Kholod's claim for relief. We were unable to find another case that fit the citation provided by Kholod.
Issue

Fabricated: Case Law | 3. Kholod also cites “Chasen v. Littman, 2019” in which, according to Kholod, “[t]he court considered the issue of unauthorized use of funds between companies.”Doc. 1-2 at 4. In its brief, Defendant Wells Fargo Bank provides the following as the proper citation for this case: L. Offs. of Bruce J. Chasan, LLC v. Pierce Bainbridge Beck Price & Hecht, LLP, No. 2:18CV-05399-AB, 2019 WL 1957950 (E.D. Pa. May 2, 2019), aff'd, 792 F. App'x 195 (3d Cir. 2019). Doc. 5 at 21. This case does not support Kholod's claim for relief; it involved an attorney's attempt to recover a contingency fee from an out of state attorney. L. Offs. of Bruce J. Chasan, LLC, 2019 WL 1957950 at *1–2. We were unable to find another case that fit the citation provided by Kholod.
Fabricated (Case Law)

4. Kholod states that in “Brown v. Wells Fargo, 2020” “[t]he court ruled that the bank must compensate the client $8,000 for wrongful withdrawals from their account.”Doc. 1-2 at 5. Construed liberally, this may be referring to Brown v. Wells Fargo Bank, N.A., No. C19-3041LTS, 2020 U.S. Dist. LEXIS 3614 (N.D. Iowa Jan. 7, 2020), or Brown v. Wells Fargo Bank N.A., No. 01-18-01002-CV, 2020 Tex. App. LEXIS 7106 (Tex. App. Sep. 1, 2020). However, these cases are factually unrelated to Kholod's claim. The Northern District of Iowa Brown case concerns alleged violations of the Fair Credit Reporting Act (FCRA), Fair Debt Collection Practices Act (FDCPA), and Iowa Debt Collection Practices Act (IDCPA) regarding a failure to make the required payments under a note and mortgage. Brown v. Wells Fargo Bank, N.A., No. C19-3041-LTS, 2020 U.S. Dist. LEXIS 3614, at *1. The Court of Appeals of TexasBrown case concerns a motion to dismiss the Plaintiff's appeal of a final judgment dismissing the plaintiff's garnishment suit. Brown v. Wells Fargo Bank N.A., No. 01-18-01002-CV, 2020 Tex. App. LEXIS 7106, at *1. Neither of these cases include any legal analysis that is useful for Kholod's claim.*7
Issue

Misrepresented: Case Law | 5. According to Kholod, in “Smith v. First National Bank, 2017” “[t]he court ordered the bank to return $5,000 to the client after evidence showed that the withdrawal was made without the client's authorization.”Doc. 1-2 at 4. Though the year is different, the closest match to this case is Smith v. First Nat'l Bank, 837 F.2d 1575 (11th Cir. 1988). This case is not relevant to Kholod's claim; the case is an appeal of summary judgment in favor of the Defendant concerning alleged violations of the Fair Credit Reporting Act (FCRA).Smith, 837 F.2d at 1576–77.
Issue

Fabricated: Case Law | 6. Kholod states that in “Jones v. PNC Bank, 2018” “the court ordered the bank to return $3,750 for unauthorized transactions made by third parties.” Doc. 1-2 at 4. We found two cases that appear to match the named parties, but neither were published in the year Kholod provides: Jones v. PNC Bank, N.A., No. 10-CV-01077LHK, 2010 U.S. Dist. LEXIS 92866 (N.D. Cal. Aug. 20, 2010), and Jones v. PNC Bank, N.A., 630 F. Supp. 3d 959 (N.D. Ill. 2022). These cases do not appear factually related to Kholod's claims. The Northern District of California Jones case involved a dismissal of the Plaintiff's allegations of violations of the Real Estate Settlement Procedures Act (RESPA) due to failure to state a claim. Jones, No. 10-CV-01077-LHK, 2010 U.S. Dist. LEXIS 92866 at *1–2. The Northern District of Illinois Jones case granted the Defendant's motion to dismiss the Plaintiff's allegations of breach of contract regarding Guaranteed Asset Protection (GAP) as part of a retail installment contract (RIC) for a used car purchase. Jones, 630 F. Supp. 3d at 961. There is no legal analysis in either case that would be supportive of Kholod's claim for relief.
Issue

Fabricated: Case Law | 7. Per Kholod, in “Miller v. Citizens Bank, 2019” “[t]he court found the bank liable for unauthorized withdrawals amounting to $2,600 and ordered it to compensate the client for all losses.” Doc. 1-2 at 4. We found one case matching the named parties, but not the year: Miller v. Citizens Bank, N.A., No. 23-10563, 2025 U.S. Dist. LEXIS 93011 (E.D. Mich. May 15, 2025), but as this 6opinion was published after Kholod filed his complaint, we assume this is not the case to which he refers. We found no other cases fitting Kholod's description.
Fabricated (Case Law)

8. Kholod also cites “Davis v. TD Bank, 2021” in which, according to Kholod, “[t]he court ordered the bank to pay $4,200 to the client, citing the bank's failure to prevent fraudulent actions.” Doc. 1-2 at 5. The closest possible match is Davis v. TD Bank, N.A. (In re Davis), 447 B.R. 738 (Bankr. D. Md. 2011). Again, the case name matches but the year does not. Furthermore, the subject matter is unrelated to Kholod's complaint; Davis concerns an opposition to a debtors' motion and plan for repaying creditors in a bankruptcy proceeding. Davis, 447 B.R. at 740–41. There are a number of other cases where the named parties are variations of TD Bank USA, N.A. v. Davis throughout the country, none of which were published in the year Kholod cites and none of which appear to be related to Kholod's claim

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Warning

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

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Source: https://www.damiencharlotin.com/documents/701/VICTOR_KHOLOD_Plaintiff_v_NATIONSTAR_MORTGAGE_LLC_dba_MR_COOPER_-_WELLS_FAR.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/701/VICTOR_KHOLOD_Plaintiff_v_NATIONSTAR_MORTGAGE_LLC_dba_MR_COOPER_-_WELLS_FAR.pdf

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