John Gilbane

** John Gilbane stands, he adjusts his fedora once again before speaking out ** "Your Honor, You are giving me and my client just dates with no time or what vehicle it was? This unreasonable. Can you give us more information to work with? So my team and I can figure it out, Your Honor. We are ready for cooperation." (( @Userone @almightybounter @nfr.ai ))

** John Gilbane rises, adjusting his tie, and steps confidently toward the bench ** "Your Honor, while we respect the court's ruling on the motion to recuse Plaintiff’s counsel, we must draw attention to a glaring issue in the Plaintiff's Motion to Compel Production of Evidence." ** John Gilbane pauses, flipping through the pages of the Plaintiff’s motion before raising his voice just slightly ** "In the Plaintiff’s Motion to Compel, the key element for the requested evidence – the date of the incident – has been entirely omitted, leaving behind the phrase “[insert dates]” as a placeholder. This omission demonstrates precisely why reliance on AI tools in drafting legal documents can lead to significant procedural errors. A lawsuit must be carefully prepared by an attorney who thoroughly reviews the case and pays attention to critical details. The absence of dates makes it impossible for the defense to properly comply with the request, as we have no idea which specific events or incidents the Plaintiff is referring to." ** John Gilbane gestures toward the opposing counsel’s table ** "The role of counsel is not merely to draft documents but to ensure that the filings are comprehensive, accurate, and reflect a deep understanding of the facts. By leaving placeholders like “[insert dates]” in a critical legal motion, Plaintiff’s counsel has demonstrated a lack of proper review and attention, which could prejudice the case against the Los Santos Police Department. Your Honor, this error underscores the dangers of delegating key aspects of legal document preparation to AI without thorough human oversight. It violates Rule 11(b) of the Federal Rules of Civil Procedure, which requires an attorney to ensure that legal filings are factually accurate and well-grounded in law. The Plaintiff’s motion, in its current state, does not meet this standard. Given this critical oversight, the defense requests that the Plaintiff’s Motion to Compel be dismissed or, at the very least, amended to include the necessary details before the defense is required to respond." ** John Gilbane gives a respectful nod, adjusting his fedora one last time before returning to his seat ** (( @nfr.ai @almightybounter ))

** John Gilbane rises, adjusting his fedora as he steps forward, addressing the court with deliberate confidence ** "Your Honor, the defense respectfully submits the following rebuttal to the Plaintiff's response regarding the use of artificial intelligence (AI) tools in the preparation of legal documents. While Plaintiff's counsel claims that AI was merely used as a drafting aid to "ensure clarity and consistency," the defense asserts that the reliance on AI fundamentally breaches the essential standards of professional responsibility and the integrity of court filings. This case presents a critical issue regarding the permissible use of technology in the judicial process, and I contend that the Plaintiff’s reliance on AI in this case is not compliant with court rules." ** John Gilbane paces slightly, pausing to glance at the Plaintiff’s counsel before addressing the court ** I. Legal Standards Governing the Preparation of Court Filings "According to the Federal Rules of Civil Procedure and standard legal practice, all filings in court must be made by attorneys licensed to practice law in the respective jurisdiction. This requirement is not merely procedural but is rooted in ensuring accountability, human judgment, and professional responsibility in the representation of clients. The relevant legal principles require that filings be personally prepared, reviewed, and submitted by an attorney who is fully responsible for the content. The use of AI, as admitted by Plaintiff’s counsel, means that certain portions of the document were not entirely authored by human judgment but instead relied on machine-generated language. This undermines the role of an attorney as the primary source of legal reasoning and accountability. In San Antonio v. Rodriguez, 411 U.S. 1 (1973), the Supreme Court highlighted the importance of legal counsel’s deliberate exercise of judgment when preparing legal arguments, stressing that legal professionals are held to a standard of rigorous preparation." ** John Gilbane firmly adjusts his tie, his voice calm but resolute ** II. Complaint Must Be Dismissed for Failure to Comply with Proper Filing Standards "Your Honor, court rules and federal case law make clear that improper or insufficient filings, especially those that violate procedural rules, should not be entertained by the court. A complaint must be dismissed if it is not properly filed according to court regulations and the principles of civil law. Under Federal Rule of Civil Procedure 11(a), every submission must be signed by an attorney of record. This signature signifies that the attorney has conducted a reasonable inquiry into the law and facts before submitting the filing." ** John Gilbane raises his hand slightly, gesturing towards the documents laid out on the Plaintiff’s table ** "The Plaintiff’s reliance on AI for drafting legal documents suggests that the attorney did not fully meet this obligation. In fact, the argument presented fails to recognize that any use of artificial enhancement that replaces or supplements the professional judgment of counsel is not allowed in this court system. The rules governing civil procedure do not permit the outsourcing of legal judgment to non-human tools, regardless of whether AI was used to detect errors or streamline processes. The legal profession is built on human interpretation, analysis, and discretion, none of which can be meaningfully replaced by AI systems, as acknowledged in the Model Rules of Professional Conduct Rule 1.1: Competence. The opposing counsel’s admission that AI was involved in the process suggests that there may have been a failure to properly file, which directly affects the integrity of the documents submitted. Thus, the complaint and any associated motions should be dismissed in their entirety for failure to comply with the standards of preparation required in this jurisdiction." III. Conclusion "Given the lack of compliance with court procedures and the improper use of AI assistance in preparing and submitting these filings, the defense respectfully requests that the court dismiss the complaint and all associated filings in this case. The court’s rules are clear: the personal responsibility and professional judgment of legal counsel cannot be delegated to AI or other artificial tools." ** John Gilbane tips his fedora slightly, giving a confident nod to the judge ** "We ask for a swift dismissal, Your Honor, as the Plaintiff's filings do not meet the standards required for legitimate court submissions." /S/ John Gilbane, Esq. Attorney for Defendant, Los Santos Police Department (( @nfr.ai @almightybounter @Userone ))

** John Gilbane stands, adjusts his fedora, and addresses the court ** "Your Honor, the defense would like to acknowledge receipt of this Motion to Compel by Plaintiff Michelle Jefferson. We intend to address it thoroughly. However, there are substantial concerns regarding the conduct of opposing counsel, particularly their reliance on AI-generated assistance, such as ChatGPT, to construct legal arguments and documents." ** John Gilbane steps forward confidently, his voice calm but firm ** "We would like to file a motion to recuse opposing counsel, as it has come to our attention that the integrity of these legal filings is in question due to the reliance on automated assistance for generating substantial portions of this motion. It is vital that human attorneys remain the sole preparers and signatories of legal filings in this jurisdiction." ** John pauses, glancing toward opposing counsel before turning back to the judge ** "We respectfully request that this issue be addressed before any further legal proceedings."

** John raises an eyebrow at Xavier from across the courtroom, muttering quietly to himself. With a quick adjustment of his tie, he rises to readdress the court ** SUPERIOR COURT OF SAN ANDREAS COUNTY OF LOS SANTOS Case No: 24-CV-1034 Michelle Jefferson v. Los Santos Police Department Defense Response to Plaintiff’s Motion Presented by: John Gilbane, Esq. Date: 17th of September, 2024 Your Honor, On behalf of the Los Santos Police Department, I respectfully submit this response to the Plaintiff’s motion, which mischaracterizes the facts and law in this case. The Plaintiff's claims are not supported by applicable law or the evidence presented. We will address each of the Plaintiff's claims in turn, referring to established case law and procedural principles relevant to this civil matter. 1. False Arrest and Breach of Duty The Plaintiff asserts that her numerous arrests by LSPD officers were improper and based on incomplete information, alleging a breach of duty and false arrest. However, the defense contends that probable cause existed for each arrest, based on the information available to the officers at the time, in compliance with established standards in Brinegar v. United States, 338 U.S. 160 (1949). The Plaintiff’s assertion that "irregularities" in the arrest process amounted to a violation of rights is speculative and lacks merit. Additionally, false arrest claims in civil court require the Plaintiff to demonstrate an absence of probable cause for her detention. As seen in Beck v. Ohio, 379 U.S. 89 (1964), probable cause justifies arrest, even when later investigation reveals that no crime was committed. The Plaintiff has failed to establish that the LSPD acted outside its lawful authority or in bad faith, and therefore, her claim for breach of duty must be dismissed. 2. Deprivation of Rights Under the Pretext of Law The Plaintiff alleges that her First Amendment rights were violated when she was arrested for "Riot" and "Inciting a Riot" during peaceful protests. The defense disputes this characterization, as the Plaintiff's participation in these events escalated into unlawful assemblies, presenting a threat to public safety. Law enforcement’s actions were justified under the "clear and present danger" standard established in Brandenburg v. Ohio, 395 U.S. 444 (1969). The court has long upheld that the right to free speech and assembly does not extend to actions that incite violence or disturb public order. Furthermore, the Plaintiff has failed to demonstrate how the charges brought against her constitute a violation of her civil rights under 42 U.S.C. § 1983. The LSPD’s response to unlawful behavior was appropriate and proportional, as law enforcement is tasked with maintaining public safety. There is no basis for the claim that the arrests were made in an effort to suppress free speech, and thus, the Plaintiff's argument lacks factual and legal foundation. ** John Gilbane leans slightly on the table, one hand gesturing smoothly as he speaks ** 3. Emotional Distress Claims The Plaintiff seeks compensation for emotional distress resulting from what she perceives as unjustified arrests. However, to succeed on a claim for intentional infliction of emotional distress, the Plaintiff must show that the Defendant’s conduct was "extreme and outrageous," as established in Hustler Magazine, Inc. v. Falwell, 485 U.S. 46 (1988). The conduct of the LSPD officers was neither extreme nor outrageous; they acted in accordance with legal standards, and all actions were justified by probable cause. Additionally, claims for negligent infliction of emotional distress require the Plaintiff to demonstrate actual injury, which she has failed to do. The medical evidence provided does not substantiate that any emotional distress was directly caused by the actions of the LSPD. Therefore, the Plaintiff’s claim for damages under this theory should be denied. 4. False Citations The Plaintiff claims that citations for "Unlawful Assembly" were improperly issued. However, the defense points to the clear legal justification for these citations under Shuttlesworth v. City of Birmingham, 394 U.S. 147 (1969), which upheld the regulation of public assembly when it threatens public safety. The Plaintiff’s participation in these assemblies violated local laws designed to protect the public from escalating conflict, and the citations issued were fully supported by the evidence. The Plaintiff has not demonstrated that the LSPD officers acted outside the scope of their authority or that the citations were issued in bad faith. As such, this claim is baseless and should be dismissed. ** John Gilbane tips his fedora back just slightly, as if considering a deeper point, before continuing ** Conclusion: In conclusion, the Plaintiff's motion lacks both legal and factual merit. The Los Santos Police Department acted lawfully in every instance, and there is no evidence of constitutional violations or tortious misconduct. The defense requests that the court deny the Plaintiff's motion in its entirety, as the Plaintiff has failed to meet the burden of proof necessary to sustain her claims. We respectfully request that this Court dismiss the Plaintiff’s claims and enter judgment in favor of the Los Santos Police Department. Sincerely, /S/ John Gilbane, Esq. Attorney for Defendant, Los Santos Police Department (( @nfr.ai @almightybounter @Userone ))

SUPERIOR COURT OF SAN ANDREAS COUNTY OF LOS SANTOS CIVIL DIVISION Case Name: Michelle Jefferson v. Los Santos Police Department Defense Argument for the Los Santos Police Department Presented by John Gilbane, Esq. Your Honor, On behalf of the Los Santos Police Department (LSPD), I respectfully submit that the allegations made by the Plaintiff, Michelle Jefferson, are unfounded and should be dismissed in their entirety. The Plaintiff claims false imprisonment, deprivation of rights, breach of duty, and emotional distress, but these accusations lack the necessary legal basis and supporting evidence. 1. False Imprisonment & Breach of Duty The Plaintiff asserts that she was falsely imprisoned and detained unlawfully by the LSPD. However, records will show that the Plaintiff was arrested and detained in accordance with proper legal procedures and protocols. The LSPD acted under reasonable suspicion and probable cause in each instance. It is critical to note that the arrests were supported by credible testimonies and evidence. The notion that these arrests were made on “inaccurate testimonies” is entirely speculative and unsupported by the facts. Furthermore, the Plaintiff has failed to provide any direct evidence that the actions of the LSPD officers were unreasonable under the circumstances or that they acted in any manner that deviated from the standard operating procedures. 2. Deprivation of Rights Under Color of Law The Plaintiff claims her First Amendment rights were violated by being falsely arrested nine times for "Riot" and "Inciting a Riot." However, these charges were brought forward due to the Plaintiff’s active participation in civil disturbances that posed significant public safety concerns. The LSPD has an obligation to maintain public order and protect citizens from harm. Any assembly that escalated into unlawful activity or posed a threat to peace and safety warranted police intervention. These actions were not in violation of constitutional rights but were measures to ensure public safety. The Plaintiff has not shown any deprivation of rights that would satisfy the necessary elements of this claim, as the police actions were justified by substantial public safety interests and were in full compliance with the law. 3. Emotional Distress Claims The Plaintiff has claimed emotional distress totaling $1,000,000 from alleged false arrests and citations. However, emotional distress claims in tort law require a showing of severe distress caused by extreme and outrageous conduct, which is conspicuously absent in this case. The arrests and citations were based on probable cause and legal justifications, and at no point did the LSPD officers act with malice or reckless disregard for the Plaintiff’s rights. The emotional distress claims are therefore baseless, as there was no negligent or intentional conduct that would give rise to such damages. 4. False Citations The Plaintiff seeks $16,000 in damages for allegedly false citations related to "Unlawful Assembly." These citations were issued in direct response to violations of local assembly laws and were processed in accordance with established legal frameworks. The Plaintiff's repeated participation in unlawful assemblies warranted the issuance of these citations. As such, there was no wrongful act on the part of the LSPD, and these citations were legally justified. Conclusion: The Plaintiff's allegations of false imprisonment, breach of duty, and emotional distress are not supported by facts or evidence. The LSPD acted in accordance with its duty to protect public safety, and its officers conducted themselves professionally and within the scope of the law at all times. The charges and citations brought against the Plaintiff were based on clear legal justifications, and there is no evidence to support her claims of misconduct. We respectfully request that this Court dismiss the Plaintiff’s claims in their entirety and find in favor of the Los Santos Police Department. /S/ John Gilbane, Esq. Attorney for the Defendant, Los Santos Police Department