In re Prince Global Holdings (Sullivan & Cromwell)

What happened

Sullivan & Cromwell LLP represents the Joint Provisional Liquidators of Prince Global Holdings Limited in a Chapter 15 proceeding (a case recognizing a foreign insolvency in a U.S. court), In re Prince Global Holdings Limited, No. 26-10769 (MG). On April 9, 2026 the firm filed an emergency motion for provisional relief.

Opposing counsel at Boies Schiller Flexner, representing objecting parties, identified errors in the motion. On April 18, 2026, Andrew G. Dietderich, co-head of the firm's restructuring group, wrote to Chief Judge Martin Glenn. The letter stated that the motion "includes inaccurate citations and other errors," listed in an attached schedule, and that the inaccuracies included artificial intelligence "hallucinations." The schedule ran to 3 single-spaced pages, as David Lat reported. It listed wrong reporter citations, misquoted authorities and a misquotation of the Bankruptcy Code, along with clerical errors. The Global Legal Post reported the count as 42.

The letter said the firm's AI policies require training before access and independent verification of all AI output, and that those policies were not followed in preparing the motion. It did not name the tool used. A corrected motion with a redline was filed the same day.

What the court did

No order, sanction or show-cause proceeding had been reported in the sources reviewed as of September 11, 2026. The matter is recorded here because the disclosure was made to the court on the record, and the filing itself is the conduct in question.

According to Reuters, Dietderich wrote: "I apologize on behalf of our entire team. I also called Boies Schiller Flexner LLP on Friday to thank them for bringing this matter to our attention and to apologize directly to them as well." The letter also acknowledged the signatory's responsibility under the local bankruptcy rule that governs signed filings.

Where it stands

The Chapter 15 case continued. The firm said it had re-reviewed its other filings in the case and found no further AI-related errors. Whether the court took any further step was not confirmed as of September 11, 2026.

The obligation it engaged

The conduct engaged Clause 3 of the Expert Record Standard (independent authority) and Clause 4 (checkability before adoption). An emergency motion is drafted quickly, and speed is the condition under which unverified output is most likely to pass into a filing. The citations were checkable, and opposing counsel checked them.

The response engaged Clause 8 (disclosure) in a way the record shows plainly. The firm identified each error in a schedule, filed a redline and told the court what its policy required. That is the form of disclosure the Standard contemplates. It does not cure the failure to verify, which the firm acknowledged. It does give the court and the parties a complete record of what was wrong.

Sources

• Sullivan & Cromwell LLP (filed letter) · April 18, 2026
  Letter to Chief Judge Martin Glenn, In re Prince Global Holdings Limited, No. 26-10769
• Reuters (via The Daily Record) · April 21, 2026
  Premier Wall Street law firm apologizes for AI 'hallucinations'
• The Global Legal Post · April 22, 2026
  Sullivan & Cromwell apologises for AI hallucinations in letter to US court

What could not be confirmed

The total number of errors (reported as 42) was not counted from the schedule. No court order or docket entry responding to the letter was located; a secondary tracker states no sanction was imposed, which is recorded here only as none reported.