Puerto Rico Soccer League NFP, Corp., et al. v. Federación Puertorriqueña de Futbol, et al.

Fabricated First Circuit citation to Estrada; correct case is a D.P.R. decision.

Fabricated First Circuit citation to the NECC MDL; correct authority is a D. Mass. 2013 order.

Fabricated First Circuit citation to Healey v. Gonzalez; Plaintiffs later claimed they meant Healy v. Spencer.

Fabricated First Circuit citation to Sullivan v. Taglianetti; court could not locate the case.

Fabricated First Circuit citation by naming the wrong party in Gill as “Gulfstream Aerospace Corp.”

Fabricated First Circuit citation to United States v. Gannett Co.; court identified only D.D.C. antitrust cases with different content.

Attributed to Kevlik that MR 3.7(a)(3) substantial hardship exemption is interpreted broadly to protect against “unnecessary disruption”; court found no mention of MR 3.7 in Kevlik.

Quoted Kevlik for “no clear and convincing MR 1.7 conflict”; court found no such language and noted MR 1.7 was not controlling there.

Quoted Culebra Enters. as calling disqualification an “extreme sanction” used only after “careful consideration”; court found no such quotes and that the case was about fee sanctions, not disqualification.

Quoted Estrada that disqualification is “not lightly granted”; court found no such quote (only similar general statements).

Quoted Fiandaca as requiring “specific instances” of conflict and rejecting “hypothetical scenarios”; court found no such quotes or support.

Attributed to Fiandaca that the First Circuit applies Model Rule 3.7 “narrowly” to avoid “tactical misuse”; court found no mention of MR 3.7 and no such quotes.

Quoted Fiandaca to label Defendants’ Rule 1.7 claim “wholly speculative” for lack of evidence; court found no such quote in Fiandaca.

Used Fiandaca to assert early disqualification is “unduly punitive” and that delay is preferred; court said the opinion held nearly the opposite and contained no such quote.

Quoted Kevlik as imposing a “high standard” for disqualification; court found no such phrasing.

Quoted Kevlik that choice of counsel is a “valued right” balanced with “scrupulous care”; court found no such quotes and observed the case emphasizes preventing unethical conduct over unfettered choice in civil cases.

Quoted Kevlik that disqualification is unwarranted without “demonstrable detriment”; court found no such language and explained the substantially related test does not require that showing.

Quoted Culebra Enters. that necessity is assessed “in light of available alternatives”; court found no such text.

Quoted Culebra Enters. that ethical rules prioritize “practical outcomes” over rigid bans; court found the opinion merely limited MR 3.7 to trial advocacy and did not make such a broad pronouncement.

Said Estrada upheld representation absent “actual showing” of divided loyalty; court found no such quote and noted Estrada applied different ethical rules.

Quoted Polyagro Plastics that MR-based disqualification requires a “clear and convincing” violation threatening judicial integrity; court found no such language.

Placed in quotes Oppenheimer language on Rule 26(b)(1) “casts a wide net” and “bears on … any issue …”; court found the quoted phrasing not in the opinion and emphasized current proportionality limits.

Quoted NECC MDL that Rule 26 has a “broad sweep”; court found no such quote (only general statements of liberal discovery).

Quoted NECC MDL that defendants’ conduct is “inextricably intertwined” with the antitrust conspiracy; court found no such quote (only general discovery breadth language).

Quoted Healy v. Spencer to claim relevance is construed “generously” and discovery limited only if it has “no possible bearing”; court found neither the quotes nor support in that habeas opinion.

Quoted In re Subpoena to Witzel that a Rule 26(c) protective order requires a “particular and specific demonstration of fact” beyond conclusory statements; court found no such quote or discussion of that standard.

Quoted DM Research that antitrust claims often require “exploration of the conspirators’ minds and actions”; court found no such statement.

Quoted Public Citizen v. Liggett that a protective order requires “specific facts, not conclusory statements”; court found no such quote.

Quoted Public Citizen v. Liggett that a “particularized showing” is required; court found no such language.

Quoted Anderson v. Cryovac that discovery should be “as broad as possible”; court found no such quote and noted the current relevance and proportionality limits of Rule 26(b)(1).

Quoted Poliquin that a protective order requires a “specific demonstration of need”; court found no such quote and explained Poliquin concerned post-trial protection standards.

Claimed Culebra Enters. held informed consent cures MR 1.7 conflicts and ethical rules are “flexible” absent systemic harm; court found no such support and noted the case did not address MR 1.7.

Asserted Culebra Enters. deferred disqualification until “actual necessity” of lawyer-witness; court found no such language and that the case allowed pretrial work by a potential witness, not deferral of disqualification.

Claimed Culebra Enters. defers disqualification until necessity to testify is “clearly established”; court found no such support.

Cited Estrada for rule that disqualification requires “tangible harm,” not “theoretical risks”; court said this contradicts Estrada’s recognition that potential threats can suffice under the substantially related test.

Cited Fiandaca to argue disqualification would unduly prejudice Plaintiffs; court noted Fiandaca discussed prejudice to the movant seeking disqualification, not to the party opposing it.

Asserted Kevlik requires a “specific showing” of conflicting interests under MR 1.7, not mere affiliation; court said Kevlik’s substantially related test assumes confidences and requires no such specific showing.

Used Culebra Enters. to claim MR 3.7 disqualification requires “actual necessity,” not “potential relevance”; court found no support and noted the case did not address disqualification.

Stated Culebra Enters. holds hardship weighs “heavily” against disqualification under MR 3.7; court found no such specific weighting in the opinion.

Argued, citing Culebra Enters., that applying MR 3.7 now is premature; court found no such determination in the opinion.

Asserted Estrada shows delays in filing disqualification motions signal bad faith and late motions are “viewed skeptically”; court found no such support.

Quoted In re Grand Jury Proceedings to require “actual prejudice” not “mere possibility” for disqualification; court found no such quote and noted a serious potential conflict may suffice.

Claimed First Circuit does not let parties “second-guess” co-parties’ joint counsel choice unless clear abuse; court found the Government was permitted to challenge joint counsel in that case.

Asserted the First Circuit dismisses privilege gamesmanship concerns absent “actual prejudice”; court noted the case allows disqualification for a serious potential conflict.

Quoted that privilege issues are resolved “case-by-case,” not preemptively; court noted only Wheat’s general case-specific evaluation language, not Plaintiffs’ formulation.

Asserted MR 8.4 requires “intentional deceit”; court found no mention of MR 8.4 in the opinion.

Quoted Herrera-Venegas to label § 1654 a “fundamental” right to self-representation and that litigants “may conduct their own cases”; court found no such quotes and a different holding.

Relied on Witzel to argue defendants provided only conclusory assertions about 68 witnesses being unmanageable; court said Witzel concerned a motion to compel and did not support that use.

Cited DM Research to say antitrust cases often require extensive evidence; court noted the case affirmed dismissal before discovery, so the proposition was unsupported.

Cited Gill to warn against “arbitrary numerical limits” on witnesses; court found no supporting language in the opinion, which concerned informant’s privilege.

Mischaracterized Whittingham as a post-discovery ruling; court noted discovery was ongoing.

Used Gill to argue Swiss Penal Code language in a protective order would confuse and delay discovery contrary to First Circuit efficiency goals; court found no support in the opinion.

Cited In re Grand Jury Subpoena (2001) to say ethical rules focus on actual conflicts, not hypothetical risks; court found the case dealt with privilege and did not support that proposition.

Misstated circuit and substance for In re Grand Jury Subpoena (Fourth Circuit), invoking the Hague Evidence Convention which the case does not mention.

Quoted Aerospatiale that Hague procedures are “permissive” at pages 539–40; court noted that wording does not appear there (similar language exists on other pages).