On The Record . . .

Official Newsletter of BERTOLINO LLP

June 2026

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Our Firm


Tony R. Bertolino, Esq.

Managing Partner


Sheri L. Middlemas

Chief Operating Officer


Senior Associates:

Troy Beaulieu, Esq.

LaJuana Acklin, Esq.

Kerry Bloodsaw, Esq.



Associates:

Amy Cadwell, Esq.

Susan Dellamea, Esq.


Legal Support:

Melissa Hooper, Manager

Valerie Rivera, Paralegal

Holly Taskov, Paralegal

Evan Looney, Legal Assistant


Client Success:

Jasen Dalus, Manager

Donald "DJ" Collora, Liaison


London de la Teja

Accounts Receivable Manager


Cimone Murphree

Public Education & Regulatory

Awareness Manager


Dena Lackey

Marketing Specialist


Colleen Raza

Firm Receptionist


Chatgpt, False Citations and Professional Responsibility


By Tony Bertolino, Esq.


 There is no doubt that artificial intelligence (AI) is rapidly reshaping legal practice, and nowhere is that shift more visible than in the researching of the law and the drafting of legal documents. As more attorneys turn to AI‑powered tools, state bars across the nation are seeing a corresponding rise in complaints involving inaccurate citations, fabricated case law, and filings that fail to meet professional standards. For Texas attorneys in particular, these missteps can trigger serious consequences before the State Bar of Texas, raising questions about competence, candor, and adherence to ethical duties.

 

The growing reliance on AI does not excuse errors. Lawyers remain fully responsible for the accuracy and integrity of every document submitted under their names. Understanding how AI‑generated content can lead to disciplinary exposure, and how to safeguard your practice against these risks, is now essential for any attorney practicing law.

 

Just scroll through social media or turn on your TV and you will see that the media is full of stories about lawyers misusing generative artificial intelligence in their work, leading to sanctions from judges nationwide. The most widely publicized missteps by lawyers have involved submission of court documents with false case citations and quotations (a/k/a AI hallucinations). However, in recent months, court sanctions for AI misuse have substantially increased, signaling a no-tolerance policy toward this conduct. Not only can attorneys face significant sanctions from judges, but they can also face disciplinary proceedings that can result in disbarment.

 

For example, in December 2025, an Illinois state court assessed a $50,000 sanction on a law firm and another $10,000 sanction on an individual attorney for including AI hallucinations in documents submitted to the court following a trial. The attorney for the opposing party, in their response to the filing, notified the court of the citations to cases that did not appear to exist. The offending law firm blamed a “serious lapse in professionalism,” stating that many of their attorneys worked on the document, including one who failed to verify the AI citation. The law firm also indicated that it was implementing measures to educate attorneys on the proper use of AI technology.

 

Nonetheless, the court ordered the involved attorneys to appear and explain themselves, including a partner with 11 years of experience, who stated that she was unaware that ChatGPT could generate fake case citations. She also reported that she knew other attorneys would review her work, but lead counsel said he did not typically review cases before filing documents. Lead counsel for the party also emphasized that only one false citation existed. However, in a motion for sanctions, the opposing counsel revealed at least 14 instances of false or misleading information in the document, as well as false citations in two previously filed documents. 

 

Notably, the offending law firm had a policy requiring attorneys to “meticulously review any output received through AI for content validity and other concerns." Several attorneys at the firm, including the attorney who drafted the document, had published articles about the risks of using AI without verification. Another court previously sanctioned the same attorney for filing a document containing at least 12 fictitious legal citations, stemming directly from her use of AI.

 

In issuing its sanctions order, the trial court described the conduct as a “serious failure” of the attorneys’ duty to present truthful and accurate information to the court. The court also noted the law firm’s failure to take adequate responsibility for the errors and its subsequent misrepresentations about the number of false citations in determining the appropriate level of sanctions. 

 

Judges generally have broad discretion to impose sanctions on attorneys who misuse AI technology. When errors are discovered, the responsible attorney, lead counsel, and law firm should act quickly to disclose them fully and candidly rather than attempt to downplay their significance. In an era where AI tools are becoming commonplace, attorneys must remember that technology does not lessen their professional responsibilities. Based on my experience, one of the most effective safeguards against AI-related misconduct is the implementation of a written, comprehensive AI policy supported by meaningful oversight and thorough verification procedures. These measures help attorneys realize the benefits of AI while minimizing the legal, ethical, and reputational risks that can result from its misuse.

Get the Advice You Need About Your License


When you face a disciplinary complaint concerning your Texas State Bar of Texas & Board of Law Examiners License, you risk significant sanctions that could adversely affect your career. Don’t try to handle such a critical situation on your own. The Bertolino LLP Texas State Bar of Texas & Board of Law Examiners License Defense Lawyers can examine your circumstances and help you determine the most effective means of protecting your license.


Call us today at (512) 476-5757 or get more information about us online on our website.

Team Bertolino Spotlight

Welcome to the Team, Holly Taskov!


We are pleased to welcome Holly Taskov to Bertolino LLP as our newest Paralegal.


Holly brings a diverse professional background and a strong commitment to client service. She earned her Bachelor's degree from Kent State University and continued her education through paralegal studies at the University of Tennessee at Martin. As she continues to grow her legal career, she is working toward becoming NALA-certified.


Before entering the legal profession, Holly built extensive experience in public accounting and spent 12 years as a licensed real estate agent. These roles helped her develop exceptional organizational skills, attention to detail, and the ability to communicate clearly and effectively, qualities that make her a valuable resource for both our attorneys and clients.


Holly's dedication to professional development, combined with her client-focused approach, makes her a wonderful addition to our growing team. We are excited to have her on board and look forward to the contributions she will make in serving the professionals who trust Bertolino LLP with their legal matters.

Hallmark Achievements

Health Insurance Carrier v. MA

 

Facts: MA retained Bertolino LLP after he was denied coverage due to current disciplinary action. MA was currently under a probated suspension with their licensing agency. The insurance carrier denied coverage due to the suspension and MA appealed the determination and asked for a hearing.  

 

Outcome: At the hearing, Bertolino LLP provided evidence and argument about the terms of the order. Evidence at trial was provided to better explain that MA’s license was not suspended but that they were simply on probation. The order was further explained to show that MA was not under any new obligations, restrictions or conditions that any other license holder did not also have to follow. Lastly, Bertolino LLP demonstrated through MA’s testimony that he did not admit to the allegations within the order, nor did the agency prove the allegations. He only agreed to the order to avoid the cost and emotional burdens of trial. After analysis of the evidence, the denial was overturned and MA was permitted to have coverage.

Texas State Board of Public Accountancy v. TE

 

Facts: TE retained Bertolino LLP to help them in applying for licensure. TE was already licensed out of state but got a job in Texas that required him to get licensed with the TSBPA. TE had several prior criminal incidents related to alcohol and they wanted to avoid any issues with disclosure

 

Outcome: Bertolino LLP drafted a supplemental disclosure of all TE’s arrests, deferred adjudications and convictions including their current deferred and pending community supervision. Bertolino LLP provided argument and evidence within the disclosure advising that many of these instances were youthful indiscretions and that TE had learned from his mistakes. We also provided evidence of past and current treatment and why the most recent treatment was substantially different than prior treatments which is what caused the change in TE sobriety. After analysis of the evidence TSBPA issued TE a license without public disciplinary action or restriction and allowed them to complete a private monitoring program.

Texas Medical Board v. TT

 

Facts: TT retained Bertolino LLP to help them in applying for licensure. TT originally needed help in disclosing a prior DUI, but after looking into the issues more, Bertolino LLP also determined that further disclosures were necessary.

 

Outcome: Bertolino LLP drafted a supplemental disclosure of TE’s conviction and his termination from two programs and a termination of a prior license with another state agency. Bertolino LLP provided argument and evidence within the disclosure advising that the DUI was an isolated event and akin to a youthful indiscretion that TMB did not have authority over. Next, they explained that the terminations were both due to the same issue involving the DUI and the licensure was terminated as TT was no longer enrolled in either program. After analysis of the application, TMB issued TT licensure without restriction.

BHEC vs. DD


Facts: Our client, DD, hired us to assist in protecting her license from disciplinary action after failing to file a mandatory disclosure in accordance with state regulations.  


Outcome:  The Firm analyzed the facts in the case. It was determined that favorable mitigating circumstances may lead to a favorable outcome.    The Firm crafted a robust response arguing favorable mitigating factors, and BHEC took no action against DD’s license.    Since the Firm successfully defended DD’s livelihood, career, and reputation, DD can continue to pursue her professional passions.   

Don't Delay Hiring Proper Legal Counsel: Why Options Shrink and Problems Grow When You Don't Hire the Right Lawyer Promptly to Protect Your License 

by Troy Beaulieu, Esq.

A recent group of cases I handled before a state-wide licensing agency where people’s livelihoods are at stake reminded me of just how important it is to retain the right sort of legal counsel early to protect your license, whether it’s in front of your licensing agency, or in the courtroom.  


All three had similar situations, but one hired Bertolino LLP at the beginning and avoided loss of the license, one hired an inexperienced lawyer and waited until the middle of the legal process to hire Bertolino LLP after disaster struck, and one represented themselves until the tail end of the agency adjudication process, significantly limiting their legal options.  Each one had significantly different prospects, options and outcomes because early involvement of the right attorney makes all the difference in the world.  


Telling yourself you can handle it on your own or that your best friend’s family law attorney who did a great job handling his divorce will suffice is not going to protect your license, it’s only going to cause more problems.  This article will discuss what you can do to protect your license and avoid further legal risks by hiring the right attorney up front. 


It’s the Unknowns That Harm You 


When you decide not to hire legal counsel immediately, or hire a lawyer who does not regularly practice license defense law, you expose yourself to harm from the unknown.  In today’s world of AI, internet research, and technology tools it’s easy to think you can handle the case at the beginning and get a lawyer later if you need one.  Or certainly any lawyer will do because these tech tools should even the playing field, right?  Not so. 


Sure, anyone can download from the internet or consult with AI about what you need to do to respond to a lawsuit or defend yourself before a licensing agency.  And maybe you can even find instructions on the types of arguments, legal theories and evidence objections one might raise.  But does you or your best friend’s excellent DWI criminal lawyer have a clue about the intricacies of license defense law based on years of representing thousands of licensed professionals?  Not by a longshot.  What you’re left with at best is a half-baked, AI driven defense that is anemic, missing key components and lacks the nuanced and knowledge-driven skill that comes with years of practicing in this unique arena.  Your license, your professional reputation, your livelihood demand much more. 


You wouldn’t settle for calling a plumber to solve an electrical problem just because plumbers and electricians both work on houses and you wouldn’t ask your dermatologist to help with your brain surgery just because the physician handled your skin cancer scare and mole removal surgery well.  Likewise, you wouldn’t be comfortable getting instructions from ChatGPT on the steps for performing a root canal and set up in your garage with your household Dremel tool to give yourself a root canal.  Your license deserves more.  Will it cost more?  Yes, but not in the long run when you compare it to the costs of choosing poorly.


You must find a lawyer who knows this niche area of the law and deals with professional licensing issues in front of agencies and in courtrooms to protect your license, livelihood and professional reputation.  The stakes are just too high to do anything less. 

 

The Costs Are Too High When Your License is On the Line


What happens when you don’t obtain qualified legal counsel from the start?  Well, now your skilled lawyer now must fix the deficient work (that created more damage to your case) plus the original problems, and you are behind the curve because of delays in hiring the right attorney and there is now more work to address.  And you now have fewer legal options because those unknowns that we not originally identified early and addressed have now harmed your defense because of time, legal, evidence or procedural requirements, limitations and restrictions you or an unqualified lawyer missed. 

Now, the damage is done, the license lost, the civil judgment imposed, or the disciplinary action imposed.  At best you may be stuck with a malpractice claim against an unqualified lawyer who should not have promised to help with your case.  Or worse, you handled the matter yourself and have no recourse.  But you cannot recover from the self-inflicted wounds caused by delayed involvement of the right lawyer.


They Takeaways You Need to Protect Your License 

 

In summary, what you need to remember is: 

 

  • Don’t wait.  Time is critical and options shrink quickly so hire a lawyer immediately when you face a legal issue, complaint or problem. 

 

  • Hire the right lawyer.  License defense is a niche area that requires unique experience, knowledge and training, so make sure you hire a lawyer known for their administrative law, license defense, and malpractice litigation expertise. 

 

  • Don’t Handle your own legal matter.  Treat your license with the care necessary to protect your livelihood and professional reputation by obtaining a professional license defense counsel. 


Contact Bertolino LLP immediately when you face a legal issue impacting your license.  We bring decades of skilled experience to bear to protect your professional or occupational license when legal challenges surface. 

Engage with your regulatory agency like never before! Navigating the laws that govern your license and profession can be challenging. That’s why we’ve created Know Your Regulator, an educational resource designed to help license holders take charge of their careers. Stay informed with important agency updates, gain valuable insights, and discover opportunities to enhance your professional license by following and subscribing to our podcast and Youtube channel.


In this episode of Know Your Regulator, host Cimone Murphree sits down with LaJuana “LJ” Acklin, a Senior Associate Attorney at Bertolino Law Firm to break down how Texas school districts handle contract termination, what ‘resign in lieu of termination’ really means, and when statutory immunity may protect educators who use reasonable force in the classroom. If you’re a Texas teacher, especially in special education, this conversation can help you understand some of your options before you make a decision.


Episode 79: Texas Special Education Teachers and Contract Termination: What to Know Before You Resign



Click here or the video to view.

Empower your license and career, and stay ahead in your industry. Take advantage of our free educational resources by visiting Know Your Regulator today!

Learn how you can proactively protect your license by engaging with your regulator and staying informed about regulatory developments in your industry.


With Bertolino LLP's insights regulatory insight, suggestions, and information, we can help you minimize your compliance risk profile and stay ahead of your competition by engaging with your regulator.




Recognition Days:

June 2026 Calendar


Team Bertolino is grateful for the expertise and dedication of these professionals. Thank you for your outstanding contributions to your respective industries.


June Professional Days


06.11: CNA Day

                                

06.14: Army Birthday

                                

06.24: Reserves Day

                                

06.26:  National Beautician Day




Side Bar ...

A Day on the Lake with the Bertolino LLP Team


At Bertolino LLP, our team works hard every day to fulfill our mission of providing the strongest possible license defense for our clients. While our work keeps us focused on serving those who trust us with their cases, opportunities to step away from the office and connect as a team are invaluable.


Recently, our team enjoyed a day on the lake together, and it was a wonderful opportunity to strengthen relationships, welcome newer team members, and reconnect with colleagues across the firm. Many team members were also able to bring their significant others, making the event even more meaningful.


Highlights from the day included:


• Building stronger connections with teammates outside of the workplace

• Getting to know new employees and their families

• Sharing stories, experiences, and interests beyond our daily work

• Creating stronger relationships that help us collaborate more effectively

• Enjoying a fun and relaxing day together in a beautiful setting


Events like these remind us that great teams are built not only through hard work, but also through meaningful connections and shared experiences.


A special thank you to Tony R. Bertolino for making this memorable outing possible. We are grateful for the opportunity to spend time together and continue building the strong culture that makes Bertolino LLP such a special place to work.

Jasen Dalus, Client Success Manager and DJ Collora, Client Success Liaison the 90s theme team winners!

Troy Beaulieu, Esq. Director of Legal Services and the boombox! Our team did a great job keeping the 90s theme!

One of our newest team members, Colleen Raza, our Law Firm Receptionist, along with her fiancé, Seth Rainey.

BERTOLINO LLP | (512) 476-5757 | 823 Congress Avenue, Suite 300, Austin, TX 78701 www.bertolinolaw.com | info@bertolinolaw.com