Article alerts attorneys to AI hallucinations embedded in document metadata — a threat to discovery integrity and evidentiary reliability
NEW YORK, November 4, 2025 — Law & Forensics LLC congratulates Expert Witness Dr. Morgan B. Ward Doran on the publication of "Attys Beware: Generative AI Can Also Hallucinate Metadata," co-authored with Daniel Garrie and Jennifer Deutsch and published in Law360 on November 4, 2025. The article warns legal practitioners that generative AI systems fabricate information not only in the visible text of documents but also in the hidden metadata fields that courts and attorneys routinely treat as authoritative. (Source)
Document metadata — the embedded data fields recording author names, creation dates, modification histories, and organizational origins — has traditionally been generated automatically by software systems rather than by human actors, making it a presumptively reliable source of documentary provenance in litigation. The article argues that generative AI has broken that assumption: because large language models "guess when uncertain, producing plausible yet incorrect statements," AI-generated documents can be populated with false authorship attributions, invented timestamps, and fabricated organizational identifiers that are invisible to standard document review but capable of undermining the integrity of discovery, authentication, and evidence. (Source)
The co-authors identify the problem as particularly acute for litigation because the concealed nature of metadata means that AI-generated hallucinations may pass undetected through document review workflows and into evidentiary record. For legal teams relying on document metadata to establish provenance, chain of custody, or the timeline of events, undetected AI metadata fabrications could materially compromise proceedings.
Dr. Ward Doran brings firsthand government enforcement experience to this analysis. During his tenure at the SEC, he served as the founding subject-matter expert in the Cyber Unit, led the agency's Dark Web Working Group, co-led the Digital Asset Tracing Working Group, and ultimately served as Senior Special Counsel and Strategy & Innovation Advisor to the Director of FinHub, where he directed the SEC's integration of generative AI into front-line enforcement workflows. He also single-handedly designed, coded, and ran the SEC's internal FinTech laboratory, through which he stood up the first Ethereum node operated by a U.S. government entity and brought the first generative AI-enabled APIs to the SEC. He received the SEC Chair's Award for Investor Protection and the SEC Paul R. Carey Agency Award in 2024, among multiple other agency honors. (Source)
" The legal profession's guard is down on metadata because it has always been machine-generated and therefore assumed to be neutral. Generative AI has changed that calculus in ways that most practitioners have not yet appreciated — and the evidentiary consequences can be severe," said Dr. Morgan B. Ward Doran.
" Morgan's ability to see both sides of this problem — as someone who has actually coded AI tools inside a federal regulatory agency and as an expert witness in complex litigation — makes this article essential reading for any litigator whose practice touches AI-generated documents," said Daniel Garrie, Co-Founder of Law & Forensics.
Dr. Ward Doran joined Law & Forensics following his 2025 departure from the SEC. At Law & Forensics, he provides expert witness and consulting services in regulatory enforcement strategy, crypto investigations, securities fraud litigation, smart contract audits, and matters involving artificial intelligence and digital evidence.
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