Jabari-Jason Tyson-Phipps v. Antony Blinken

• Court: District Court, S.D. New York
• Decided: January 30, 2026
• Docket: 1:23-cv-02316
• Status: Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ---------------------------------------------------------------x : JABARI-JASON TYSON-PHIPPS : Plaintiff, ORDER -v.- : : 23 Civ. 2316 (LAK) (GWG) ANTONY BLINKEN : Defendant. ---------------------------------------------------------------x GABRIEL W. GORENSTEIN, UNITED STATES MAGISTRATE JUDGE It has come to the Court’s attention that there are erroneous citations in plaintiff’s filing entitled “Plaintiff’s Reply to Government’s Response to Motion to Transfer Venue” and dated January 29, 2026 (Docket # 88). Here are three examples: • Plaintiff cites to “Lehrer v. J&M Monitoring, Inc., No. 20-cv-6956, 2022 WL 2527091, at 2 (S.D.N.Y. July 1, 2022).” (Docket # 88 at 1). There is no such case at this Westlaw citation. • Plaintiff quotes from “Kaufman v. Salesforce.com, Inc., No. 20-cv-06879, 2021 WL 1579488, at *3 (S.D.N.Y. Apr. 22, 2021).” (Docket # 88 at 2). There is no such case at this Westlaw citation. • Plaintiff describes “Chien v. Blinken, No. 16-cv-1583 (D.D.C. Nov. 21, 2025)” as “denying reconsideration and rejecting the Government’s reliance on Egan as an absolute bar to judicial review of alleged retaliatory conduct.” (Docket # 88 at 3.) It appears that this decision is reported at 2025 WL 3251049. However, the decision makes no mention of a case called “Egan.” The Court has not yet scrutinized the remaining citations in Docket # 88 and thus cannot be sure of their accuracy. Accordingly, plaintiff is directed to examine every citation in Docket # 88. With respect to those citations, he shall file a sworn statement that includes or attaches two lists. List # 1 shall include (in alphabetical order by first name of the case) all citations he contends are accurate. List # 2 shall include (in alphabetical order by first name of the case) all citations he now recognizes are improper in any respect — whether they give an incorrect Westlaw citation, do not exist, or do not stand for the proposition they are cited for. For each citation on List # 2, he shall (1) specify the manner in which the citation was improper; (2) give the reason he included that citation in Docket # 88, including an explanation of the source of the improper citation; and (3) supply a corrected citation, if one exists. Plaintiff shall also inform the Court in this sworn statement if he is aware of citations in his filings other than Docket # 88 that are inaccurate. Plaintiff shall file the sworn statement on or before February 6, 2026. SO ORDERED Dated: January 30, 2026 New York, New York Soe ag esl United States Magistrate Judge