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Audit the citations in a brief before filing
Builds a row-by-row ledger of every citation in the brief (form, pin cites, id. discipline, history risk) and separates the cites you can file from the ones somebody has to pull first.
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*(Bluebook 21st ed.; N.D. Cal.; draft source: AI-assisted; every case cite below is treated as unverified.)*
Read this first. This draft was AI-assisted. I have not confirmed that any cited case exists, and neither has anyone else. Nothing in this ledger should be treated as verification.
Ledger
| Location | Citation as written | First/short | Form OK? | Pin cite? | Status |
|---|---|---|---|---|---|
| p. 6, ¶ 1 | Yartzoff v. Thomas, 809 F.2d 1371, 1376 (9th Cir. 1987) | First | Yes | Yes | OK on form; pull |
| p. 7, ¶ 2 | Bell, 341 F.3d at 866 | Short | Yes | Yes | OK on form; first reference is at p. 5 n.4 |
| p. 9, ¶ 3 | Smith v. Jones, 234 F.3d 567 (9th Cir. 2002) | First | Missing pin | No | SUSPECT |
| p. 9, ¶ 3 | Id. at 569 | Short | Chain broken | Yes | Depends on the Smith cite; also a string cite intervenes at n.11 |
| p. 11, ¶ 1 | Coszalter v. City of Salem, 320 F.3d 968, 977 (9th Cir. 2003) | First | Yes | Yes | Shepardize |
| p. 14, ¶ 2 | "unequivocal repudiation" (quoted, no citation) | n/a | n/a | None | Quotation with no source |
| p. 18, n.22 | 2 Witkin, Cal. Proc. § 412 | First | Edition and year omitted | Partial | Form fix; also cited for a Ninth Circuit holding it cannot carry |
Suspect: pull before filing.
- *Smith v. Jones*, 234 F.3d 567: cited for the proposition that a four-day gap between protected activity and termination establishes causation. Generic party names, no pin cite, and the proposition is one the brief could support with *Coszalter* instead. If this case does not exist, it is the one that ends the motion and starts a different conversation with the court.
- *Id. at 569* at p. 9: inherits Smith's status, and the id. is broken regardless by the string cite in note 11. Rewrite as a full short form once Smith is resolved.
Pin cite gaps.
- p. 14, ¶ 2: "unequivocal repudiation" appears in quotation marks with no citation at all.
- p. 18, ¶ 3: the damages calculation cites *Yartzoff* generally; add the pin or drop the cite.
Shepardize these. *Coszalter* (2003, First Amendment retaliation; check against the *Lane v. Franks* line). *Yartzoff* (1987, and load-bearing for your causation argument). Anything remaining from note 11's string cite after you cut it to three.
Local rule and house style. Witkin needs edition and year. Note 11 runs five sources; house rule caps string cites at three; cut the two district court cases. No parallel citations required in N.D. Cal., so the Cal.Rptr. cites in notes 14 and 19 can come out.
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Assumptions I made. That Bluebook 21st ed. governs and your court has no supplemental citation rule [verify - local rules sometimes override]. That *Bell* was first cited in full at p. 5 n.4 [safe - it appears there]. That footnote 11's string cite is the only intervening authority before the id. at p. 9 [verify - I may have missed a cite inside a block quote].
Where this is weakest. I cannot confirm that any of these cases exist, that any quotation is accurate, or that any holding is current, and that limitation matters most for *Smith v. Jones*, which is doing the causation work in Section II, and for the unattributed "unequivocal repudiation" quote on p. 14, which reads as though it came from a case nobody has identified.
What only you can decide. What to do about *Smith*. Pulling it takes ten minutes in Westlaw and keeps Section II intact if the case is real; replacing it with *Coszalter* (which you already cite and have presumably read) is safe and immediate but slightly weaker on the facts, since Coszalter's gap was longer. Filing it unverified is not one of the options. Also yours: whether to touch the form-only items at all. Judge Chhabria's chambers will not care about a Witkin edition, and a global find-and-replace on short cites the night before filing is how a clean brief acquires a new error.
What would make this materially better. (1) A Westlaw pull of *Smith v. Jones*, 234 F.3d 567: one lookup resolves the largest risk in the brief. (2) The table of authorities, so I can reconcile it against this ledger. (3) The source of the "unequivocal repudiation" quotation on p. 14.
Why this prompt is built the way it is
## Framework
1. **A ledger, in document order, checked against the right manual.** Every citation gets a row and a location; no sampling. First reference full, subsequent short, measured against the manual the court actually requires, not the one you know best. Every quotation and specific proposition carries a pin cite, and each that does not gets flagged.
2. **Id. discipline.** An id. must point to the immediately preceding authority with nothing intervening. String cites break the chain.
3. **Proposition match.** Where the text asserts a holding, a quote, or a number, ask whether that source could carry it. Mismatch is the tell.
4. **Suspect means suspect, and history is a task list.** Implausible reporter-volume-page combinations, unplaceable case names, out-of-range pin cites. Say why in one clause and never guess a fix. Cases that warrant Shepardizing are flagged as work to do, not as a conclusion about their status.