A recent court filing on behalf of onetime Trump lawyer and self-described “fixer” Michael Cohen may have cited cases that do not exist, a federal judge has found.

U.S. District Judge Jesse Furman of the Southern District of New York issued a two-page order to show cause Tuesday, writing that Cohen’s attorney David M. Schwartz, a solo practitioner in New York, cited three cases as examples of “District Court decisions, affirmed by the Second Circuit Court, granting early termination of supervised release.”