Kluft v. Wash Multifamily Laundry

What happens when defense counsel submits a declaration summarizing an AI-powered review of a sampling of his client's contracts? It is inadmissible.

Interesting decision out of Los Angeles County, California Superior Court (Kluft v. Wash Multifamily Laundry, LLC, Case No. 22STCV33031, 2026 WL 1270128 (Apr. 20, 2026)).

Plaintiff objected to a defense declaration, in which defense counsel explained his use of Harvey (like Legora) to review and summarize a large set of his client's contracts.

Although there was human review of Harvey's output (and those humans claimed Harvey was correct 99.22% of the time), the Court questioned that accuracy (and explained in some detail why that reliability quotient was questionable).

Defense also did not have an expert. Plaintiff did--a statistician who challenged the "statistical randomness" of defense and Harvey's contract review.

And, no one could explain exactly how Harvey worked or how it reached its conclusions.

The end result? The declaration and the testimony concerning Harvey's findings was inadmissible because it lacked foundation or amounted to improper expert testimony.

Something for all us litigators to keep in mind--even if a declaration of this nature had not crossed your mind, it might cross your team's mind or opposing counsel's mind. Be on the look out.

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