Judge says "none" of the cases cited by Michael Cohen's lawyer seem to exist

The big picture: Cohen was sentenced to three years in prison in December 2018 after pleading guilty to federal charges including campaign finance violations related to hush money payments to adult film actress Stormy Daniels.

• Former President Trump's ex-personal attorney also pleaded guilty to tax evasion and lying to Congress.
• He was released in November 2021.

What's next: Furman gave Schwartz until Dec. 19 to provide copies of the three decisions he cited to court.

• If he is unable to do so, Furman said the lawyer must provide a sworn declaration and "a thorough explanation of how the motion came to cite cases that do not exist and what role, if any, Mr. Cohen played in drafting or reviewing the motion before it was filed."

What they're saying: E. Danya Perry, a new lawyer who said she began representing Cohen in his request after Schwartz filed the motion, said she was "unable to verify" from her research into the matter "the case law that had been submitted" in the motion, per the New York Times.

• "Consistent with my ethical obligation of candor to the court, I advised Judge Furman of this issue," added Perry, who told the NYT Cohen would not comment on the matter.
• Representatives for Schwartz did not immediately respond to Axios' request for comment.

Go deeper: House Republicans issue criminal referral for Michael Cohen