Multi-modal large language models (LLMs) have shown remarkable performance in various natural language processing tasks, including data extraction from documents. However, the accuracy of these models can be significantly affected by document in-plane rotation, also known as skew, a common issue in real-world scenarios for scanned documents. This study investigates the impact of document skew on the data extraction accuracy of three state-of-the-art multi-modal LLMs: Anthropic Claude V3 Sonnet, GPT-4-Turbo, and Llava:v1.6. We focus on extracting specific entities from synthetically generated sample documents with varying degrees of skewness. The results demonstrate that document skew adversely affects the data extraction accuracy of all the tested LLMs, with the severity of the impact varying across models. We identify the safe in-plane rotation angles (SIPRA) for each model and investigate the effects of skew on model hallucinations. Furthermore, we explore existing skew detection and correction mechanisms and discuss their potential limitations. We propose alternative approaches, including developing new multi-modal architectures that are inherently more robust to document skew and incorporating skewing techniques during the pre-training phase of the models. Additionally, we highlight the need for more comprehensive testing on a wider range of document quality and conditions to fully understand the challenges and opportunities associated with using multi-modal LLMs for information extraction in real-world scenarios.