Trump is still appealing Judge Engoron's gag order, which he imposed in response to the former president's constant flurry of attacks against law clerk Allison Greenfield. Trump's posts about Greenfield reportedly resulted in the clerk getting a deluge of death threats from Trump supporters — many of them anti-Semitic in nature.

"Ms. Greenfield's personal information, including her personal cell phone number and personal email addresses also have been compromised resulting in daily doxing. She has been subjected to, on a daily basis, harassing, disparaging comments and antisemitic tropes," a court document detailing the threats read. "I have been informed by Ms. Greenfield that she has been receiving approximately 20-30 calls per day to her personal cell phone and approximately 30-50 messages per day on combined sites of social media, Linkedln and two (2) personal email addresses."

Engoron, who is overseeing the bench trial and will decide its verdict, already ruled that Trump was liable for fraud. The verdict will ultimately decide how much in financial penalties Trump should have to pay. New York Attorney General Letitia James is seeking $250 million in damages, alleging that Trump knowingly and deliberately submitted false financial statements aimed at increasing the value of Trump's real estate portfolio in order to secure more favorable tax and insurance benefits.