I love how the author describes the ruling, “unsparing.” Heh.

He assured this Court directly that he “understand[s] the obligations” because he has “been doing this for 50 years[.]” In this case, however, Giuliani has given only lip service to compliance with his discovery obligations and this Court’s orders by failing to take reasonable steps to preserve or produce his ESI. Instead, Giuliani has submitted declarations with concessions turned slippery on scrutiny and excuses designed to shroud the insufficiency of his discovery compliance.

And that’s just page 1.