The former president attacked Justice Arthur F. Engoron’s clerk in a social media post that soon disappeared. He was called to account behind closed doors.

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    Justice Engoron said that his statement should be considered a gag order forbidding any posts, emails or public remarks about members of his staff.

    Mr. Trump has spent much of the first two days of the trial attacking Justice Engoron, Ms. Greenfield and Letitia James, the New York attorney general.

    She accused Mr. Trump of “staggering fraud” in the way he inflated the values of his assets, as a way to gain favorable treatment from banks and insurance companies.

    Federal prosecutors who have accused Mr. Trump of seeking to overturn the 2020 election have asked a judge for a gag order, citing his threatening statements.

    In a criminal case against Mr. Trump in Manhattan, which stems from a 2016 hush money payment to a porn star, the judge has restricted the former president’s ability to post about some evidence.

    In a pretrial ruling, Justice Engoron found that the former president was liable for fraud and dissolved the companies he uses to run his New York properties.


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