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Judge's dismissal of Rudy Giuliani's bankruptcy case paves the way for collection of $146M verdict against him

In the ruling, which denies Giuliani bankruptcy protections, the judge said Giuliani's "lack of financial transparency is particularly troubling."
Rudy Giuliani, the former personal lawyer for former U.S. President Donald Trump  in Washington, DC. on Dec. 11, 2023.
The judge's ruling allows two former election workers in Georgia to begin collecting on a $146 million verdict against him.Drew Angerer / Getty Images

A New York bankruptcy judge on Friday dismissed Rudy Giuliani's petition seeking bankruptcy protections, ruling that the onetime attorney to former President Donald Trump had failed to turn over key financial information despite being given numerous directives to do so.

The order by Judge Sean Lane paves the way for two former election workers in Georgia who were repeatedly defamed by Giuliani after the 2020 election to begin collecting on their $146 million verdict against him.

Giuliani filed his bankruptcy petition in December, days after a jury awarded Ruby Freeman and her daughter Wandrea “Shaye” Moss nearly $150 million for the false allegations of election fraud he made about them.

The bankruptcy filing had enabled Giuliani to get protection from creditors under the “automatic stay” feature of federal bankruptcy law, which, with some exceptions, halts ongoing litigation as well as the enforcement of pre-existing judgments.

Giuliani had been found liable for defaming Freeman and Moss after repeatedly ignoring court orders in that case — and Lane said in his 22-page ruling Friday that the former New York City mayor ignored court orders in the bankruptcy case as well. Lane said that Giuliani had failed to turn over virtually any necessary information about his businesses. Information that he did turn over about his personal spending and income was often wrong or incomplete, the judge said.

"Every single monthly operating report filed by Mr. Giuliani has been untimely," Lane wrote. "Perhaps even more troubling, the information in the monthly operating reports has been incomplete or inaccurate. For example, the monthly operating report for February 2024 attaches bank statements for the wrong year, February 2023."

"The monthly operating reports also appear to contain errors as none of the end of month cash balances match the opening cash balance for the following month," the judge added.

Giuliani also was not forthcoming with information about a book contract or a coffee sponsorship deal, the judge noted.

"The lack of financial transparency is particularly troubling given concerns that Mr. Giuliani has engaged in self-dealing," Lane wrote. Giuliani further indicated that he "received no income other than his social security benefits even though he receives compensation" from other sources, including "between $100,000 and $150,000 from his work hosting a podcast called America’s Mayor Live."

Absent intervention by an appeals court, the end of the bankruptcy case frees Freeman and Moss to go after Giuliani's assets, including his homes and bank accounts.

Another potential option for Freeman and Moss would be to assume Giuliani’s claims that Trump and the Republican National Committee owe him $2 million for his work challenging the results of the 2020 election — and even sue those entities directly.

A source familiar with the case said Freeman and Moss will “pursue all available avenues” to get their claims satisfied.

Rachel Strickland, the lead bankruptcy attorney for the mother and daughter, said in a statement Friday that Giuliani had filed his petition "in bad faith" and "tried to game the legal system and further harm Ruby and Shaye."

"Judge Lane saw through Giuliani's tactics and threw the case out. As a result, Ruby and Shaye can begin to exercise their judgment and make Rudy pay for his malicious lies," Strickland said.

Ted Goodman, a spokesperson for Giuliani, said the "bankruptcy case was burdened with many of the same voluminous and overly broad discover requests and other actions — including regular leaks of information — intended to harm the mayor and destroy his businesses," and said that he'd been denied the ability to appeal the defamation judgment while the proceeding was pending.

The judge's ruling comes during a difficult stretch for Giuliani, a former federal prosecutor.

In May, WABC radio suspended Giuliani and canceled his show for continuing to make false statements about the 2020 election, which could have opened the station up to legal liability. This month, he was disbarred in New York over his election lies, and is also facing the prospect of losing his law license in Washington, D.C.

Giuliani has also been hit with election fraud related charges in Georgia and Arizona, and is an unindicted co-conspirator in special counsel Jack Smith’s federal election interference case against Trump. He's pleaded not guilty and denied any wrongdoing.