Freeman and Moss accused Giuliani of defamation in his claims that they mishandled ballots in Fulton County, Ga., that allowed President Joe Biden to defeat Trump in the state’s 2020 presidential election. Giuliani has argued, in part, that his comments are protected by the First Amendment.

“The bottom line is that Giuliani has refused to comply with his discovery obligations and thwarted plaintiffs Ruby Freeman and Wandrea’ ArShaye Moss’ procedural rights to obtain any meaningful discovery in this case,” Howell said in a 57-page opinion in the case.

Howell bristled at Giuliani’s defiance, claiming his actions were more of an effort to bolster public opinion rather than the law.

“Rather than simply play by the rules designed to promote a discovery process necessary to reach a fair decision on the merits of plaintiffs’ claims, Giuliani has bemoaned plaintiffs’ efforts to secure his compliance as ‘punishment by process,'” Howell said.

“Donning a cloak of victimization may play well on a public stage to certain audiences, but in a court of law, this performance has served only to subvert the normal process of discovery in a straightforward defamation case.”

Giuliani previously complained that he had difficulty finding the records Freeman and Moss asked for because the FBI seized many of his devices in 2021 as part of a foreign-influence investigation that did not lead to any charges against him and serious personal financial difficulties.

Howell told both sides to prepare for a Washington trial to determine compensatory and punitive damages against Giuliani.

Meanwhile, Giuliani faces 13 charges in a Georgia case alleging he and 18 others, including Trump, engaged in criminal conspiracies to reverse the state’s election results, violating Georgia’s racketeering act and soliciting a public officer to break their oath.

Giuliani surrendered last week on those charges and was freed on a $150,000 bond.

Giuliani is also believed to be among the six unindicted co-conspirators mentioned in a federal indictment charging Trump with a scheme to overturn the 2020 election.

A disciplinary committee in Washington has recommended he be disbarred and his law license is suspended as he undergoes an ethics review in New York.