James’ office argued KSIC is a “small insurer that is not authorized to write business in New York” and had “never before written a surety bond in New York” prior to working with Trump.

According to the filing, KSIC has a total policyholder surplus of just $138 million. Under New York state law, the firm cannot expose itself to liabilities, like a bond, greater than 10% of its surplus, or just $13.8 million.

James’ office also criticized Trump’s apparent control of $175 million in cash he placed in an account as collateral, arguing the defendants “failed to meet their burden to demonstrate that the bond is ‘sufficiently collateralized by identifiable assets.'”

“KSIC does not now have an exclusive right to control the account and will not obtain such control unless and until it exercises a right to do so on two days’ notice,” her office wrote.

When Trump’s bond was posted, his attorney Alina Habba had said he “looks forward to vindicating his rights on appeal and overturning this unjust verdict.”

James earlier this month filed a motion asking Trump’s lawyers or the insurance company to “file a motion to justify the surety bond” or to provide additional information about the collateral backing the bond within 10 days.

Trump’s bond so far ensures James’s office can’t collect on the $464 million verdict Judge Arthur Engoron earlier this year handed down to Trump, the Trump Organization and top executives for conspiring for years to inflate the net worth of the organization’s assets.

Trump, alone, had been liable for $454 million.

A state appeals court in March reduced the bond to $175 million after Trump’s attorney’s successfully argued it would be “impossible” for him to secure a full bond.