After the first break of the day, Judge Engoron threatened to penalize Trump after what Engoron said was a "dangerous disobeyal" of the gag order he imposed prohibiting comments about his staff.

"I am very protective of my staff, as I should be. I don't want anybody killed," said Engoron, who handed down the limited gag order earlier in the trial after Trump made a social media post about his clerk.

Citing Associated Press reporting, Engoron expressed concern that Trump made a comment in the hallway about "a person who is much more partisan sitting alongside him."

Since Engoron's clerk usually sits to his right, the judge interpreted Trump's comment as referring to her.

"It is very easy for the public or anyone to know who this person is," Engoron said.

Trump's attorney Chris Kise said there was a misunderstanding, clarifying that Trump was referring to Michael Cohen, who has been sitting in the witness stand to Engoron's left. Kise attested that Trump confirmed to him that he was referring to Cohen.

"That's the way I read the statement," Kise said. "He is tired of listening to what he is hearing. It is very partisan."

Engoron did not impose any penalty and took Kise's explanation "under advisement."

Speaking to reporters during a break after his lawyer Alina Habba grilled Michael Cohen for over an hour, Trump continued his attacks on his former attorney.

"[He] went to jail for lying, [and] this is their only witness," Trump said of Cohen. "When you think about it, it's pretty amazing."

Trump said that despite the lack of a jury, he would win the case.

"We will win because the facts are on our side to a level that nobody's ever seen anything like that before," Trump said.

The case will be decided by Judge Engoron, who already determined in a pretrial ruling that Trump had engaged in repeated fraud.

Judge Engoron encouraged the attorneys in the case to be respectful of one another as the sparring continued during the cross-examination of former Trump attorney Michael Cohen.

After Assistant Attorney General Colleen Faherty attempted to object to why a news article referenced by the defense was not entered into evidence, defense attorney Chris Kise responded, "Just sit down and you will find out."

Cohen rarely looked toward Trump, largely directing his attention at Habba as she posed questions and shot back comments.

"You are very good at blaming other people," Habba observed to Cohen at one point during his testimony.

After Engoron called for the attorneys to be respectful, Kise retorted: "Respect is not something you get -- it's something you earn."

Confrontational outbursts punctuated the ongoing cross-examination of Michael Cohen as defense attorney Alina Habba attempted to confront the former Trump attorney with nearly a decade of his past statements about his ex-boss.

Habba showed Cohen portions of his books -- one of which was handed out in court -- as well as past comments on social media and media interviews in which Cohen heaped praise on Trump before Cohen broke with Trump in 2018.

"I can tell you that Mr. Trump's memory is fantastic, and I've never come [across] a situation where Mr. Trump has said something that is not accurate," Cohen told CNN in 2015 in a quote that was read aloud by Habba in court.

Habba also read from an ABC News story in which Cohen said he admired Trump and that he had read Trump's book, "The Art of the Deal," twice while in high school.

"I have answered every question you want. Why are you screaming at me?" Cohen asked Habba at one point after a line of questions related to his 2015 CNN appearance.

"Do I have animosity towards him? Yes, I do," Cohen said about Trump, as the former president sat just feet away from him.

"You have made a career out of publicly attacking President Trump, haven't you?" Habba asked.

"Yes," Cohen said.