After Judge Engoron raised concerns that Trump had possibly violated the limited gag order the judge had imposed during the trial, Trump and his lawyers remained inside the courtroom at the start of the lunch break for a 25-minute conference that was sealed to the press.

Afterward, when asked by reporters about the private conference, Trump responded, "I can't tell you."

Trump otherwise praised his lawyer's cross examination of Michael Cohen, who admitted he lied under oath on multiple occasions.

"That was a Perry Mason moment," Trump said.

Defense attorney Alina Habba's cross-examination of former Trump attorney Michael Cohen featured frequent objections, cross talk and nonresponsive or argumentative answers that often breached customary courtroom decorum.

"You didn't ask me a yes-or-no question," Cohen scolded Habba at one point. "Yes I did," Habba shot back.

Cohen at times resisted answering questions, either objecting to them or insisting he did not understand them, while Habba paced the floor, blaring her questions into a hand-held microphone as Trump observed from the defense table.

"President Trump makes you relevant," Habba chastised Cohen. "If you didn't work for President Trump you wouldn't make most of your income today."

Cohen eventually conceded that he makes his living because of his prior relationship with Trump.

"Outside of your two podcasts, your merchandise and your books, is there any other form of income in your life?" Habba asked. "No," Cohen answered.

Habba's cross-examination concluded with a pointed question meant to question Cohen's motive for cooperating with the attorney general's investigation.

"Did you ever ask President Trump to pardon you while he was in the White House?" Habba asked.

"No," Cohen said.

"And he didn't pardon you?" she asked.

"No," Cohen replied.

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.