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He urged Merchan to warn Trump “that his recent conduct is contumacious and direct him to immediately desist.”

Former federal prosecutor Andrew Weissmann, who served on special counsel Bob Mueller's team, said it was "interesting" that Chutkan excused Trump's presence at the hearing "given his dangerous and contumacious social media posts."

“Mr. Donziger’s conduct was a pattern of contumacious behavior that bore out over the better part of a decade,” Preska said.

“Defendants began this litigation with the same opportunities for discovery and presentation of evidence as any other litigant, but they have squandered these opportunities with poor strategic decisions and contumacious, combative conduct.”

Admittedly, the two chambers of Congress have rarely made use of their power to directly arrest and detain contumacious witnesses.