NEW YORK — A Manhattan judge has ordered Rudy Giuliani to pay about $1.36 million in legal fees to attorney Robert Costello and the Davidoff Hutcher & Citron LLP for work done while he was investigated over efforts to overturn President Donald Trump’s 2020 election loss. With interest, the total bill rises to nearly $1.6 million.

Judge Arthur Engoron granted summary judgment on the fee dispute, rejecting Giuliani's claim that he never received bills for the work. The ruling requires Giuliani to cover the unpaid balance and the costs the firm incurred pursuing payment.

The ruling adds to a string of financial and legal setbacks for Giuliani, once celebrated as “America’s mayor” for his leadership after the Sept. 11 attacks. He has faced bankruptcy filings and other civil and criminal matters, including a defamation-related judgment in Georgia that led to a payout of $148 million to two former Georgia election workers and his disbarment in New York and Washington.

Costello and the firm had alleged Giuliani paid only $214,000 of the nearly $1.6 million billed, leaving a $1.36 million balance. The last payment to the firm was $10,000 on Sept. 14, 2023, about a week after Trump hosted a fundraiser at his Bedminster, New Jersey, golf club.

Costello represented Giuliani from November 2019 to July 2023 in matters ranging from investigations into his business dealings in Ukraine—an inquiry that led to an FBI raid on his home and office in April 2021—to state and federal probes tied to his actions after the 2020 election loss, as well as several civil lawsuits and disciplinary proceedings that culminated in Giuliani’s disbarment. Costello has since left Davidoff Hutcher & Citron LLP and, in September 2024, was hired as a lawyer for Republican-controlled Nassau County on Long Island.

In a separate thread of related action, Costello was called as a witness by Trump’s lawyers in the president’s hush-money criminal trial last year. He drew the trial judge, Juan M. Merchan, into a moment of friction by making comments under his breath and describing the proceedings as “ridiculous.”

Giuliani’s spokesman criticized Engoron’s ruling as partisan. “The idea that Judge Arthur Engoron is permitted to sit on a case involving President Donald Trump’s good friend and former personal lawyer, Mayor Rudy Giuliani, flies in the face of justice and demonstrates the partisan political nature of this decision,” Ted Goodman said. Messages seeking comment were left for Costello and Davidoff Hutcher & Citron.