Neither a spokesman for Mr. Trump nor Ms. Habba immediately responded to requests for comment.
Ms. Habba was the lead lawyer among a group who filed the suit on Mr. Trump’s behalf in March. She is also representing Mr. Trump in a sweeping fraud case brought by the New York State attorney general and a case filed by E. Jean Carroll, a woman who alleges that Mr. Trump raped her in the 1990s. Ms. Habba has offered advice in the federal investigation into Mr. Trump’s handling of classified documents as well, according to people close to Mr. Trump, including arguing he should hire someone to search his properties for any additional documents.
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The suit names Mrs. Clinton, the Democratic National Committee and other people and entities that he claimed conspired to damage him in the 2016 election with what he called false claims about his ties to Russia. Among the defendants were Mr. Comey; the former deputy F.B.I. director Andrew G. McCabe, who opened the counterintelligence investigation into Mr. Trump’s ties to Russia; and the former British intelligence agent Christopher Steele, who helped circulate a dossier of lurid claims about Mr. Trump and Russia, many of which were unsubstantiated.
The conspiracy-minded racketeering suit was filed with hyperbole and exaggerations, and made claims easily shown to be false. In the ruling on Thursday, Judge Middlebrooks broke down how the suit’s claims — including that Mrs. Clinton and Mr. Comey had conspired to take down Mr. Trump — were “implausible” and “categorically absurd.”
Mr. Trump’s claims were “a hodgepodge of disconnected, often immaterial events, followed by an implausible conclusion,” the judge wrote, adding, “This is a deliberate attempt to harass; to tell a story without regard to facts.”
Judge Middlebrooks, who was nominated by President Bill Clinton in 1997, threw out the suit in September, saying that “most of plaintiff’s claims are not only unsupported by any legal authority but plainly foreclosed by binding precedent.” The judge said that what the suit “lacks in substance and legal support, it seeks to substitute with length, hyperbole, and the settling of scores and grievances.”
He said Mr. Trump was trying to brandish a “political manifesto” against political rivals, masquerading as a lawsuit.
In November, Judge Middlebrooks fined Mr. Trump’s lawyers $50,000 and ordered them to pay the legal fees of one of the defendants. But a number of defendants, including Mrs. Clinton, filed jointly seeking additional sanctions, which the judge wrote at the time “may be appropriate.” The actions of Mr. Trump’s lawyers, he warned then, could also merit attention from “the bar and disciplinary authorities.”
