New York Judge Arthur Engoron, who is presiding over former President Donald Trump’s $250 million civil fraud trial, has been warned by a liberal legal analyst about the kind of language he’s using during proceedings.

Michael Conway, a legal expert and former House Judiciary Committee counsel, Conway cited the trial of the so-called “Chicago 7” in a column at MSNBC last month, reminding “Engoron that the defendants in the notorious case went out of their way to antagonize Judge Julius Hoffman, which seems to be Donald Trump’s strategy in a case where Engoron has already found evidence of fraud,” Raw Story noted.

Conway further highlighted that during testimony, Engoron frequently clashed with both Trump’s legal team and the former president himself. He noted that instances of profanity are likely to be raised during an appeal.

“In New York, Engoron has used strident language in rejecting Trump’s legal positions, terming them ‘pure sophistry,’ ‘risible,’ ‘bogus arguments,’ and ‘egregious’ in his summary judgment opinion. He sanctioned five Trump attorneys for $7,500 each for the ‘borderline frivolous’ arguments in their briefs,” Conway wrote.

“Harsh language isn’t a problem if it’s justified. But the more Engoron pushes the envelope, the more he risks an appellate court disagreeing with his assessment. And Trump’s lawyers can and will argue the judge’s rhetoric is evidence of judicial bias,” Conway added.

Conway added that “there are other examples of Engoron seemingly overreacting in response to relentless complaining from Trump’s lawyers” before noting: “He needs to take all necessary steps to ensure that a New York appellate court cannot overturn his decision. And that means not reacting to Trump’s hate-filled speech or his lawyers’ baiting and provocation. It’s simply not worth it.”

To that end, New York Rep. Elise Stefanik, the No. 3 House Republican, filed an ethics complaint against Engoron last month in the case brought by Attorney General Letitia James.

In her letter, she accused Engoron of “clear judicial bias” against the former president and argued that he broke “several rules” in the judicial conduct code of New York State.

“Simply put, Judge Engoron has displayed a clear judicial bias against the defendant throughout the case, breaking several rules in the New York Code of Judicial Conduct.

“Last year, Judge Engoron told President Trump’s attorney that the former president is ‘just a bad guy’ who Democrat New York Attorney General Letitia James ‘should go after as the chief law enforcement officer of the state,’” she said in the complaint.

“At the start of the trial, Judge Engoron infamously smiled and posed for the cameras. After the defendant won an appellate ruling against Judge Engoron on the appropriate statute of limitations in this case, the judge simply ignored the ruling,” she said.

“Judge Engoron entered summary judgment against the defendant before the trial even began, without witnesses, other evidence, and cross-examination. This, despite the fact there’s disputed material evidence–and there’s no victim of the defendant’s supposed fraud. Indeed, as the trial evidence has made clear, the defendant paid back the sophisticated Wall Street banks, on time, in full, with interest, as agreed.4 No insurance company paid a penny. And these banks and insurance companies, supposedly defrauded, continue to do business with the defendant.

“Yet Judge Engoron decreed before trial the defendant somehow committed fraud. Now, the judge is holding a trial–with no jury–to determine how much of Tish James’ requested $250 million in damages–with no victims–he will extract from the defendant. How does this not violate the defendant’s Seventh Amendment right to a jury trial?” the representative said.

“And Judge Engoron has made it crystal clear he doesn’t care what the defendant or his attorneys have to say. Indeed, Judge Engoron illegally gagged them. Judge Engoron told the defendant: ‘We are not here to listen to what you have to say.’ He told the defendant’s counsel: ‘I am not here to hear what he has to say, now sit down!’ And Judge Engoron even threatened the defendant’s counsel if he filed a routine motion for a directed verdict: ‘You better not, Chris!’” she said.