Rudy Giuliani, the former mayor of New York
Rudy Giuliani, the former mayor of New York and personal lawyer for Donald Trump, has filed for bankruptcy. AFP

A judge overseeing Rudy Giuliani's bankruptcy case refused to lift a legal barrier that prevents the former New York City mayor from appealing a $148 million defamation judgment.

Judge Sean Lane also expressed concern over the lack of progress in resolving Giuliani's financial situation.

Giuliani declared bankruptcy in December after being ordered to pay $148 million to two former election workers, whom he had falsely accused of involvement in a conspiracy during the 2020 election.

But since then, Giuliani has failed to meet deadlines for filing financial disclosure reports and has not managed to sell his properties in New York and Florida.

He was recently also suspended from his daily show on WABC Radio for repeatedly violating the station's ban on discussing false claims about former President Donald Trump's defeat in the 2020 election.

Rachel Strickland, an attorney representing the election workers, told the judge: "They have done nothing. They sold nothing. They settled nothing."

In response, Judge Lane said: "I agree with you. And I am disturbed about the status of this case."

Giuliani's attorneys said their client has upcoming work opportunities to generate income, although they did not specify the nature of this work. They also said that Giuliani's Manhattan apartment might be liquidated soon.

Judge Lane also addressed a request from the lawyers of the election workers, who sought to bar Giuliani from making further defamatory statements against them. While the judge did not immediately decide on this request, he said that he would not permit the court to be used to flout legal requirements, saying: "Tell your client to stop. It's not complicated."

The judge has scheduled another meeting with the lawyers for Thursday to further discuss the issue.

Meanwhile, it has been revealed that Giuliani was served with notice of his indictment by an Arizona grand jury last month related to his alleged attempts to impede Trump's 2020 loss in the state, according to state prosecutors.

The summons notifies him of criminal charges and requires him to appear before a judge by May 21.

Despite efforts, Arizona Attorney General Kris Mayes's team has struggled to serve Giuliani with a summons regarding his indictment.

According to Richie Taylor, a spokesperson for the attorney general's office, multiple attempts have been made to serve Giuliani, including a visit by two agents to his New York City apartment. However, they were not granted access to Giuliani by the building's front desk.

The office has also tried to contact Giuliani through various phone numbers without success.