Justice Juan Merchan appeared to lose patience with Donald Trump's lawyer, Todd Blanche, in the hearing on Thursday about potential violations of a gag order, legal analysts and reporters in the courtroom posted on social media.
Trump has already been found to have broken the order nine times. Thursday's hearing came after the Manhattan District Attorney's office accused him of four new violations.
The latest accusations are related to Trump's attacks on his former lawyer, Michael Cohen, who will be a witness in the trial.