Days before First Lady Melania Trump’s lawyers are due to file for sanctions against him, author Michael Wolff says he has known the move was coming since January — and that he has one of President Donald Trump’s own lawyers to thank for the heads-up.
Wolff, 72, revealed on the “Inside Trump’s Head” podcast that on the morning of Jan. 26, 2026, he received a text from Boris Epshteyn, a personal attorney to the president, that read: “Hey team – what’s our timing on Rule 11? Reading filing now.” Moments later came a second message: “Wrong recipient – please delete.” Wolff told co-host Joanna Coles that his number was already in the lawyer’s contacts from previous off-the-record conversations, and called the text a strong indication the case was being overseen directly from the White House. He stopped short of calling it proof, writing that it proved “nothing that I didn’t know” — and raised the possibility the text was not misdirected at all, but “another act of intimidation.”
Epshteyn has said Wolff remains in his address book because the author is a frequent off-the-record contact, and that he was writing a text about Wolff that was not meant to go to him.
A $1 Billion Threat Spirals Into Courtroom Drama
The dispute traces back to October 2025, when Melania Trump threatened to file a $1 billion lawsuit against Wolff over claims he made about her and the late convicted sex offender Jeffrey Epstein. Those claims included an allegation that Melania may have first crossed paths with Donald Trump through Epstein’s social circle, and a separate allegation that the president first slept with Melania aboard Epstein’s private jet. In response, Wolff filed suit against Melania Trump under anti-Strategic Lawsuit Against Public Participation statutes — laws designed to shield journalists and others from litigation intended to suppress free expression rather than seek genuine legal remedy.
That lawsuit did not survive long. U.S. District Judge Mary Kay Vyskocil, a former Federalist Society member whom Trump appointed to New York’s Southern District during his first term, dismissed Wolff’s case in May, accusing him of an “inappropriate level of tactical gamesmanship.” Vyskocil ruled that Wolff lacked standing because Melania Trump had not then — and still has not — actually sued him for defamation. Wolff appealed to the Second Circuit on June 17.
Melania Pushes for Sanctions Despite Judicial Skepticism
Rather than letting the matter rest after winning the dismissal, Melania Trump’s legal team moved to seek sanctions against Wolff, arguing he should be penalized for what they described as “factual misrepresentations, frivolous legal arguments and bad-faith conduct” — penalties they say should be sufficient to deter future misconduct and reimburse her legal costs.
That push, however, ran into immediate resistance from Vyskocil herself. On July 1, she questioned whether it was even in the parties’ interest to keep battling in her courtroom. She told Melania’s lawyers that the first lady would have to show “clear evidence” the suit was brought baselessly and in bad faith — a standard that, by the judge’s own description, “places a very high burden on the moving party.” Noting that “the case is now closed,” Vyskocil suggested Melania might prefer to quit while ahead. Her attorneys said they intend to press ahead, and told the court they will file the formal sanctions motion by July 20.
“Essentially, they are moving to sanction my lawyers for doing nothing more than bringing the lawsuit against Melania Trump,” Wolff said on the podcast. “So this is preposterous on its face.” Wolff has said the litigation is being funded by more than $800,000 in GoFundMe donations from tens of thousands of small contributors, and that he expects the final cost to run well past that — which, he argues, is exactly the point.
Wolff’s Long History of Trump Controversies
Wolff has built much of his recent career chronicling the Trump orbit, producing four books about the president and his administrations: “Fire and Fury,” “Siege,” “Landslide,” and “All or Nothing.”
His first Trump book, “Fire and Fury,” caused an immediate firestorm when excerpts surfaced on Jan. 3, 2018, prompting Trump lawyer Charles Harder to fire off cease-and-desist letters within hours and the White House to brand the book tabloid fiction.
Critics of Wolff’s work have long pointed to inconsistencies in his reporting. In the introduction to “Fire and Fury,” Wolff himself acknowledged that many accounts within the book conflict with one another and that some may prove inaccurate — though he added that he settled on the versions of events he believed to be true.
What Comes Next for Both Sides
With the motion due Monday and the judge’s skepticism already on the record, Melania’s sanctions push faces a steep uphill climb. Wolff framed the effort as a delay-and-drain tactic — one he says reflects a broader pattern of Trump-aligned litigants filing aggressive motions to exhaust opponents rather than win on the merits.