Rudy Giuliani filed for Chapter 11 bankruptcy protection in New York on Thursday, citing debts that include a recent nearly $150 million civil judgment against him for defaming Georgia election workers while acting as a lawyer for former President Donald Trump.

The filing by Giuliani came a day after a federal judge in Washington, D.C., ordered him to begin paying the two election workers the damages he owed for their lawsuit against him, and three days after the women filed a new lawsuit seeking to bar him from defaming them again.

[As Giuliani’s attorneys said, this should surprise no one. However, it won’t solve all of Giuliani’s issues either. Bankruptcies do not usually discharge debt from punitive awards for willfully malicious conduct such as defamation. That’s a good reason to be careful with public statements about non-public persons, in the Sullivan sense. — Ed]