A misdirected text message from Boris Epshteyn, a personal attorney to President Donald Trump, gave author Michael Wolff advance warning that First Lady Melania Trump planned to seek sanctions against him, Wolff revealed on the “Inside Trump’s Head” podcast.
The 72-year-old author told co-host Joanna Coles that Epshteyn accidentally texted him on Jan. 26, 2026, writing: “Hey team, what’s our timing on the Section 11 filing?” Wolff’s phone number had remained in the attorney’s contacts from previous off-the-record conversations, and the message showed the legal campaign against him was being orchestrated at the highest levels of Trump’s legal team.
Origins of the Dispute
The legal battle traces back to October 2025, when Melania Trump threatened Wolff with a lawsuit over published statements connecting her to deceased convicted sex offender Jeffrey Epstein. The allegations included insinuations that Melania may have met Donald Trump through Epstein’s social circle, and that the president initially engaged in sexual relations with Melania aboard Epstein’s private plane. Wolff countered by launching a suit under anti-Strategic Lawsuit Against Public Participation laws — statutes designed to protect journalists and others from litigation intended primarily to silence speech rather than obtain legitimate relief.
Judge Raises Doubts About Sanctions Effort
District Judge Mary Kay Vyskocil, a former Federalist Society member whom Trump appointed to New York’s Southern District during his first administration, dismissed Wolff’s case in May after determining he had attempted to litigate a dispute before any actual lawsuit was filed against him. Wolff has appealed to the Second Circuit.
Melania Trump’s attorneys have nonetheless continued to push for penalties against the author, describing his conduct as marked by “factual misrepresentations, frivolous legal arguments and bad-faith conduct.” They contend Wolff should face sanctions substantial enough to deter similar conduct going forward and to reimburse her legal fees.
But on July 1, Vyskocil herself questioned whether pressing ahead in her court served the parties’ best interests. She warned Melania’s legal team that a Rule 11 sanctions motion — the mechanism Epshteyn called “Section 11” in his text — carries a demanding standard, and noted that parties sometimes neglect to consider whether pursuing such a motion justifies the cost in light of the likely outcome. The lawyers indicated they intend to proceed anyway.
“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 framed the sanctions push as a delay-and-drain tactic, arguing it reflects a broader pattern in which Trump-aligned parties deploy aggressive motions mainly to exhaust opponents’ resources rather than prevail on the merits.
A Career Built on Trump Scrutiny
Wolff has written four books analyzing the president and his administrations: “Fire and Fury,” “Siege,” “Landslide,” and “All or Nothing.”
When passages from “Fire and Fury,” his first Trump volume, surfaced on Jan. 3, 2018, the ensuing controversy led Trump to dispatch lawyers and prompted the White House to denounce the book as tabloid garbage.
Critics of Wolff’s reporting have consistently pointed to inconsistencies in his work. In the introduction to “Fire and Fury,” Wolff acknowledged that many accounts in the book conflict with one another and that some may eventually prove false — although he said he selected the versions he believed to be true. Those caveats have not quelled the legal and political firestorms his Trump coverage has generated.
The Path Ahead
With Vyskocil’s concerns now on the record, Melania’s sanctions drive faces a steep climb — courts rarely award Rule 11 sanctions without clear proof of deliberate bad faith, exactly the bar the judge underscored.