New York, New York - Donald Trump returned to his New York civil fraud trial on Tuesday and complained about a partial gag order imposed on him by the judge presiding over the election subversion case.

Trump's former personal lawyer-turned-foe Michael Cohen had been scheduled to testify at the trial on Tuesday but had to delay his appearance to attend to what he said was a medical issue.

The ex-president spoke to reporters as he arrived at the Manhattan courtroom, attacking New York attorney general Letitia James, who brought the civil fraud case against him, the judge presiding over the trial, and President Joe Biden.

"This is a witch hunt by a radical lunatic attorney general," Trump said. "And it's very unfair."

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"This is a rigged trial," he added, with a "Democrat judge" who is "very liberal."

Trump, the frontrunner for the 2024 Republican presidential nomination, also claimed, falsely, that the federal judge who will preside over his trial in Washington for conspiring to overturn the 2020 US election had taken away his "right to speak."

"My speech has been taken away from me," he said. "I'm a candidate that's running for office and I'm not allowed to speak."

He added: "It's all set up by Biden and his thugs that he's surrounded with to try and sneak out an election victory that he's not entitled to win."

US District Judge Tanya Chutkan did not take away Trump's "right to speak" on Monday. Instead, she ordered him not to publicly attack prosecutors, court staff or potential witnesses ahead of the trial scheduled to begin in Washington in March 2024.

Chutkan's ruling came after special counsel Jack Smith, a frequent target of Trump's vitriol, filed a motion claiming that the real estate tycoon's inflammatory rhetoric threatened to undermine his trial for election subversion.

Judge Arthur Engoron, who is overseeing the civil fraud trial, also slapped a limited gag order on the former president this month after he insulted a court clerk in a social media post.

Engoron forbade "all parties from posting, emailing or speaking publicly" about his court staff.