Giuliani has been under pressure to turn over assets to pay $148m to Georgia election workers he allegedly defamed.
The fourth anniversary of the US Capitol riot was met with hope by those convicted for trying to overturn 2020 election.
The decision adds further uncertainty to the case, which alleges Trump and his allies tried to overturn the 2020 race.
Former New York mayor was one of many associates of Donald Trump who made false claims over 2020 election.