On December 27, 2010, Florida Circuit Court Judge Gill Freeman issued a default judgment against Minkow in response to a motion by Lennar. Freeman found that Minkow had repeatedly lied under oath, destroyed or withheld evidence, concealed witnesses, and deliberately tried to "cover up his misconduct." According to Freeman, Minkow had even lied to his own lawyers about his behavior. Freeman determined that Minkow had perpetrated "a fraud on the court" that was so egregious that letting the case go any further would be a disservice to justice. In her view, "no remedy short of default" was appropriate for Minkow's lies. She ordered Minkow to reimburse Lennar for the legal expenses it incurred while ferreting out his lies. According to legal experts, terminating sanctions such as default judgments are extremely rare, since they are reserved for particularly egregious misconduct and have the effect of revoking a litigant's right to defend himself. Earlier, Freeman had been so angered by Minkow's behavior that she called him a liar in open court, a rarity for a judge. Lennar estimated that its attorneys and investigators spent hundreds of millions of dollars exposing Minkow's lies.