Lawyers for Donald Trump on Monday urged a New York appeals court to stay the execution of a $464 million business fraud judgment against their client—calling the bond “a practical impossibility” that would require nearly $1 billion in cash reserves.

“Waiving the bond requirement will impose no cognizable harm on the Attorney General” Letitia James, the filing reads. “The case involves no actual victims and no award of restitution, and she is fully protected by Defendants’ real-estate holdings. This factor alone warrants a stay.”