Donald Trump’s record against the writer E. Jean Carroll is now at 0-2 after a judge in New York City tossed out his defamation countersuit on Monday. Trump had accused Carroll of defaming him when she claimed that he raped her in the changing room of a Bergdorf Goodman store in the mid-1990s. However, in a separate civil case earlier this year, a jury sided with Carroll when they found him liable of sexual assault. While jurors did not, specifically, find Trump liable of “rape,” Judge Lewis A. Kaplan ruled on Monday that the sexual assault in question was akin to rape, thereby making Carroll’s claims “substantially true.” Carroll initially sued Trump under New York’s Adult Survivors’ Act, which provides victims with a short window to litigate sexual abuse claims outside the state’s statute of limitations. She filed a parallel defamation suit after Trump branded her allegations as lies. That suit is still pending.