Good question. I believe they're covered under the following -

"... electronic items like cellphones would not be permitted.

"The use of cellphones, laptops or any electronic devices will be strictly prohibited in the courtrooms. Any such devices will have to be turned off and secured outside of public view while in the courtrooms," ..."

-- as stated by Judge Merchan, according to the linked article. I didn't see anything specifically referencing audio recorders so can't be 100% sure, but the general tone of this ruling seems to prohibit recording of any kind during the proceedings.

Good question. I believe they're covered under the following -

"... electronic items like cellphones would not be permitted.

"The use of cellphones, laptops or any electronic devices will be strictly prohibited in the courtrooms. Any such devices will have to be turned off and secured outside of public view while in the courtrooms," ..."

-- as stated by Judge Metchan, according to the linked article.