No, Borat himself implies that she is.
Giuiliani thought he showed up for a normal interview by a young adult woman.
She flirts with him and he flirts half-back.

Sequence of events:

1. Giuliani gets interviewed by a woman.
2. They wrap up the interview.
3. She invites him to his bedroom, supposedly for a drink.
4. They lift and shift clothes to help each other take off their microphones.
5. A half-naked stranger (Borat) barges into his hotelroom and tells him to stop what he’s doing because she’s underage and only 15 years old.

On top of making people think that Giuliani think she’s 15 as in the movie,
as the adult woman play a teenager dressing up in teen/child clothes throughout most of the movie (not the interview), there are signs that some of the video and audio might be edited.

The audio where she invites him to the bedroom for a drink was out of mouth’s view and so was the phone number and address request.

Not only do I think that that’s an entrapment, but I will accuse Sacha Cohen of putting his own life and that of his assistant’s life in unnecessary danger.
Things could have easily gone wrong in my humble opinion if it hadn’t been Rudy, but someone far more on edge carrying a gun and thinking the jump-scaring stranger is a burglar or that the whole thing was some kind of an assassination plot instead of an innocent prank.

At the same time you have Sacha Cohen acting in a way towards a Republican official that I WOULD have called out if Giuliani acted like that towards his assistant.
But this is Sacha Cohen doing so.

Sequence of events:

1. Ron Paul gets interviewed by Bruno, another character by Sacha Cohen.
2. Ron Paul is suggested by the cameraman to take a break in his hotel room because of technical difficulties.
3. Bruno walks into Paul’s hotel room with him.
4. Bruno then makes advances to Paul and starts taking his jacket off.
5. Paul rejects his advances with shortcut no’s, physically turning away from him and taking an interest in magazine lying around. Clearly showing that he’s feeling uncomfortable.
6. Bruno then takes off his pants.