See also this unpub from 4/2 here, where appellate sanctions are denied, but the appeal "comes right up to the line of sanctionable conduct" and some "remarks cross the line from vigorously asserting [] legal position[s] to ad hominem attack." "[I]t is telling that the closest legal question presented by this appeal is whether sanctions should be imposed. We caution [the pro per appellant] to proceed carefully in the future."
Law360 has 5 Key Steps To Prepare For Oral Arguments