Another "note on civility"

One of 2019's most memorable opinions was Briganti v. Chow (2019) 42 CA5th 504, 510, in which Justice Currey included a section titled "A Note on Civility, Sexism, and Persuasive Brief Writing." Well, this year's installment is Brock v. Bramzon (unpub'd), in which Justice Currey cites Briganti and remands for the trial court to further explore and possibly impose sanctions. Those collecting such notes at home should add this case: Garcia-Pastrana v. U.S. (D.P.R. 2012, No. 10-2147), in which Judge José Antonio Fusté  wrote, "we pause briefly for a note on civility and professionalism—or the lack thereof—with respect to the behavior of Rafael Castro-Lang, Petitioner's current counsel, during the evidentiary hearing." He then recounted the "rancorous tone of voice" and bad behavior by counsel, which "raised more than a few eyebrows in court," and concluded: "In sum, vigorous advocacy and professional courtesy are not mutually-exclusive concepts ...."