In this unpub from 1/5 (on page 8, footnote 5), appellant's counsel is chastised for bad tone:
In its reply brief, FanX accuses the trial judge of being “completely uninformed,” “disregard[ing] . . . California law,” and “abdicat[ing] . . . her duties as a judge” in denying the motion to vacate. It is a long-standing rule that an appellate brief “containing matter manifestly disrespectful toward the trial judge is to be deemed contempt of the appellate court.” (First Nat. Bank v. Superior Court (1909) 12 Cal.App. 335, 348.) We advise counsel for FanX to consider his language more carefully in the future when challenging a ruling of the trial court.
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