In 1995, the Philadelphia-based U.S. Court of Appeals for the Third Circuit promulgated Local Appellate Rule 28.1(d), which states in full: "The court expects counsel to exercise appropriate professional behavior in all briefs and to refrain from making ad hominem attacks on opposing counsel or parties." Exhibiting professionalism on appeal may seem like good policy, but apparently it can be quite difficult advice to follow in practice.
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