Direct ContemptNecessity of Warning of
When the defendant's conduct is clearly contemptuous, United
v. Schiffer, 351 F.2d 91 (6th Cir. 1965), cert. denied, 384 U.S.
(1966), or when he is aware of the character of his conduct, United
Seale, 461 F.2d 345 (7th Cir. 1972), the court need not warn the
of the fact that his conduct is contemptuous prior to summarily holding him
criminal contempt although such a warning may be appropriate. United
v. Abascal, 509 F.2d 752, 755 (9th Cir.), cert. denied, 422 U.S.
[cited in USAM 9-39.000]