When the defendant's conduct is clearly contemptuous, United States v. Schiffer, 351 F.2d 91 (6th Cir. 1965), cert. denied, 384 U.S. 1003 (1966), or when he is aware of the character of his conduct, United States v. Seale, 461 F.2d 345 (7th Cir. 1972), the court need not warn the defendant of the fact that his conduct is contemptuous prior to summarily holding him in criminal contempt although such a warning may be appropriate. United States v. Abascal, 509 F.2d 752, 755 (9th Cir.), cert. denied, 422 U.S. 1027 (1975).
[cited in JM 9-39.000]