The pro se plaintiff in Anderson v. Wade, 2008 U.S. Dist. LEXIS 28537 (W.D.N.C. March 27, 2008) evidently thought that brief-writing was supposed to consist of insult piled on insult. An example:

The defendant's lawyers initiated their reprehensible ploy to corrupt, subvert and grossly misrepresent the power court's ruling, taint and prejudice the appeal, take advantage of the pro se plaintiff, and further deny him justice and fundamental fairness. Defendant counsel prepared a deceitful, dishonest, proposed order which grossly misrepresented the trial judge's ruling. [Plaintiff's Memorandum of Law Doc.17 at 9].

The Court’s reaction: “Such ad hominem rhetoric has no place in a memorandum of law to this Court.” The remedy:

With the history of filings written in an abusive manner, and actions that can be construed as harassment by litigation, the Court believes it is appropriate to admonish the Plaintiff that he needs to be much more careful — and much more civil — as this matter continues. For this reason, the Court will allow the Plaintiff ten days from the entry of this Order to amend his pleadings in the remaining subsidiary case (3:07cv318) to bring them into conformity with proper practice. The Court would also strongly encourage Plaintiff to obtain counsel for the purpose of going forward with this litigation. Appearing pro se has not worked well for Plaintiff and has been to the disadvantage of all involved in this litigation, including the Court.