Moreover, this Court has generally held that counsel's failure to provide information to a judge implicates the lawful process of the court. See Appeal of J. Shane Creamer, 529 A.2d 27 (Pa. Super. 1987). For these reasons, we conclude that a finding of contempt based on Appellant's failure to either withdraw her appearance or appear in court at the November 18, 2014 short list conference falls within the purview of ยง 4132(2).
Moreover, this Court has generally held that the failure to provide information to the court relates to the lawful process of the court. See Appeal of J. Shane Creamer, 365 Pa. Super. 170, 529 A.2d 27 (Pa.Super. 1987). Therefore, we conclude that a finding of contempt based on the quality of the briefs submitted by Attorney Tunnell falls within the purview of Subsection 4132(2).
Although there is conflicting case law, recent Pennsylvania cases have mandated that subsection (1) is inapplicable to the conduct of attorneys at trial. Matter of Creamer, 365 Pa. Super. 170, 529 A.2d 27 (1987); Matter of Campolongo, 495 Pa. 627, 435 A.2d 581 (1981). In furtherance, these recent cases have also stated that the proper avenue for addressing the conduct of attorneys at trial is subsection (3).