In Skripek v. Skripek (NYLJ, 3/27/96 [Sup. Ct. Westchester Co. 1996]), the Court ordered the defendant, an attorney appearing pro se in a divorce action, to appear and begin serving a period of incarceration unless he purged a civil contempt adjudication by the appearance date. The defendant failed to appear as required, contending in correspondence he sent to this Court that his filing of a bankruptcy petition had triggered an automatic stay of the civil contempt proceeding. Upon this Court's conclusion that no stay had been obtained, it issued a warrant for the defendant's arrest. Following his subsequent surrender on the warrant, the Court directed him to show cause why he should not be held in criminal contempt for failing to appear when directed. After conducting a contempt hearing, the court found the defendant guilty of criminal contempt and sentenced him to 30 days in jail. The comtempt adjudication and sentence were unanimously affirmed by the Appellate Division ( Skripek v. Skripek, 239 A.D.2d 488, 658 N.Y.S.2d 62 [2d Dept. 1997].)