Rule 46 of the court's procedural rules (pdf) states that "A chamber may, after a warning, impose sanctions against or refuse audience to a counsel if, in its opinion, his conduct remains offensive or abusive, obstructs the proceedings, or is otherwise contrary to the interests of justice".
He went on to challenge some of the "myths" and "stereotypes" made about victims of sex assault, noting that delayed reporting of a crime or the fact that a victim remains in an abusive relationship should have no bearing on the judge's decision.
Finally, there remains the possibility that abusive partners have used violence or the threat of violence to coerce these women into having abortions.
What resonates in Manhattan Night is the frank and (if I may use a buzzy word) problematic way Caroline remains attracted to Simon despite his abusive nature.
We also know that despite the incredible work of service providers across the country to provide safe options for victims leaving abusive relationships, domestic violence remains a pervasive and, at times, fatal issue impacting American women.
In theory, the church remains steadfastly committed to the removal of all abusive priests.
Her abusive boyfriend, the criminal mastermind Bill Sykes, remains discreetly off screen.
The number of women gamers is growing fast - in the US they now make up 42% of the total - but it remains a macho environment, where women are often exposed to abusive language.
But the broader problem remains — of immigrant workers afraid to "push the system" and challenge abusive employers and even federal agencies when their jobs, visas and futures are at stake.
"Despite the abusive Article 32 process," Ms. Burke said, "the victim is strong and remains willing to testify at trial".
