As noted here previously, Judge Posner does not take poor briefing lightly. This time his critique is supported by visual aids!  

Writing for the Seventh Circuit in Gonzalez-Servin v. Ford Motor Company, issued on November 23, Posner critcizes appellants in the consolidated cases for failing to properly address dispositive authority.  Posner writes:  “The ostrich is a noble animal, but not a proper model for an appellate advocate.”  To underscore the point, he includes both an image of an ostrich and one of a suited man—both with heads buried in the sand.

Any idea how to cite a photograph in a judicial opinion?  Ostrich, slip op. at 5??