What is the test for providing 48 hours notice of a criminal contempt hearing?

9 See In re Timmons, 607 F.2d 120, 125 (5th Cir.1979) ("We are not prepared to hold either that discretion was abused by allowing only 48 hours to prepare for trial of the criminal contempt charge or that, even if it was any prejudice was suffered thereby."); United States v. Robinson, 449 F.2d 925, 931 (9th Cir.1971) (24-hour notice of a criminal contempt hearing was found to be adequate where it was really a renewal of a prior motion, same counsel had represented defendants throughout proceedings, and there was no real doubt on anyone's part as to the scope of the inquiry.)