Oh yes, I do believe it's way deliberate.

She just gets so mad that she throws that up to show to show whoever is testifying just what she thinks of them. And it's held until it's so obvious too
She also did it in April's hearings (if I remember right it was in answer to something said by the prosecutor) and Jose got a real kick out of it (then he stuck his tongue out at the camera!)
Kind of like Lindsay Lohan spelling out the F word on her fingernails during her trial then holding those up all innocently...wha? Oh I forgot I had that on them
But then again, what can you expect when her
attorney does the same thing to the prosecutor (during the April pre-trial session) as reported by WFTV legal analyst Bill Sheaffer:
Sheaffer even saw defense attorney Cheney Mason make a vulgar gesture toward the prosecutor with his arms.
"I've not seen anything like this in the 33, 35 years that I've been practicing law," Sheaffer said
(During that same hearing Defense attorney Cheney Mason even threatened prosecutor Jeff Ashton. After the two traded accusations of inappropriate behavior during the deposition, things got more heated and Mason threatened:
"Don't get out of line with me, because I will take you, and you know I will.")