I've seen it done before too, but it wasn't a 38 if I remember correctly. If I'm thinking right, the plane I saw do it was a F4U believe it or not. Wish I knew how it was done, or how to watch for it.
I was fighting a guy about a week ago, who had figured out how to intentionally stall a Niki so that as you began to fire at him he would "flutter" down like a leaf out of your line of fire, and then before you could zoom past him, he would recover and be crawling up your ass. Watched him do it to a wingman from a distance (he pinged my wingie but had to brake off for my attack), and he did it too me twice. Thank goodness I had a great head of steam up each time, or he would have got me.