You've probably either tried a case against a "Rambo" litigator - or you've heard stories from your colleagues about this hardball approach to practicing law, and, as you know, it's no picnic. This instruction is designed to teach you how to deal with frustrating and all-too-common litigation techniques. If you deal with "Rambos" with any regularity, this is a must have!

1. Identifying the "Rambo" Litigator
2. Hidden Agendas - Why Does "Rambo" Exist?
3. Dirty Tactics That You Need to Look Out For
4. Using Effective Remedies to Combat Rambo Litigation
5. Ethics - It's Legal, but is it Right?

1. IDENTIFYING THE "RAMBO" LITIGATOR
   9:00 - 10:15, William L. Berry
1. Who is This "Rambo?"
2. Civility: The Hallmark of Professionalism
3. Knowing What You are up Against: 13 Helpful Hints on How to Deal With Difficult Opposing Counsel
4. Win Battles by Knowing the Rules of Procedure
5. Documenting Bad Behavior and Dirty Tactics
2. HIDDEN AGENDAS: WHY DOES "RAMBO" EXIST?
   10:30 - 11:45, William L. Berry
1. Climbing the Ladder
2. Beware of "Little Big Man"
3. Bad Facts = Bad Case
4. Overcompensating
5. Preparation, Knowledge and Experience
3. DIRTY TRICKS THAT YOU NEED TO LOOK OUT FOR
   12:45 - 2:00, James R. Garrison
1. "Hiding the Ball:" Make Sure You Get Documents and Discovery That You are Entitled To
2. How to Deal With Frivolous Objections to Discovery
3. Improper Behavior of Counsel at Depositions: Coaching the Witness and Instructing a Witness Not to Answer a Question
4. Dealing With the "Rambo" Lawyer Who Will Not Communicate
5. The Paper War and the Poison Pen
6. Prescriptions for Controlling Bad Conduct: Videotaped Depositions and Providing for Special Masters/Judges at Depositions
7. "Scorched Earth" Litigation Tactics: Winning at All Costs
8. "The Documents Don't Exist:" The Needle in the Haystack
9. Hiding Discovery That is Relevant to the Case
10. Dealing With "Paid for Hire" Expert Witnesses
11. How to Ensure That Your Opponent Designates the Proper 30(B)(6) Corporate Designee Witnesses
12. Using Motions to Compel Effectively
4. USING EFFECTIVE REMEDIES TO COMBAT "RAMBO" LITIGATION
   2:15 - 3:30, Mark Peebles
1. Sanctions
2. Motions to Strike Pleadings
3. Rules Governing Professional Conduct
4. Telling it to the Judge
5. Your Reputation and the Big Picture
6. Why Playing by the Rules is the Only Way to Practice
7. Weeding Out the "Rambos:" Cleaning the Slate
5. ETHICS - IT'S LEGAL, BUT IS IT RIGHT?
   3:30 - 4:30, Untress L. Quinn
1. State Bar Code of Ethics and Ethics Code of Various Specialties
2. Real and Potential Conflicts of Interest
3. Vigorous Representation or Questionable Practices

WILLIAM L. BERRY is the principal member of William Berry & Associates, LLC, with it's principal office in Collinsville, Illinois. The practice of his current firm encompasses litigation, including workers' compensation, automobile liability, product liability, and insurance coverage issues, as well as a wide range of general practice issues, including probate planning and estate administration. Mr. Berry commenced his practice as an associate with the firm of Oehmke, Dunham, Boman & Leskera, having clerked with that firm commencing in 1972. He joined the successor firm of Dunham, Boman & Leskera, as a partner, in 1982. Mr. Berry remained associated with that firm until July 1, 2008, at which time the principal practice of that firm was terminated. He has been recognized as a member of the Leading Lawyers Network for his expertise in product liability, automobile litigation and personal injury litigation. Mr. Berry has been a frequent lecturer for National Business Institute since 1992, writing and lecturing referable to probate practice and estate administration, as well as litigation issues. He also has lectured for the ICLE, most recently referable to insurance coverage issues. In October 2011, Mr. Berry was appointed the chairman of Illinois Racing Board. He earned his undergraduate degree from Millkin University and his J.D. degree from Washington University Law School.

JAMES R. GARRISON is an attorney with the law firm of Boyle Brasher LLC, with more than 25 years of experience. His practice areas include, but are not are limited to, civil practice, personal injury, insurance defense, products liability, class actions, and health care. Mr. Garrison earned his B.S. degree from the University of Illinois and his J.D. degree from the University of Illinois College of Law. He is a member of the St. Clair County and Illinois State bar associations, and The Missouri Bar.

MARK PEEBLES is the owner of Peebles & Associates LLC, a firm specializing in civil litigation, municipal law, Social Security disability and criminal defense. Mr. Peebles earned his B.A. degree from Brown University, his M.F.A. from Washington University, and his J.D. degree from St. Louis University.

UNTRESS L. QUINN is an attorney with Hinshaw & Culbertson LLP in Belleville, Illinois, where he is involved with all aspects of trial work. Mr. Quinn's practice includes general liability, personal injury, commercial, municipal and professional liability, medical malpractice litigation, and police liability litigation. He also is a registered nurse with more than ten years of extensive experience in both medical and surgical settings. Mr. Quinn earned his B.S. degree from National-Louis University, his B.S.N. degree from Lutheran Medical Center School of Nursing and his J.D. degree from Saint Louis University School of Law. He is a member of the St. Clair County, Illinois State, American, and National bar associations.

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