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 - 10:30, Written by Doris L. Sweetin. Presented by Christopher W. Johnson.
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?
   10:45 - 12:00, Written by Peggy K. Little. Presented by Thomas C. Higgins.
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
   1:00 - 2:15, Written by Douglas A. Crawford. Presented by Christopher W. Johnson.
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
   2:30 - 3:30, Written by Peggy K. Little. Presented by Michael A. Kreppein.
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, Written by Douglas A. Crawford. Presented by Michael A. Kreppein.
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

THOMAS C. HIGGINS is an attorney in private practice in Valparaiso, where his practice involves defending clients in civil actions. He has worked for three major insurance carriers in Chicago and Northwest Indiana as in-house counsel. Mr. Higgins has defended Fortune 500 clients and has conducted many first chair jury trials, arbitrations and mediations in Illinois and Indiana. Additionally, he has served as judge pro tem in Lake County, Indiana. Mr. Higgins earned his J.D. degree from John Marshall Law School in Chicago.

CHRISTOPHER W. JOHNSON is a claims litigation attorney for the State Farm Insurance Company in Merrillville, Indiana, where his duties include the defense of personal injury lawsuits. He received his B.A. degree, with high honors, in political science/psychology from DePaul University and his J.D. degree from the DePaul College of Law, DePaul University. Mr. Johnson is a member of the Indiana State Bar Association and the Lake County Bar Association.

MICHAEL A. KREPPEIN is a partner in the Michigan City firm of Huelat Mack & Kreppein, P.C. Mr. Kreppein practices in insurance defense, insurance coverage, products liability, personal injury and civil litigation. He earned his B.A. degree from the University of Illinois at Chicago and his J.D. degree from Valparaiso University School of Law, where he was president of the Student Association of Trial Lawyers of America's Mock Trial Team. Mr. Kreppein is a member of the Defense Trial Counsel of Indiana, the LaPorte County Bar Association and the Indiana State Bar Association, for which he served as a district representative for its Young Lawyers Section from 2005 to 2008. He is admitted to practice in Indiana, and before the U.S. District Court for the Northern and Southern districts of Indiana and the U.S. Court of Appeals 7th Circuit.

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