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. Professionalism
6. Ethics - It's Legal, but is it Right?

1. IDENTIFYING THE "RAMBO" LITIGATOR
   9:00 - 9:50, Donald R. Dobbins
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?
   9:50 - 10:45, Donald R. Dobbins
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
   11:00 - 12:30, Christopher L. Whittington
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
   1:30 - 2:15, Yigal Bander
1. How to Respond
2. Staying in Control
3. It's About Your Client, Not About You
4. Your Reputation and the Big Picture
5. PROFESSIONALISM
   2:30 - 3:30, Yigal Bander
   1. What is "Professionalism" ?
   2. Professionalism and Ethics - What's the Difference?
   3. Codes of Professionalism
   4. Where Ethics and Professionalism Meet
   5. Dealing With Difficult Judges
6. ETHICS - IT'S LEGAL, BUT IS IT RIGHT?
   3:30 - 4:30, Yigal Bander
1. What is Ethics?
2. Some Common Misconceptions
3. Conflicts of Interest in Personal Injury Cases
4. Communications With Persons Represented by Counsel
5. Communications With Witnesses
6. Prosecutors and Criminal Defense Lawyers
7. Duties to Third Parties

YIGAL BANDER is an attorney with the Baton Rouge law firm of Manasseh, Gill, Knipe & Belanger, PLC, where he practices in the areas of personal injury, criminal defense and public school teachers' rights. Mr. Bander also writes and consults in the areas of ethics, liens and subrogation claims. He earned his B.A. degree from Hebrew University of Jerusalem, and his M.S.W. and J.D. degrees from Louisiana State University. Mr. Bander is admitted to practice in Louisiana; New York; Pennsylvania; the District of Columbia; the U.S. Supreme Court; the U.S. 5th Circuit; and the U.S. District Courts for the Eastern, Middle and Western Districts of Louisiana. He has been recognized by the ACLU as a "Defender of Civil Liberties."

DONALD R. DOBBINS is the founder of Donald R. Dobbins & Associates LLC, a law firm in Baton Rouge, where his practice is concentrated in the areas of criminal law, family law and civil practice. Mr. Dobbins has lectured for various CLE programs at Southern University Law Center. He earned his B.S. and J.D. degrees from Southern University. Mr. Dobbins is a member of the Louisiana State and American bar associations and the Louis A. Martinet Society.

CHRISTOPHER L. WHITTINGTON is an attorney with The Whittington Law Group, specializing in general civil litigation, personal injury and maritime law. Mr. Whittington received his J.D. degree in 1992 from Southern University Law Center and his B.S. degree in finance in 1987 from Louisiana Technical University. He is a member of the Louisiana Association for Justice Board of Governors; the American Association for Justice; and the American, Louisiana State, and Baton Rouge bar associations. He has also served on the Louisiana Court Reporters Board.

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