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, Paul D'Amato
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, David Azotea
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, L. Patricia Sampoli
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, David Azotea
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, L. Patricia Sampoli
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

DAVID AZOTEA is an associate with Levine, Staller, Sklar, Chan, Brown & Donnelly, P.A., where his practice focuses on the areas of commercial litigation, employment litigation, construction litigation, and estate and trust litigation. In the area of commercial litigation, he has represented both plaintiffs and defendants. Mr. Azotea is a member of the Atlantic County and New Jersey State bar associations, as well as The Florida Bar. He earned his B.A. degree from Ursinus College and his J.D. degree from Florida Coastal School of Law.

PAUL D'AMATO is a sole practitioner in Egg Harbor Township where he devotes his practice solely to litigation. He is certified as a Civil Trial Attorney by the Supreme Court of New Jersey. Mr. D'Amato is a frequent lecturer for the New Jersey Association for Justice and the New Jersey Institute of Continuing Legal Education. He was the 2006 recipient of the Professional Lawyer of the Year Award, presented by the Commission on Professionalism in the Law of the New Jersey State Bar Association and the Atlantic County Bar Association. Mr. D'Amato is a member of the New Jersey State, Atlantic County, and American bar associations; the American Association for Justice; the New Jersey Supreme Court (former member, District Ethics Committee); the New Jersey Association for Justice; and the American College of Trial Lawyers. He also is a founder of the Vincent Haneman American Inns of Court. Mr. D'Amato earned his B.S. degree from Mt. Saint Mary's College and his J.D. degree from Georgetown University Law Center.

L. PATRICIA SAMPOLI is a shareholder in the law office of Youngblood, Corcoran, Lafferty & Hyberg P.A., in Linwood, New Jersey. Ms. Sampoli is admitted to practice in the state of New Jersey and U.S. District Court for the District of New Jersey. Her areas of practice include insurance defense, automobile negligence, premises liability and tort claims. Ms. Sampoli earned her B.A. degree, cum laude, from Glassboro State University, her M.S. degree from Drexel University, and her J.D. degree from Rutgers University. She was a graduate teaching assistant at Bowling Green State University in Ohio. Ms. Sampoli taught school for 17 years. She is a member of the Atlantic County (president elect), New Jersey State and American bar associations, and the Vincent S. Haneman Inns of Court (secretary). Ms. Sampoli is a certified civil trial attorney by the New Jersey Supreme Court.

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