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 - 10:00, Larry W. Zukerman
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?
   10:15 - 11:30, Larry W. Zukerman
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
   11:30 - 12:15 and 1:15 - 2:00, Edward H. Blakemore
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
   2:00 - 3:15, Clifford C. Masch
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, Clifford C. Masch
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

EDWARD H. BLAKEMORE is senior corporate counsel with Eaton Corporation, where he manages litigation filed against the Fortune 500 company. Prior to joining Eaton Corporation, Mr. Blakemore's diverse practice included the defense of small to medium-sized businesses, corporations, insurers and individuals in all of the following areas of litigation: product liability, transportation litigation, catastrophic injury litigation, general liability, appellate litigation and professional liability. Mr. Blakemore has tried numerous cases to juries and the bench in several different Ohio jurisdictions. He is a member of the Cleveland Metropolitan Bar Association's Board of Trustees and its Certified Grievance Committee. He is also a member of the Board of Trustees for the Stephanie Tubbs Jones' Summer Legal Academy. Mr. Blakemore earned his B.A. degree from Morehouse College in Atlanta, Georgia and his J.D. degree from the University of Dayton School of Law in Dayton, Ohio.

CLIFFORD C. MASCH is a partner in the Cleveland law firm of Reminger Co., L.P.A., where he heads the firm's insurance coverage and appellate department. His practice areas include general tort practice, appellate practice, general liability and professional liability. He has previously lectured for National Business Institute on the admissibility of evidence and expert testimony. Mr. Masch earned his B.A. degree from Denison University and his J.D. degree from Cleveland-Marshall College of Law. He is a member of the Ohio State (Insurance Law Committee), Cleveland and Portage bar associations and the Defense Research Institute.

LARRY W. ZUKERMAN is a partner with the Cleveland law firm of Zukerman, Daiker & Lear, L.P.A., where his areas of practice include criminal defense, professional ethics, disciplinary proceedings and criminal law. He has more than 23 years of experience in professional ethics, grievance and disciplinary proceedings and has served on various committees for state and local bar associations. He earned his A.B. degree from Washington & Jefferson College and his J.D. degree from Case Western Reserve University. Mr. Zukerman is a member of the Cleveland, Cuyahoga County and Ohio State bar associations, the National Association of Criminal Defense Lawyers, Ohio Association of Criminal Defense Lawyers and Cuyahoga Criminal Defense Lawyers Association.

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