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, Ronald L. Hicks Jr.
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, Alexander J. Jamiolkowski
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 - 1:45, Ronald L. Hicks Jr.
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
   1:45 - 3:15, Alexander J. Jamiolkowski
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, Ronald L. Hicks Jr.
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

RONALD L. HICKS JR. is a partner of the Pittsburgh firm of Meyer Unkovic & Scott LLP. He has been a member of the firm's litigation section since his start with the firm in 1987. He is a seasoned trial lawyer whose practice focuses on complex business litigation matters, with an emphasis on business and commercial disputes; trade secrets; business protection litigation; banking litigation; bankruptcy and creditors' rights litigation; fraud and fiduciary liability litigation; fraudulent transfer; asset recovery litigation; insurance coverage litigation; mechanics' lien and construction litigation; real estate; oil and gas litigation; and telemarketing and on-line marketing compliance. He is the partner in charge of paralegals and serves as chair of the firm's technology committee and co-chair of the Litigation Section of Meritas, an association of select independent law firms in principal cities worldwide. Mr. Hicks earned his B.A. degree, with distinction, from Pennsylvania State University; and his J.D. degree from Wake Forest University School of Law. He is a member of the Allegheny County, Pennsylvania and American bar associations.

ALEXANDER J. JAMIOLKOWSKI is a partner in the Pittsburgh law firm of Egan & Jamiolkowski. His practice is concentrated in the areas of plaintiff's personal injury, products liability, and commercial and insurance litigation. Mr. Jamiolkowski has lectured to various professional groups on topics relating to his practice of law. He has litigated cases in both state and federal trial courts throughout Pennsylvania, and in the appellate courts of the Commonwealth of Pennsylvania, as well as the U.S. Court of Appeals for the third circuit. Mr. Jamiolkowski is a member of the Allegheny County Bar Association. He earned his B.A. degree from the University of Scranton, and his J.D. degree from Duquesne University.

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