Litigation & Appeals

Skills

Live Online

Litigation Hardball: Dealing With Obstruction, Gamesmanship, and Dirty Tricks

Credits Available

Credit	Status	Total
Alaska CLE	Reciprocity	6 Total
Alabama CLE	Approved	6 Total
Arkansas CLE	Approved	6 Total
Arizona CLE	Approved	6 Total
California CLE	Approved	6 Total
Colorado CLE	Approved	7 Total
Connecticut CLE	Approved	6 Total
Delaware CLE	Approved	6 Total
Florida CLE	Approved	7 Total
Georgia CLE	Approved	6 Total
Hawaii CLE	Approved	6 Total
Iowa CLE	Approved	6 Total
Idaho CLE	Pending	6 Total
Illinois CLE	Approved	6 Total
Indiana CLE	Approved	6 Total
Kansas CLE	Approved	7 Total
Kentucky CLE	Approved	6 Total
Maine CLE	Approved	6 Total
Minnesota CLE	Approved	6 Total
Missouri CLE	Approved	7.2 Total
Northern Mariana Islands CLE	Approved	6 Total
Montana CLE	Approved	6 Total
North Carolina CLE	Approved	6 Total
Nebraska CLE	Approved	6 Total
New Hampshire CLE	Approved	6 Total
New Jersey CLE	Approved	7.2 Total
New Mexico CLE	Approved	6 Total
Nevada CLE	Approved	6 Total
New York CLE	Approved	7 Total
Ohio CLE	Approved	6 Total
Oklahoma CLE	Approved	7 Total
Oregon CLE	Approved	6 Total
Pennsylvania CLE	Approved	6 Total
Rhode Island CLE	Upon Request	7 Total
South Carolina CLE	Approved	6 Total
Tennessee CLE	Approved	6 Total
Texas CLE	Approved	6 Total
Utah CLE	Approved	6 Total
Virginia CLE	Approved	6 Total
Vermont CLE	Approved	6 Total
Washington CLE	Approved	6 Total
Wisconsin CLE	Pending	7 Total
West Virginia CLE	Approved	7.2 Total
Wyoming CLE	Upon Request	6 Total

Live Online

6 hours

Wed, Feb 17, 00:00 AM – 00:00 PM

With Hon. Jared C. Bennett from United States District Court for the District of Utah + 5 others

Wed, Feb 17, 00:00 AM – 00:00 PM

Product ID 103046

Register For Course

Course Includes

$429

Live Webinar Registration

OnDemand Recording

Course Book Download

OnDemand content will be available within 7 days of event date.

Overview

Counter Dirty Tactics in Motions, Discovery, Negotiations, and Trial

Have you ever faced opposing counsel who seems to channel the litigation spirit of Rambo or John Wick? From the overly zealous to the downright unscrupulous, win-at-all-costs litigators can turn routine disputes into unnecessary battles. Join our experienced faculty as they break down aggressive tactics throughout the litigation process and reveal practical strategies for responding without getting pulled into the fight. Learn how to counter discovery gamesmanship, deposition ploys, negotiation tricks, improper trial tactics, and other conduct that pushes legal, professional, and ethical boundaries. Stay calm, strategic, and firmly in control the next time you're up against a difficult adversary - register today!

Know where zealous advocacy ends and improper litigation conduct begins.
Get practical strategies for countering frivolous filings, abusive motion practice, and procedural gamesmanship.
Cut through discovery obstruction, document dumps, questionable privilege claims, and other attempts to hide the ball.
Learn how to control witness coaching, improper objections, and other deposition misconduct.
Recognize negotiation tactics designed to manipulate facts, manufacture urgency, or gain an unfair advantage.
Know how to respond when trial tactics cross the line with witnesses, jurors, evidence, or the court.
Explore how AI-generated cases, citations, and other fabricated material are creating new litigation misconduct risks.
Fight back effectively without becoming the "Rambo" lawyer yourself.

Abbreviated Agenda

Identifying the "Rambo" Litigator and Knowing Your Remedies
Pleadings, Motions, and Communications That Cross the Line
Dirty Discovery Tricks to Watch For
Deposition Ploys and Misconduct
Countering Dirty Tactics in Negotiations
Trial Tactics That Cross the Line
Ethics: It's Legal, but Is It Right?

Can't Attend Live?

Get the OnDemand Instead

Watch the recording of this event on your own schedule. We'll notify you when its ready.

Credit Details

Credits Available

Credit	Status	Total
Alaska CLE	Reciprocity	6 Total
Alabama CLE	Approved	6 Total
Arkansas CLE	Approved	6 Total
Arizona CLE	Approved	6 Total
California CLE	Approved	6 Total
Colorado CLE	Approved	7 Total
Connecticut CLE	Approved	6 Total
Delaware CLE	Approved	6 Total
Florida CLE	Approved	7 Total
Georgia CLE	Approved	6 Total
Hawaii CLE	Approved	6 Total
Iowa CLE	Approved	6 Total
Idaho CLE	Pending	6 Total
Illinois CLE	Approved	6 Total
Indiana CLE	Approved	6 Total
Kansas CLE	Approved	7 Total
Kentucky CLE	Approved	6 Total
Maine CLE	Approved	6 Total
Minnesota CLE	Approved	6 Total
Missouri CLE	Approved	7.2 Total
Northern Mariana Islands CLE	Approved	6 Total
Montana CLE	Approved	6 Total
North Carolina CLE	Approved	6 Total
Nebraska CLE	Approved	6 Total
New Hampshire CLE	Approved	6 Total
New Jersey CLE	Approved	7.2 Total
New Mexico CLE	Approved	6 Total
Nevada CLE	Approved	6 Total
New York CLE	Approved	7 Total
Ohio CLE	Approved	6 Total
Oklahoma CLE	Approved	7 Total
Oregon CLE	Approved	6 Total
Pennsylvania CLE	Approved	6 Total
Rhode Island CLE	Upon Request	7 Total
South Carolina CLE	Approved	6 Total
Tennessee CLE	Approved	6 Total
Texas CLE	Approved	6 Total
Utah CLE	Approved	6 Total
Virginia CLE	Approved	6 Total
Vermont CLE	Approved	6 Total
Washington CLE	Approved	6 Total
Wisconsin CLE	Pending	7 Total
West Virginia CLE	Approved	7.2 Total
Wyoming CLE	Upon Request	6 Total

Agenda

All times are shown in

Identifying the "Rambo" Litigator and Knowing Your Remedies
1. Who Is the "Rambo" Litigator?
2. Rambo vs. Zealous Advocate: Knowing Where the Line Is
3. Civility as a Hallmark of Professionalism
4. Practical Strategies for Dealing With Difficult Opposing Counsel
5. Know Your Procedural Options: Meet-and-Confer, Motions to Compel, Protective Orders, Sanctions, and Court Intervention
6. Documenting Bad Behavior and Questionable Tactics
Pleadings, Motions, and Communications That Cross the Line
1. Frivolous Filings and Vexatious Litigation
2. Strategic Vagueness, Baseless Claims, and Counterclaims
3. Forum Shopping and Other Procedural Gamesmanship
4. Motion Practice as a Weapon: Delay, Burden, and Unfair Advantage
5. Abusing Discovery Through Motion Practice
6. Misrepresenting, Misquoting, or AI-Fabricating Legal Authority
7. When Opposing Counsel Won't Communicate
8. The Paper War: Abusive Emails, Letters, and Excessive Communications
Dirty Discovery Tricks to Watch For
1. "Hiding the Ball": Getting the Discovery Your Client Is Entitled To
2. Overusing Privilege and Other Improper Withholding Tactics
3. Boilerplate and Frivolous Discovery Objections
4. The Document Dump: Buried Evidence and Discovery Overload
5. "Those Documents Don't Exist": Finding the Needle in the Haystack
6. Spoliation, Missing Evidence, and Evidence Tampering
7. Fabricated, AI-Generated, or Manipulated Evidence
Deposition Ploys and Misconduct
1. Expert Witness Gamesmanship
2. Getting the Right Rule 30(b)(6) Corporate Representative
3. Witness Coaching, Speaking Objections, and Improper Instructions Not to Answer
4. Remote Deposition Gamesmanship: Off-Camera Coaching, Messaging, and Unauthorized Materials
5. Controlling Bad Conduct: Video, Court Intervention, and Special Masters
6. Deposition Ambushes and Surprise Tactics
7. Mischaracterizing or Misusing Deposition Testimony
Countering Dirty Tactics in Negotiations
1. Misrepresenting Facts and Withholding Key Information
2. Empty Threats, Bluffs, and Manufactured Urgency
3. Bad-Faith Negotiations and Refusal to Engage
4. The "No Authority" Problem at Mediation
5. Bait-and-Switch Settlement Tactics
6. Settlement Agreement Traps: When the Deal Isn't What You Thought
Trial Tactics That Cross the Line
1. "Scorched Earth" Litigation: When Aggressive Advocacy Goes Too Far
2. Poisoning the Well: Improper Arguments and Prejudicial Tactics
3. Discrimination and Misconduct in Jury Selection
4. Improper Contact With Jurors and Other Jury Misconduct
5. Expert Testimony That Pushes Beyond Permissible Bounds
6. Witness Coaching, Intimidation, and Improper Influence
7. Evidentiary Gamesmanship and Attempts to Circumvent Prior Rulings
8. Violating Motions in Limine and Court Orders
9. Ex Parte Communications
10. Misrepresenting the Record, Evidence, or Law to the Court
11. When Misconduct Leads to Sanctions or Contempt
Ethics: It's Legal, but Is It Right?
1. The Ethical Rules Behind the Day's Litigation Battles
2. Candor to the Tribunal and Truthfulness to Others
3. Fairness to Opposing Parties and Counsel
4. Conflicts of Interest and Other Divided Loyalties
5. Zealous Advocacy vs. Professional and Ethical Obligations
6. Responding to Misconduct Without Becoming the "Rambo" Lawyer Yourself
7. When Must - or Should - You Report Another Lawyer's Conduct?
8. Sanctions, Discipline, and the Consequences of Crossing the Line

Who Should Attend

This program is designed for attorneys. Paralegals may also benefit.

Speakers

Hon. Jared C.

Bennett

United States District Court for the District of Utah

Nathalie C.

Hackett

Kelley Kronenberg

Namvar A.

Mokri

Mokri, Vanis & Jones, LLP

Blake

Milner

Singleton Schreiber

Yvonne M.

Flaherty

Lockridge Grindal Nauen PLLP

Louis R.

Cohan

Cohan Law Group, L.L.C.

Speaker bio

Namvar A. Mokri

Mokri, Vanis & Jones, LLP

Namvar Mokri

is a Co-Founder of Mokri, Vanis & Jones, LLP, with more than 25 years of litigation experience. His practice focuses on general liability, product liability, construction defect, real estate, and business litigation. He has extensive experience handling complex litigation and dispute-resolution matters and has led numerous high-exposure cases through trial and arbitration before juries, judges, arbitrators, and private mediators. Mr. Mokri represents a diverse range of clients, including insurance companies, developers, general contractors, design professionals, and institutional clients. His practice emphasizes developing creative, practical, and cost-effective strategies for complex legal disputes. Mr. Mokri's experience includes business and real estate transactions and litigation, construction litigation, insurance coverage and bad-faith matters, products liability, professional liability, catastrophic injury, and other complex disputes. He has particular experience with insurance coverage and risk-management issues and has worked extensively with clients to analyze coverage issues and develop strategies addressing complex insurance and litigation risks. Mr. Mokri also represents private and corporate clients in transactional matters, including the drafting and analysis of contracts and corporate documents. He is a member of the American Bar Association, Association of Southern California Defense Counsel, Los Angeles County Bar Association, and Orange County Bar Association. Mr. Mokri earned his J.D. degree from Western State University College of Law in 1995 and his B.A. degree from the University of Southern California in 1992. He is admitted to practice in California and before the U.S. District Courts for the Central and Southern Districts of California.

View full profile

Speaker bio

Blake Milner

Singleton Schreiber

Blake Milner

is Senior Counsel at Singleton Schreiber in Birmingham, Alabama, where he represents individuals and families in personal injury matters and handles whistleblower and False Claims Act litigation. He brings extensive courtroom experience from both civil and criminal practice, including complex federal prosecutions, investigations, and high-stakes litigation. Before joining Singleton Schreiber, Mr. Milner served as an Assistant United States Attorney for the Northern District of Alabama, where he led the Organized Crime Drug Enforcement Task Force. In that role, he managed complex federal prosecutions involving organized crime, money laundering, firearms, kidnapping, tax fraud, and large-scale drug conspiracies. He successfully tried jury cases involving drug trafficking, wire fraud, money laundering, and tax fraud and supervised other attorneys handling high-stakes federal litigation. Earlier in his career, Mr. Milner served as a Deputy District Attorney in Jefferson County, Alabama, where he prosecuted jury and bench trials involving violent crime, capital murder, robbery, rape, and domestic violence. He also has significant experience in white-collar criminal defense, investigations, False Claims Act matters, and complex qui tam litigation. Mr. Milner is also an experienced trial advocacy instructor and coach. Since 2017, he has coached the Cumberland School of Law National Trial Team, teaching law students trial skills, case theory, and courtroom strategy. He also serves as an adjunct professor teaching Jury Selection, Basic Skills in Trial Advocacy, and Alabama Practice and Procedure. His combination of federal prosecution, complex investigations, trial advocacy, and civil litigation experience provides a practical perspective for CLE programs addressing the changing litigation environment, including the application of emerging technologies and artificial intelligence to case preparation, investigation, discovery, evidence, and trial strategy. Mr. Milner earned his J.D. from Cumberland School of Law at Samford University in 2014, where he was a decorated trial advocate and recipient of numerous national trial-competition awards. He earned his B.S. from Mississippi College in 2011. He is admitted to practice in Alabama and before the U.S. District Courts for the Northern, Middle, and Southern districts of Alabama. Mr. Milner is a member of the Alabama Association for Justice, Alabama State Bar, Birmingham Bar Association, American Bar Association, American Association for Justice, Academy of Truck Accident Attorneys, and ALAJ Elite Academy. He was recognized in The Best Lawyers in America for Personal Injury Litigation – Plaintiffs in 2027.

View full profile

Speaker bio

Yvonne M. Flaherty

Lockridge Grindal Nauen PLLP

Yvonne Flaherty

is a Partner at Lockridge Grindal Nauen PLLP in Minneapolis, Minnesota, where she leads the firm's national personal injury and mass tort practice. She focuses her practice on complex pharmaceutical, medical-device, products-liability, and mass-tort litigation and has successfully represented more than 10,000 individuals throughout the United States who have been injured by defective products or the negligence of others. Ms. Flaherty has extensive experience in all phases of complex litigation, including discovery, trial, settlement, and the coordination of large-scale multidistrict and mass-action proceedings. She has served as Plaintiffs' Co-Lead Counsel in major consolidated litigations involving medical devices and has been appointed to plaintiffs' executive and steering committees in complex litigation throughout the United States. Her experience includes pharmaceutical, medical-device, toxic-substance, environmental, antitrust, and consumer litigation. Ms. Flaherty has also been involved in significant nationwide class actions and has served on trial teams in cases that proceeded to verdict. Her experience managing large numbers of individual claims, coordinating discovery, evaluating evidence, and developing litigation strategy provides a practical perspective on the use of technology and emerging tools in complex litigation. She has held numerous leadership positions within the American Association for Justice, including Past Chair of the National College of Advocacy Board, Past Co-Chair of the Electronic Discovery Committee, Past Chair of the Section on Toxic, Environmental, and Pharmaceutical Torts, and Past Chair of the Women's Trial Lawyer Caucus. She has also served for more than a decade on the AAJ Board of Governors and is active in Minnesota trial-lawyer organizations. Ms. Flaherty has been recognized as a Super Lawyer in Class Action/Mass Torts since 2011 and has been named among the Top 50 Women Minnesota Super Lawyers and Top 100 Minnesota Super Lawyers. She was named an Attorney of the Year in 2015 and was included in the 2026 edition of The Best Lawyers in America for Product Liability Litigation – Plaintiffs. Ms. Flaherty earned her J.D. from William Mitchell College of Law and her B.A. from St. Olaf College. She is admitted to practice in Minnesota, the U.S. District Court for the District of Minnesota, and the U.S. Court of Appeals for the Eighth Circuit.

View full profile

Loading recommendations...

TOP FAQs

How do I access my courses?

Courses are available within your account. Simply login to your account and click on My Courses. If you require additional assistance please call our Customer Service Department at 800-930-6182.

Do you have options for attendees who are deaf or hard of hearing?

Closed captioning is available for all Live Webinars. After you've joined the event room, you can enable closed captioning by clicking the "cc" button in the lower right of the player.

What happens if my course is cancelled?

In the unlikely event that NBI cancels or reschedules an upcoming program, each registered attendee will be contacted via email by a representative of NBI. Outreach to attendees begins as soon as NBI is made aware that a program will not move forward at its originally scheduled date and time.

Are multiple attendee discounts available?

Yes, the more people you bring from your organization, the more you save. After the first registration, each additional attendee receives a special discount off of their total tuition.

When will the OnDemand be available and how long will I have access to the content?

The OnDemand Video will be available to stream within 7 days of live broadcast date. You will have access to the content for 6 months in your account. If you’re a subscriber, you’ll have access to your course recordings until 7 days after the expiration date of the subscription.

What is included with my course purchase?

When you enroll prior to the live event date you will receive access to the live-streaming webinar which will allow you to interact with faculty in real-time. With each course, you will receive access to the content via OnDemand Streaming and the Video Download. Course reference materials are included with each course purchase in a downloadable PDF format.

Will I receive a certificate of completion?

Yes, we'll email you a certificate of completion and store in your account for any future reporting needs.

Can multiple people watch courses and request credit?

While only paid registrants can receive continuing education credit for attending, there are no limitations to the number of viewers at each connection.

Have more questions? Please Contact Us

Training That Works as Hard as You Do

Individual CLE Pass

Team Training Solutions

Litigation Hardball: Dealing With Obstruction, Gamesmanship, and Dirty Tricks

Credits Available

Wed, Feb 17, 00:00 AM – 00:00 PM

Wed, Feb 17, 00:00 AM – 00:00 PM

Register For Course

Add to Cart | $429

Get This Course

Section

Overview

Counter Dirty Tactics in Motions, Discovery, Negotiations, and Trial

Abbreviated Agenda

Can't Attend Live?

Get the OnDemand Instead

Pre-Order OnDemand | $429

Related Topics

Credit Details

Credits Available

Select Your State

Credit Details by Jurisdiction

Live Webinar Registration

OnDemand Video

Course Book (PDF Download)

Select Jurisdiction

Agenda

Identifying the "Rambo" Litigator and Knowing Your Remedies

Pleadings, Motions, and Communications That Cross the Line

Dirty Discovery Tricks to Watch For

Deposition Ploys and Misconduct

Countering Dirty Tactics in Negotiations

Trial Tactics That Cross the Line

Ethics: It's Legal, but Is It Right?

Who Should Attend

Speakers

Speaker bio

Hon. Jared C. Bennett

Speaker bio

Nathalie C. Hackett

Speaker bio

Namvar A. Mokri

Speaker bio

Blake Milner

Speaker bio

Yvonne M. Flaherty

Speaker bio

Louis R. Cohan

You may also be interested in

TOP FAQs

Get this Course

About

Products

Resources

Support

Institute for Paralegal Education

Added to Cart

Empty Cart Drawer

Go Unlimited

Course quick view

Quick Shop