Don Maciejewski has published an article entitled "Dealing With Difficult Opposing Counsel – How to Tame "Rambo’" in the January / February 2012 edition of Litigation Commentary & Review.
Don includes 13 helpful hints on how to deal with jerks. As he correctly notes, "Rambo is probably well-skilled in lying and cheating and does not play by the rules."
There are lots of good suggestions in this article. Here is a sample:
(6) Do Not Get in the Gutter With Rambo
Lawyers are famous for writing poison pen letters. All too often, a lawyer will write a poison pen letter that is dripping with hate, only to later regret that he or she has put the words on paper, to be memorialized forever and for all to read. If Rambo sends you scathing letters, do not sent scathing letters in return. Rather, call Rambo, explain that you received the scathing letter and that you disagree with it and then memorialize your conversation in writing. Remember the old saying, “when you lie down with dogs, you get up with fleas”. The same saying may be applied if you get in the gutter with Rambo, because you will begin to identify with him and play his or her games. Do not fall for the trap.