For teaching purposes, I'm putting together an extensive list of bad faith (or at least dubious) things that lawyers do, often routinely. If anyone has thoughts, please chime in. I am NOT looking for war stories. Some examples I've thought of are....

- evasive interrogatory answers

- excessive witness lists

- disorganized discovery responses

- failure to specify damages being sought (despite being asked a billion times)

- objecting to everything

- poison pen letters

- uncooperative scheduling

- making any statement that starts with "I've been doing this for ____ years, and...."

- fake legal or record cites

- failure to show up at settlement conferences with any authority

- making decisions they have not discussed with their client

- inflating attorney fees

- being rude to opposing counsel staff

- being rude to court staff (you'd think this would *never* happen, but I've seen it often)

- last-minute cancellations (depositions, private conferences, etc.)

- blaming their co-counsel, staff or anybody else but themselves for a screw-up

- excessive speaking objections

- misrepresenting counsel conduct in case (misrepresenting anything really, but especially this)

- padding complaints with ridiculous allegations/claims

- unwilling to stipulate to *anything*

- *suddenly* getting sick before a key date

- repeated failure to return phone calls

- expecting instantaneous responses from opposing counsel

- routinely insulting opposing client and/or witnesses

- showing up unprepared for depos and hearings and wasting everyone's time

- not providing copies of exhibits during depositions

- threatening to go to judge on minor disputes

- involving the press or social media in mundane cases

- demanding e-discovery when they don't know even the difference between PDF and DOC files (and you can forget about metadata).