Just a little addition to my last reply.
If it were the case of, say, Obozo, ‘Nasty’ would probably be the tactic that we would try all the time, mostly because he would never be anything except towards us. To be ‘Nasty’ would be the correct move there because he’d never be anything different, and to be Nice would just be to get taken advantage of.
So when I say ‘Nasty,’ I don’t mean ‘bad,’ just non-cooperative.
When dealing with lawyers sometimes you need to step on their toes to get their respect.