IN THE FIRST PHASE OF A NATIONAL STUDY OF PLEA-BARGAINING BLUFFING WAS ONE OF MANY ISSUES DISCUSSED IN OPEN-ENDED, UNSTRUCTURED INTERVIEWS WITH PROSECUTORS IN 31 JURISDICTIONS, 20 OF WHICH REPRESENTED A 10-PERCENT RANDOM SAMPLE OF AMERICAN JURISDICTIONS WITH POPULATIONS OF 100,000 OR MORE. IN THE SECOND PHASE, BLUFFING WAS DEALT WITH IN STRUCTURED INTERVIEWS CONDUCTED IN SIX JURISDICTIONS STUDIED INDEPTH; THESE JURISDICTIONS WERE SELECTED TO REPRESENT A CONTINUUM FROM CENTRALIZED TO DECENTRALIZED CONTROL IN THE PROSECUTOR'S OFFICE. THESE INTERVIEWS ALL DEMONSTRATED THAT BLUFFING DOES NOT TYPICALLY INVOLVE VIOLATIONS OF LEGAL OR ETHICAL NORMS, ELABORATE FRAUDS TO SUSTAIN DECEPTIONS, OR CASES IN WHICH NO CHANCE EXISTED THAT THE DEFENDANT WOULD BE CONVICTED AT TRIAL. PROSECUTORS ABIDE BY THE LAW RELATING TO DISCOVERY AND THE PRODUCTION OF EXCULPATORY EVIDENCE, BUT FEEL NO OBLIGATION TO TELL DEFENSE COUNSEL ABOUT WEAKNESSES IN THEIR CASES THAT ARISE FROM LOGISTICAL OR ADMINISTRATIVE PROBLEMS, SUCH AS THE ACCIDENTAL LOSS OF DRUGS OR THE FAILURE TO NOTIFY A WITNESS OF A HEARING. PROSECUTORS ARE RESTRAINED IN THEIR BLUFFING NOT ONLY BY LAW AND CODES OF ETHICS BUT ALSO BY THE UNOFFICIAL NORMS OF THE WORK PLACE; LAWYERS MUST PROTECT THEIR REPUTATIONS FOR HONESTY IN NEGOTIATIONS IF THEY ARE TO MAINTAIN SMOOTH RELATIONS WITH OTHER LAWYERS. OVERALL, THE BLUFFING SYSTEM DOES NOT WARRANT THE ABOLITION OF PLEA-BARGAINING, BUT IT DOES CALL FOR A COMPETENT AND WARY DEFENSE BAR. DEFENSE ATTORNEYS MUST CHECK THE STRENGTH OF THE PROSECUTOR'S CASE BY ASKING SIMPLE AND DIRECT QUESTIONS ABOUT WHETHER THE PROSECUTOR IS READY TO GO TO TRIAL. REFERENCES AND TABLES SHOWING INTERVIEW RESPONSES ARE INCLUDED. (MHP)