For years on the old PS1 games and even the first few PS2 version of Pro Evo, it was Nuno Gomes. I swear he would dive in the area, get penalties, or just score from open play. Even foul players on a corner, the score and the goal count.
Claudio Lopez was close to being the first player to get 30 goals for me on Pro, and with 5 games to go Pancaro injured him, leaving him stuck on 29 for the rest of the season (He went on to get 50 next season! good times)
This time around, there has not been one player who has constantly been a pain. There are occasional good performances from a Puyol, or a unknown CB, bu then the next time i play them, i tend to exploit them.