I think the E30 and E36 slave cylinders are similarly oriented, and with the bleeder in a dependent orientation, air can get stuck in the slave. Some bench bleed the slave, others just try to angle the slave so the bleeder is non-dependent, but if it's as tight under there as the E30 is, good luck.
(As an aside, it's also fun to get air in the clutch line while bleeding the brakes as the E30s use a shared reservoir. Conveniently the clutch line attaches to the reservoir on its side at a slightly higher point than the brake lines do, and if you're not careful air will get in the clutch. Yep, I suck.

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Steve Carter
1972 Datsun 240Z-- resto pics at
http://picasaweb.google.com/srcartermd2007 GPW Honda S2000-- STR 86