Can you show me how to do a sheep?

Here’s a question for those of you with a bit more experience than I have with game content creation applications such as 3ds Max or Gmax.

One of my buddies did some game scenery with sheep. They are just 2D shapes with sheep images mapped onto them, but here’s the thing he won’t let on about: they are always perpendicular to the viewpoint/virtual camera.

Clearly it makes sense to keep the plane of the sheep shape at 90 degrees to the line-of-sight so that it can be seen, but how is this done in 3ds Max?

SWABS.