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Combating Plaintiff Reptilian Tactics in Complex Litigation: Discovery, Voir Dire, Direct and Cross-Examination

Recording of a 90-minute CLE video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Tuesday, June 27, 2023

Recorded event now available

or call 1-800-926-7926

This CLE course will guide litigators on combating the trial strategy commonly known as the "reptile theory." The panel will educate counsel about identifying and responding to "reptile" tactics at every stage of a matter, from discovery through closing argument.


Plaintiff attorneys use "reptile theory" to get larger plaintiff verdicts by appealing to the primal region of jurors' brains focused on safety and self-preservation. "Reptile" tactics seek to subtly lead the jury to believe that the defendant put all of society in danger and that a plaintiff's verdict is the only way to keep the world safe for themselves and others.

Its proponents credit reptile theory for $6 billion-plus in jury verdicts, including a single $50 million verdict in a wrongful death case.

To be most effective, reptilian theory tactics are deployed during every phase of a case, including discovery, opening statement, direct- and cross-examination, and closing argument. Defense attorneys must spot when reptilian tactics are being used and develop strategies for nullifying them.

Listen as our authoritative panel of litigators shares how to defend against these tactics and create the best opportunity for success at trial.



  1. Reptilian tactics in litigation: how to spot them
  2. Defense strategies: from discovery through closing argument


The panel will review these and other key issues:

  • What is the underlying basis for "reptilian" theory trial tactics?
  • How are plaintiffs' attorneys leveraging reptile tactics to influence jurors?
  • How can defense attorneys counter plaintiffs' use of reptilian tactics?


Paul F. Devine
Paul F. Devine

Boggs Avellino Lach & Boggs

Mr. Devine has thirty years’ experience in various types of litigation, in a career that has focused on insurance...  |  Read More

Gurbach, Matthew
Matthew D. Gurbach

Bricker Graydon

Mr. Gurbach is a diversified trial attorney that represents individuals and corporations in complex business litigation...  |  Read More

Whitlock, Kathryn
Kathryn S. (Kate) Whitlock

McAngus Goudelock & Courie

Ms. Whitlock has spent her entire career defending and counseling individuals and insurance companies in professional...  |  Read More

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