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The Litigation Consulting Report

Top 10 Litigation & Persuasion Articles from Q3 2015

Posted by Ken Lopez on Fri, Oct 23, 2015 @ 10:50 AM

top 10 litigation persuasion articles a2l consulting q3 2015by Ken Lopez
A2L Consulting

In a recent post, I discussed why we blog here at A2L, and I pointed to the very positive side effects of blogging in terms of revenue growth. Today, I'm returning to one of my favorite things -- highlighting the most popular articles of the previous quarter. In this case, it was the third quarter of 2015.

I think that many of our 7,500 subscribers can't read all of the articles that we post. It can be two or three a week, the equivalent of about 10 every month. But our readers don’t want to miss the very best ones either.

These 10 articles below were, in effect, voted the very best by our readership in the third quarter. It’s simple: A visit to the article is a vote, as we keep track of exactly how many visits each article receives. We do this to continually get a better sense of what our readers want to read. Some of our articles may only be read a couple of hundred times while others may be read tens of thousands of times.

Last quarter, two series dominated our top 10 articles. The first is by our Managing Director of Litigation Consulting, Ryan Flax. It’s a four-part series and webinar titled Winning Before Trial. It is focused on persuasion strategies that an attorney can use successfully, even before going to trial. Ryan's articles are especially popular among litigators, as Ryan is himself a litigator and expert in storytelling and the development of persuasive litigation graphics.

The second series is one that I wrote called Repelling the Reptile Trial Strategy as Defense Counsel. I was prompted to write this series after speaking to a group of defense counsel about the “reptile” tactic, a plaintiff-focused trial tactic that is working its way into the kind of cases we typically work on. I was happy to see this series become so popular as I feel it is very important for all lawyers to understand this tactic.

Below are the top 10 articles. Each has been formatted for easy reading, liking and sharing.

10. Social Proof and Jurors

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9. Winning BEFORE Trial - Part 2 - Parallel Trial Preparation Tactics

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8. Winning BEFORE Trial - Part 1 - Consider Litigation Costs and Opportunities

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7. The Best Litigators Love Sales, Love Storytelling and Persuasion

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6. Winning BEFORE Trial - Part 4 - Don't Overlook Visual Persuasion

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5. Winning BEFORE Trial - Part 3 - Storytelling for Lawyers

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4. How Much Text on a PowerPoint Slide is Too Much?

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3. Repelling the Reptile Trial Strategy as Defense Counsel - Part 4 - 7 Reasons the Tactic Still Works

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2. Repelling the Reptile Trial Strategy as Defense Counsel - Part 3 - Understanding the Bad Science

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1. Repelling the Reptile Trial Strategy as Defense Counsel - Part 5 - 12 Ways to Kill the Reptile

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a2l consulting top 75 articles of all time


Tags: Trial Graphics, Litigation Graphics, Litigation Consulting, Demonstrative Evidence, Articles, Storytelling, PowerPoint, Opening, Reptile Trial Strategy

Free Top-75 Articles E-Book! Help Us Celebrate 7,500 Subscribers!

Posted by Ken Lopez on Tue, Sep 8, 2015 @ 08:30 AM

by Ken Lopez
A2L Consulting

Welcome back from summer (to most), and welcome to the busy fall/winter litigation season.

This blog, The Litigation Consulting Report, is now just about 4 ½ years old. In that time, we have written nearly 500 posts on dozens of trial and presentation-related subjects, including everything from TED talks to Reptile trial techniques to voir dire best-practices.

We've earned accolades, won awards, won countless trials, and we have steadily grown our number of subscribers year after year, and I'm especially thrilled to say that we've just signed up our 7,500th blog subscriber! Every subscription is free, and perhaps that is part of the reason it took us less than a year to grow our community from 5,000 subscribers in September 2014 to 7,500 subscribers in September 2015 — a 50% increase.

To celebrate reaching 7,500 blog subscribers, today we’re publishing (as a free download) this collection of our very best articles to date called, A2L Consulting's Top 75 Articles of All Time. By "very best," I mean that our readers have, by choosing which articles they read most, told us which articles they think are the best. On the Web, your clicks are your votes. We’re thrilled to receive this feedback from you.Many of these articles are geared toward lawyers going to trial, while others are more generally focused on how to give a great speech or presentation. For lawyers and others in the legal industry, we generally write about litigation consulting, litigation graphics, trial strategy and trial technology. For those outside the legal arena, we write about visual persuasion, delivering a great speech and how best to prepare for a PowerPoint presentation.

Some of these articles have been read more than 30,000 times, and we credit this readership with having helped The Litigation Consulting Report be named one of the top 100 blogs in the legal industry and one of the top 10 litigation blogs by the American Bar Association. As a result, our A2L's blog reader demographics isarefascinating, and we continue to make improvements to our blog each and every month. 

I hope that you enjoy these articles. There’s really nothing else like them, and we look forward surpassing 10,000 subscribers soon. Click here or on the images below to download your Top 75 A2L Consulting Articles of All Time Free E-Book!

a2l consulting top 75 articles of all time

Tags: Trial Technicians, Litigation Graphics, Trial Presentation, Jury Consulting, Litigation Consulting, E-Book, Trial Technology, Litigation Support, Jury Consultants, Trial Preparation, Voir Dire, Reptile Trial Strategy

Repelling the Reptile Trial Strategy as Defense Counsel - Part 5 - 12 Ways to Kill the Reptile

Posted by Ken Lopez on Tue, Aug 4, 2015 @ 01:40 PM


reptile-trial-strategy-defense-win-beat-overcome-jury-consultantsby Ken Lopez
A2L Consulting

This is the fifth and final installment in a series of articles focused on how defense counsel can overcome the increasingly popular Reptile trial strategy. In parts one through four, I offered an introduction to the strategy, I shared ten ways to recognize when the strategy is being used against you, I explained why the strategy does not actually work in the way that its authors describe, and I explained that despite the bad science, the Reptile trial strategy still works.

In this post, I summarize how to overcome the strategy in both the pretrial and trial phases of a case. I rely heavily on the work of Jill Bechtold of Marks Gray and Steve Quattlebaum of Quattlebaum, Grooms & Tull. They were my co-presenters at a recent defense attorney-focused conference devoted to repelling the Reptile strategy.

One theme that clearly emerges from the 12 points below is that being a good defense lawyer is more important than ever. No longer is it enough simply to outlast your opponent. No longer is it enough to come up with a great theme and narrative just before trial. Because the Reptile strategy often begins with the complaint, a defense against it must start shortly thereafter -- or you will pay the price later.

  1. Spot the Reptile: It can appear as late as closing arguments, but more often than not, plaintiffs counsel will introduce the key themes as early as the complaint. See, 10 Ways to Spot the Reptile in Action.

  2. Read the Book: I hate to say this, but you probably should read it. It is Reptile: The 2009 Manual of the Plaintiff’s Revolution by David Ball and Don Keenan.

  3. Spot your Opponent on the Reptile Hall of Famehttp://www.reptilekeenanball.com/reptile-allstars/ Plaintiffs counsel with a record of suggest using the Reptile strategy are listed here. Is one your opponent?

  4. Storytelling Will Prevail: As you go through your case intake process, begin looking for the elements and start developing your own narrative. If you build the right narrative, you stand a higher chance of winning your case at trial. See, The Litigator's Guide to Storytelling for Persuasion 

  5. Understand Your Opponent's Narrative: Plaintiffs lawyers are often successful because they focus on narrative from the very beginning. You need to uncover that narrative and be ready to replace it with your own.

  6. Articulate Your Narrative from Day One. The sooner you build your own narrative, the better off you will be. Developing a narrative long before trial allows for testing of that narrative and it allows for it to be used throughout the discovery process. Keeping it a secret until trial is not a great tactic and is often an excuse for procrastination. See 25 Things In-House Counsel Should Insist Outside Litigation Counsel Do

  7. Prepare Your Witnesses: They will be badgered. Teach them how not to give in and to think of each answer they give as a potential video clip. Give them standard phrases that will play well – such as: I don't understand, it depends, or I don't have enough information. Use witness preparation techniques and consider outsourcing witness preparation to firms that understand the Reptile theory. See Witness Preparation: Hit or Myth?

  8. Use Motions in Limine to keep out evidence that is irrelevant and inflammatory. Also, use pre-trial motions to introduce and undermine the Reptile strategy.

  9. Object at Depositions: Use objections based on form, relevance, lack of foundation, mischaracterization of law, or seeking legal conclusions. Don't rely on standing objections as this will not be effective in fending off damaging testimony, nor do they help minimize the impact of video testimony.

  10. Help your Client Understand the Reptile Trial Strategy: Your client should understand the nature of the actual duties that are owed to the plaintiff and should be able to distinguish between those and the made-up community standards that are characteristic of the Reptile trial strategy. See The Top 14 Testimony Tips for Litigators and Expert Witnesses

  11. Test Plaintiffs’ Case in a Mock Trial, Using Reptile Techniques. See 12 Astute Tips for Meaningful Mock Trials

  12. Watch for Golden Rule Violations at Trial. The Reptile strategy gets close to crossing this line, and a less sophisticated plaintiffs lawyer may very well cross it --potentially resulting in a new trial.

Using these and other techniques, I am confident that a well-prepared defense attorney will be able to defeat the Reptile theory.

Other articles and resources related to Reptile trial strategy, jury persuasion and jury consulting from A2L Consulting:

pretrial trial graphics motions briefs hearings




Tags: Jury Consulting, Mock Trial, Trial Consulting, Jury Consultants, Storytelling, Expert Witness, Depositions, Witness Preparation, Reptile Trial Strategy

Repelling the Reptile Trial Strategy as Defense Counsel - Part 4 - 7 Reasons the Tactic Still Works

Posted by Ken Lopez on Mon, Jul 13, 2015 @ 04:14 PM


repitile-litigation-tactics-strategyby Ken Lopez
A2L Consulting

In my previous three posts concerning the “Reptile” trial strategy, I provided an introduction to the strategy, I discussed how to spot it, and I discussed why the science that its authors claim supports the strategy is just plain wrong.

As I have mentioned in previous articles, this trial strategy has been largely absent from the types of cases that we work on at A2L. However, with high-stakes pattern litigation on the rise, and with the increase in sophistication on the plaintiffs side in big-ticket litigation, the “Reptile” is something that medium and large law firm defense firms must be able to spot and to cope with.

In this article, I will focus on the critical fact that, despite the bad science that its authors employ, the Reptile trial strategy still works. In other words, the “Reptile” advocates are tapping into authentic ways of persuading jurors. There are at least seven reasons for that.

  1. The “Reptile” advocates suggest using a strong theme that is constantly reinforced throughout the case from complaint to closing. That's just good lawyering, and a majority of lawyers still don't do this. See 14 Differences Between a Theme and a Story in Litigation.

  2. Similarly, they encourage focusing on a consistent strategy from the very beginning of the case. Few defense counsel do this throughout a case, and again, following this practice is just good lawyering. See Planning For Courtroom Persuasion? Use a Two-Track Trial Strategy.

  3. They encourage the use of narrative as a persuasion strategy. We've written about that many times, and they are right to encourage it, because it works very effectively. Our proposed narratives are based on real psychological science and theirs are not, but the use of narrative is a very good idea. See $300 Million of Litigation Consulting and Storytelling Validation.

  4. Plaintiffs are going to score some hits in video depositions because the strategy is just so relentless. The authors advocate a fanatical pursuit of admissions from the defendants. If one doesn’t know how to stop the badgering, it is easy to slip in a deposition, and it sometimes only takes one slip to win a case. See The Top 14 Testimony Tips for Litigators and Expert Witnesses.

  5. By redirecting the focus away from the plaintiff and on the defendants and the injury they might have caused, plaintiffs take the focus off the plaintiffs regardless of their contributory behavior. Again, this can be very effective. See Storytelling Proven to be Scientifically More Persuasive.

  6. Emotional appeals work. As a rule, whether you are buying a new suit, watching your kids tour a college campus or sitting in a jury box, people buy on emotion and justify on fact. The reptile trial strategy is a good method of making an emotional appeal. See Are You Smarter Than a Soap Opera Writer?

  7. Finally, the book reads like a manual -- and even a bad lawyer can follow a manual. Over and over again, good tactics are suggested, wrapped up in a palatable vocabulary. The strategy works because it's easy to follow, easy to remember and easy to implement. See The Top 5 Qualities of a Good Lawyer.

In my next post, I will discuss how to overcome the strategy as a defense lawyer. If you'd like to be notified of subsequent articles, please click here.

Other articles and resources related to trial strategy, jury persuasion and jury consulting from A2L Consulting:

pretrial trial graphics motions briefs hearings

Tags: Jury Consulting, Juries, Trial Preparation, Storytelling, Depositions, Reptile Trial Strategy

Repelling the Reptile Trial Strategy as Defense Counsel - Part 3 - Understanding the Bad Science

Posted by Ken Lopez on Thu, Jul 2, 2015 @ 12:47 PM


reptile-trial-strategy-neuroscienceby Ken Lopez
A2L Consulting

In two recent posts, we discussed the “Reptile” theory of courtroom advocacy, a plaintiff lawyer’s strategy that essentially asserts that plaintiffs can win at trial if they successfully appeal to the “reptilian” portion of jurors’ brains. This portion, according to the theory, is the primitive part of the brain, the portion that humans supposedly share with reptiles. It is this portion that responds on an elemental level to fear, according to “Reptile” advocates, and jurors therefore simply need to be persuaded that they themselves are placed in danger by the defendant’s behavior and that they should return a plaintiffs’ verdict essentially to ensure their own continued safety.

As we said earlier, we believe that far from presenting the latest concepts from neuroscience, the “Reptile” theory presents a laughable and amateurish set of scientific theories. In two earlier posts, we explained how to identify the “Reptile” theory in court. Here are five articles that explain, in plain English, why the theory makes absolutely no sense scientifically. These responses to the “Reptile” advocates, while they will not in and of themselves get “Reptile” concepts out of a trial, will help defense lawyers understand the true roots of the strategy – and may help convince some judges that the “Reptile” strategy, although effective, is based on bogus science.

  1. This article from The Jury Expert, a publication of the American Society of Trial Consultants, argues that “To reduce the human being to a body organ, even the brain, disregards the value of the reflective mind – something no reptile possesses. From time immemorial we have used imagination and supporting evidence in narrative to persuade. A reptile hears no human story. It reacts as a coiling rattlesnake or a slithering lizard. To equate men and women serving on a jury with reactive sub-mammals is both offensive and objectionable.” It instead recommends the use of “persuasive narrative” – the invocation of compelling stories – to influence and persuade juries.
  1. In this interview, trial consultant Stephen Hnat concludes that advocates of the “Reptile” theory confuse brain structure with brain function.” He says that although there is in fact an area of the brain labeled the “reptile brain” that controls “flight or fight” and similar responses, current research in cognitive neurobiology has consistently shown that other areas of the brain that regulate emotion are far more influential in determining perceptions and behavioral responses.
  1. This article from Courtroom Sciences Inc. says that the “Reptile” theory involves a “misuse of neuropsychology” and contends that while “Reptile” advocates have succeeded with juries, it was not because of their knowledge of brain science. The authors say that “Reptile” lawyers succeed not because of their “ability to tap into jurors’ survival instincts” but because they use “successful techniques long used by great plaintiff’s attorneys: reduce a case to its essence and rhetorically focus a case on a critical issue for jurors (e.g. safety).

  2. This article, published earlier this year for an American Bar Association Litigation Section conference [pdf], asserts that human beings “are not just flight or fight responders, they in fact process information. And, the fear responses that humans experience are not predictable, in part because higher level functions often intervene in fear responses.” The article notes that fear can backfire against plaintiff lawyers if jurors believe they are being treated like “reptiles.” The author says that despite its use of bad science, the theory is “here to stay,” and that defense lawyers need to understand why the theory often works with jurors.
  1. In this article, Ken Broda-Bahm asserts that in view of contemporary scientific critiques, the reptile brain theory “stands out as illustrating scientific beliefs that persist more because they are useful than because they are valid. It persists and sticks not because there is strong evidence that it is true, but because it feels ‘complete’ and has, as Stephen Colbert would put it, ‘truthiness,’ independent of its truth.” Nonetheless, Broda-Bahm asserts, the theory needs to be taken seriously.

Experts agree that the science alleged to support the Reptile Trial Strategy is bogus. However, just because the reasoning behind the strategy is flawed, it does not mean that the approach doesn't work — because it does. We will discuss why the Reptile Trial Strategy works and how to counter it in upcoming parts of this series (click here to be notified of subsequent posts).

Other articles and resources related to trial strategy, jury persuasion and jury consulting from A2L Consulting:

opening statements toolkit ebook download a2l

Tags: Trial Consultants, Jury Consulting, Litigation Consulting, Trial Consulting, Jury Consultants, Science, Psychology, Reptile Trial Strategy

Repelling the Reptile Trial Strategy as Defense Counsel - Part 2 - 10 Ways to Spot the Reptile in Action

Posted by Ken Lopez on Fri, Jun 26, 2015 @ 01:24 PM


spot-the-reptile-trial-strategyby Ken Lopez
A2L Consulting

As I discussed in Part 1 of this series, the “reptile” trial strategy is quickly spreading among plaintiffs counsel. Some plaintiffs counsel have, in fact, claimed that the strategy has resulted in verdicts totaling more than $6 billion in the past few years.

In a large room of defense attorneys to whom I made a presentation last week, more than half reported having seen the strategy used in one of their cases. I think that may just be the tip of the iceberg. It appears that many defense counsel are being subjected to the strategy and don't know it is happening to them until it is too late.

In light of this fact, below are 10 ways to spot the strategy. In subsequent articles, we will discuss what to do to counter it. From the very start of your case, look for any of the following 10 phenomena:

  1. You encounter themes suggesting that the community needs to be protected from the defendant; e.g. “Walking past stores on Main Street is part of what it means to be American.”

  2. The behavior of the plaintiff or other contributing or mitigating traits of the plaintiff are ignored, and instead the plaintiff works hard to keep the focus on the defendant or even an idealized defendant.

  3. Plaintiffs introduce a discussion of “safety rules” throughout all pre-trial phases of the case; e.g. “Do you agree that keeping the public safe is a key role of your train operators?”

  4. Plaintiffs use phrases during discovery like “No person has a right to needlessly endanger another person.”

  5. Plaintiffs make an effort to imagine what the defendants’ conduct could have been in a worst-case scenario. e.g. “What if your plane hit a school instead of a forest?”

  6. There is an almost bizarre avoidance of discussing the standard of liability.

  7. Plaintiffs emphasize the word “must” during depositions like, “You would agree that management must remove needless workplace dangers?”

  8. There is considerable emphasis on "responsibilities" and little emphasis on the actual standard of liability.

  9. Plaintiffs counsel try to ask your client to articulate worst case scenarios if safety rules are violated, as in, “How much harm could a chemical spill from your plant cause?”

  10. Plaintiffs try to substitute job duties for a standard of liability. e.g. “A pilot's job is to make sure the plane is flightworthy, right?”

Spotting any one of these indicators means there is a good chance that the reptile trial strategy is in play. Failing to pay close attention to the use of the strategy may very well create a strong advantage for the plaintiff at trial. It is now critical that every defense attorney know how to respond to this strategy. We will cover this and other topics in subsequent posts (click here to be notified of subsequent posts) in this Reptile trial strategy series.

Have you seen these tactics in your cases? I'm particularly interested in non-tort case examples. Please tell me, either publicly or by private email, what you have seen.

Other articles and resources related to trial strategy, jury persuasion and jury consulting from A2L Consulting:

A2L Consulting Voir Dire Consultants Handbook

Tags: Trial Consultants, Trial Presentation, Jury Consulting, Trial Consulting, Juries, Jury Consultants, Trial Preparation, Psychology, Reptile Trial Strategy

Repelling the Reptile Trial Strategy as Defense Counsel - Part 1

Posted by Ken Lopez on Tue, Jun 23, 2015 @ 02:05 PM


repitile-trial-strategy-jury-consultantby Ken Lopez
A2L Consulting

Last week, I spoke at an annual gathering of defense attorneys whose subtitle was “Lawyers and Other Reptiles.”

What's going on? Who are these reptiles? It’s an interesting story. This conference was planned as a way to bring together defense attorneys around the nation who want to learn how to turn aside a frequently used set of trial tactics championed by David Ball and Don Keenan in their "Reptile" series of books and webinars. Ball is a North Carolina-based jury consultant, and Keenan is an Atlanta-based plaintiffs trial lawyer.

According to Ball and Keenan’s publicity materials, the “reptile” concept is “the most powerful tool in the fight against tort reform.” Ball and Keenan say that through their books, DVDs, seminars and workshops, “the Reptile is revolutionizing the way that trial attorneys approach and win their cases.” The proof, they say, is in the numbers, as more than $6 billion in verdicts and settlements have resulted from these tactics since they launched them in 2009.

William A. Ruskin of Epstein Becker & Green has summarized the concept well in a 2013 Lexis-Nexis article:

The Reptile theory asserts that you can prevail at trial by speaking to, and scaring, the primitive part of jurors' brains, the part of the brain they share with reptiles. The Reptile strategy purports to provide a blueprint to succeeding at trial by applying advanced neuroscientific techniques to pretrial discovery and trial. The fundamental concept is that the reptile brain is conditioned to favor safety and survival. Therefore, if plaintiff's' counsel can reach the reptilian portion of the jurors' brains, they can influence their decisions; the jurors will instinctively choose to protect their families and community from danger through their verdict.

While the “science” described by the authors is laughable and amateurish, the strategies they recommend are effective. As a result, defense attorneys nationwide are taking notice and developing strategies to combat these tactics.

The Reptile strategy is showing up mostly in single-plaintiff cases on the coastal areas, but it is spreading geographically and is now being used in larger cases. Looking at the Reptile trial strategy more as a comprehensive litigation tactic, I'd summarize the approach this way:

  • Beginning as soon as the complaint, articulate a set of common sense safety rules that people as good members of a community should follow.

  • Get experts and fact witnesses, in discovery, to agree that these common sense safety rules are reasonable for society. For example people shouldn't drive fast, pouring chemicals into rivers and streams is not ideal, a single company should not own too much of the market, doctors shouldn't hurt people.

  • Use fear as a persuasion device to frighten jurors into defending their communities by adopting what is effectively a new standard of liability.

When fully implemented, the strategy sees the defendant’s conduct as a secondary consideration to what might have occurred. For example, what if it had been a school bus in the accident? What if the contamination would have been of drinking water for a pregnant mom? These arguments substitute for the actual standard of liability and the actual conduct of the defendant.

The rationale for this approach is that fear will cause jurors to abandon rational thought and penalize the defendants. That's not how people think, that's not how juries reach decisions, and that’s not actual science. But just because the authors flub the science it doesn't mean their recommended trial strategies are bad. Ball and Keenan make some suggestions that defense lawyers must be aware of.

I believe it's possible to overcome these strategies, particularly at trial, by simply being a good lawyer and doing what you should be doing at trial anyway -- specifically by articulating a strong narrative that makes sense to people and that people care about.

If you have not seen the Reptile trial strategy in one of your cases yet, you probably will soon. A show of hands at my speaking engagement showed more than half of a large audience having seen it in one of their cases recently.

I will go more into detail about how to spot the Reptile trial strategy and how to respond to it in upcoming articles. Click here to be notified of subsequent articles.

Other articles and resources related to trial strategy, jury persuasion and jury consulting from A2L Consulting:

opening statements toolkit ebook download a2l



Tags: Trial Consultants, Juries, Jury Consultants, Trial Preparation, Psychology, Storytelling, Opening, Persuasion, Reptile Trial Strategy

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KenLopez resized 152

Ken Lopez founded A2L Consulting in 1995. The firm has since worked with litigators from all major law firms on more than 10,000 cases with over $2 trillion cumulatively at stake.  The A2L team is comprised of psychologists, jury consultants, trial consultants, litigation consultants, attorneys and information designers who provide jury consulting, litigation graphics and trial technology.  Ken Lopez can be reached at lopez@A2LC.com.


Tony Klapper joined A2L Consulting after accumulating 20 years of litigation experience while a partner at both Reed Smith and Kirkland & Ellis. Today, he is the Managing Director of Litigation Consulting and General Counsel for A2L Consulting. Tony has significant litigation experience in products liability, toxic tort, employment, financial services, government contract, insurance, and other commercial disputes.  In those matters, he has almost always been the point person for demonstrative evidence and narrative development on his trial teams. Tony can be reached at klapper@a2lc.com.

dr laurie kuslansky jury consultant a2l consulting

Laurie R. Kuslansky, Ph.D., Managing Director, Trial & Jury Consulting, has conducted over 400 mock trials in more than 1,000 litigation engagements over the past 20 years. Dr. Kuslansky's goal is to provide the highest level of personalized client service possible whether one's need involves a mock trial, witness preparation, jury selection or a mock exercise not involving a jury. Dr. Kuslansky can be reached at kuslansky@A2LC.com.

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