Defense attorneys need new rules to counteract reptile plaintiff attorneys’ approach to 30(b)(6) depositions.

Plaintiffs’ attorney Don C. Keenan, Esq., and David Ball, Ph.D., authored a book published in 2009, Reptile: The 2009 Manual of the Plaintiff’s Revolution, in which they formulate their reptile theory for plaintiffs’ lawyers. The reptile theory is loosely based on the work of physician and neuroscientist Paul D. MacLean, who worked at Yale Medical School and the National Institute of Mental Health and posited a triune brain theory, which proposed that the human brain was in reality three brains in one: the reptilian complex, the limbic system, and the neocortex.