Today we pick up with the second part of our conversation with Bob Tyson, founding partner of 200-lawyer insurance defense law firm Tyson & Mendes. Tyson is author of a book about defending against nuclear verdicts, which was the basis for a defense-side workshop on that topic last month.

In yesterday’s column, we focused on Tyson’s thoughts about how defense lawyers need to change up their tactics to address approaches adopted by plaintiffs counsel over the past decade and a half to tap into juror anger. In the second half of our conversation, we discussed non-economic damages, the discretionary portion of a case where that anger is often felt most intensely by defendants. The following has been edited for length and clarity.

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