Plaintiff Fact Sheet (PFS)

The most methodical initial mechanism for obtaining individual plaintiff discovery.

A PFS is a set of questionnaire released by the federal court mostly involving mass-tort cases that have been centralized for coordinated discovery and pretrial proceedings. The court requires the fact sheets to be completed by the plaintiffs and submitted within a stipulated period set by the court. The information helps the attorneys to analyze the validity of the claim thoroughly before preparing a case as both parties get an overview of the case to understand its strengths and limits before trial.

The main advantage of filing plaintiff fact sheets is that it results in filtering unsupported claims in large MDL proceedings thereby creating a pool of cases for initial trial if the case management process includes bellwether trials.

PFS form has a set of standardized questionnaires that serve the same function as interrogatories and requests for production.
Ordered most often in multidistrict litigation (MDL) proceedings involving large numbers of plaintiffs.
Release of PFS comes within an average of 8 months of centralization of the proceeding.
The general information required in the PFS includes:
  • health records (e.g., general health, health issues related to the product, names of doctors, pharmacies, and denial of health insurance)
  • personally identifying information (e.g., names, addresses, education, and employment);
  • litigation history (e.g., prior tort litigation, past bankruptcy, social security claims, and workers’ compensation claims).
At times, following the filing of a master complaint involving large proceedings, Short Form Complaints (SFC) may be ordered for direct-file cases in conjunction with PFS.
A substantially filled PFS invokes a Defendant Fact Sheet order.

*Under the federal MDL statute, 28 U.S.C. § 1407, temporary transfer of federal civil lawsuits to one or more district courts for pretrial consolidation or coordination is allowed before a single judge aims for coordinated discovery and pretrial proceedings.

*The “transferee” court has jurisdiction over all pretrial matters in all transferred cases with the right to dispose of claims completely through dismissal or summary judgment. It controls the pace and scope of discovery and the limits of expert testimony. Every case is then remanded to its “transferor” court for the trial itself; however, most mass tort claims are resolved before then.

*The centralization allows all cases to be handled in a single district court and coordinated and consolidated managed by a single judge.

PFS Dismissal:

Motions to dismiss actions for failing to submit completed PFS can rely on:

Federal Rule of Civil Procedure 41(b) (dismissal for failure to prosecute or comply with a court order).
Federal Rule of Civil Procedure 37(b)(2) (dismissal for failure to comply with a discovery order).
Transferee courts with prejudice for failure to comply with PFS obligations imposed by court order.
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Advantages of a PFS

Sets an orderly procedure for discovery specific to plaintiffs and their prescribing/treating physicians.
Federal Rule of Civil Procedure 37(b)(2) (dismissal for failure to comply with a discovery order).
Allows case analysis thoroughly before preparing a case.
Filters the number of cases to be subjected to fuller case-specific fact discovery and expert discovery.
Defendants are spared the expense of interrogating numerous individual claimants while allowing plaintiffs’ attorneys to fulfill early discovery obligations with relative ease.

Neural IT and PFS: What we offer?

We understand

  • Collecting facts is the most crucial stage as it can either lead to the acceptance of the case or its dismissal.
  • Filling PFS can be a complicated task requiring accurate and comprehensive information, backed up with required documented proofs.

MDL Centrality: PFS

MDL Centrality is an online fact sheet exchange which was created to help manage cases in an efficient and cost-effective way. The website plays a crucial role in reducing the paperwork and saving a substantial amount of time in this process.

Salient Facts

Exchange Fact Sheets and supporting documents through a secure online portal instead of by email or mail.
Automatically download and store court filings, eliminating the need to spend time and money uploading and distributing documents manually.
Export data and documents from Fact Sheets to Claim Forms, eliminating the need to spend time and money manually re-entering information already provided.
Store documents in a secure, online repository, eliminating the need to pay for and maintain a separate document storage solution.

How can Neural IT help here?

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Our PFS Team is thoroughly adept at entering Fact Sheets directly through MDL Centrality.

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Our team keeps updating the information as and when medical records or other proofs become available.

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We provide satisfying responses to any deficiency notification that comes from the MDL with specified deadlines.

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MDL is also an easy tracking tool for law firms when they are handling a large volume of cases.

Challenges faced by law firms and lawyers while handling PFS

Medical Jargons

The medical records required are extremely vast requiring a personal medical history of each patient. In such cases, understanding and filling plaintiff fact sheet details becomes difficult for attorneys.

Tagging Documents

Medical events entered in the PFS need to be supplemented with authorized medical records, and can be time-consuming as well as challenging task for attorneys to comprehend and report.

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Neural IT filled PFS forms

Records are bate stamped and medical events are bookmarked to be then arranged in chronological order. This leads to a better case understanding by the legal team.
Our well-trained medical experts understand every question and forms are filled with the utmost relevance to the particular medical case type.
Quick TAT
Value for money proposition.
Accreditations & HIPAA compliant ensuring legal security and privacy of all clients.
Other related services to help companies achieve greater heights.

Our Strengths

A PFS filled by our team of experts further sets up the case for ease of settlement negotiations. We ensure submission of an accurately and thoroughly completed PFS form at court before the stipulated deadline. Weaknesses and missing details are identified by our team that can be fixed.

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Our Track Record

We have successfully submitted facts sheets on behalf of plaintiffs in various Multidistrict Litigations and
other mass tort litigations, listing a few for your reference.

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Team receives scanned medical documents
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Documents are bate stamped and bookmarked
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Missing events/details are identified- Request forwarded
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PFS questionnaire form is filled with relevant details
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Entry tagged with page reference to source

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