Plaintiff Fact Sheet (PFS)

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 submitte

• 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.

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 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.

• 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.

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.