This CLE course explores the Plaintiff Fact Sheet (PFS), a key document in Mass Tort litigation that functions as a customized set of written questions in place of standard interrogatories. In Mass Tort cases, parties negotiate the questions that appear in the PFS.

Defendants aim to include detailed questions covering basic claimant information—like date of birth and marital status—as well as case-specific details such as the type and date of injury, and the claimant's medical history. Plaintiffs, on the other hand, prefer a more concise PFS, focusing on essential information, and seek to limit the range and scope of the questions asked, including the timeframe of discovery.

Throughout the course, you'll gain insight into the dynamics and challenges of negotiating a PFS, including the differing priorities of plaintiffs and defendants. We will examine the key issues to consider when crafting a PFS, how to navigate the negotiation process, and strategies for managing and minimizing the discovery required.

By the end of the course, you'll understand the critical aspects of PFS negotiation and how to effectively advocate for your client's interests in limiting the scope of discovery.