Litigation glossary

Plaintiff Fact Sheet (PFS)

A standardized questionnaire every MDL plaintiff must complete — product use, medical history, damages — that substitutes for individualized early discovery. Miss its deadlines and a case can be dismissed.

Fact sheets let a court and defendant learn the shape of thousands of claims without thousands of depositions. They are court-ordered discovery: incomplete or ignored fact sheets trigger show-cause orders and dismissals in every large MDL.

The 2025 amendment to the federal rules (Rule 16.1) pushes this earlier — courts now systematically exchange claim information at the start of an MDL, which is raising the bar against unvetted claims. If your firm asks for records and signatures, this is usually why.

Sources & attribution

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