The Plaintiff Fact Sheet (PFS) is a written questionnaire which takes the place of non-negotiated interrogatories, or written questions, and is typically served in Mass Tort litigation. In a Mass Tort case, the Parties negotiate the questions to be asked on the PFS questionnaires.

The Defendants are entitled to ask questions in a PFS that provides both basic information about the claimant (date of birth, marital status) and specific information (date of injury, type of injury, name of doctor). While the defense would prefer that the PFS be as extensive as possible, Plaintiffs will want it to provide the bare minimum of information. If possible, Plaintiffs want to eliminate non-essential questions and also limit the time frames of discovery that will be provided and the scope of the discovery.

This Course will discuss some of the issues that arise when negotiating a PFS and why these issues are important so the plaintiff negotiator can control and limit the amount of discovery being provided.