Plaintiff Fact Sheet (PFS)

A Plaintiff Fact Sheet is a standardized questionnaire required of each plaintiff in an MDL, capturing medical history, product exposure, alleged injuries, and damages information in a uniform format established by the transferee court. PFS completion is typically a prerequisite to maintaining active status on the docket, and deficient or non-responsive PFS submissions can result in dismissal of individual claims. For funders with portfolio exposure across large MDL dockets, PFS compliance rates are an operational risk factor — a high rate of dismissals for PFS deficiency can impair the funded claim pool and reduce aggregate recovery. Due diligence on any mass tort investment should include an assessment of the law firm's infrastructure for client communication, records collection, and PFS submission compliance.

Because PFS compliance failures are a routine basis for dismissal, funders with portfolio-wide exposure across a large MDL treat a law firm's client-intake and records-collection infrastructure as a due diligence item distinct from the strength of any individual claim. A firm with a high rate of PFS deficiencies effectively shrinks the funded claim pool over time, which funders account for by discounting expected portfolio size rather than assuming full enrollment converts to eligible claims.