Practice Law firms · Mass tort and MDL

The deadline is the same whether you have nine plaintiffs or nine hundred.

Mass tort is the personal injury records problem multiplied, and then given a court order with teeth. A plaintiff fact sheet that goes in late or deficient is not a scheduling problem, it is a Rule 41(b) problem.

57% of MDL proceedings order fact sheets
81% of those with more than 100 actions
Rule 41(b) dismissal for failure to comply
Rule 37(b)(2) the discovery-order equivalent

Published figures and statutory rules, not measurements of your practice. We have not audited your files and these are a starting point for a conversation rather than a claim about your numbers.

Where the hours and the money go

Fact sheets are court-ordered, not optional

Plaintiff fact sheets were ordered in 57 percent of MDL proceedings examined, and in 81 percent of those carrying more than a hundred actions. They replace individual interrogatories, and the court expects them complete and on time.

A deficiency is a dismissal risk

Missing pharmacy records, an absent lot number, an exposure date nobody pinned down. Defense moves to compel, and dismissal runs under Rule 41(b) for failure to comply or Rule 37(b)(2) on the discovery order. The claim was good; the paperwork was not.

The work does not scale with headcount

Nine hundred claimants is not nine hundred times harder, it is nine hundred times more places for one field to be blank. Adding paralegals adds coordination, and coordination is where things get missed.

You find the gap after the deadline

Deficiencies discovered when defense identifies them are expensive. Found three weeks earlier, they are a phone call to a client and a supplemental records request.

What we would build

Fact sheet assembly from the file

Fields populated from records, intake and the client interview, with provenance on every answer so a reviewer can see where it came from rather than trusting it.

Deficiency detection before submission

Every fact sheet checked against the governing order before it goes out. Missing lot numbers, absent pharmacy records, unpinned exposure dates surfaced as a work queue while there is still time to fix them.

Records collection at volume

Requests raised, chased and reconciled across hundreds of claimants and providers, with the ones actually blocking a deadline sorted to the top.

A census that is one source of truth

Claimant status, deadlines, deficiencies and documents in one place, reportable to co-counsel and leadership without somebody rebuilding a spreadsheet each Friday.

Fact sheet review MDL 3021 · PFS 0412
Plaintiff Sample, R.
Fields populated 84 of 91
Exposure dates Complete
Pharmacy records Missing
Days to deadline 19

Deficiency Pharmacy records absent and lot number unpinned. Caught 19 days out, so it is a client call rather than a motion to compel.

Held for supplement Checked against PTO 14
Illustrative sample. Not a client record.

Questions

We already use a mass tort case management platform. Where does this fit?

Alongside it, usually. The platforms hold the census well and are weaker at the document work feeding it: reading records, populating fact sheets, catching deficiencies before defense does. We build that layer and write results back rather than asking you to migrate.

Can it handle several MDLs with different fact sheet formats?

That is the normal case and it is a reason to build rather than buy. Each order defines its own fields and deadlines, and a product built for one tort will fight you on the next. The Audit week scopes against the orders you are actually working under.

Working with us

Vendor-ready
Thrive Development LLC, a Texas LLC. W-9 and a signed MSA the day you ask for them.
Your infrastructure
Everything runs in your cloud tenant on your accounts. We hold no client data.
References
Available on request once we are past a first conversation.

Questions about insurance, security or contracting go straight to contact@thrivedevelopment.io. We reply to everything within one business day, including the enquiries we are not the right firm for.

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