- A plaintiff fact sheet is a court-approved questionnaire each plaintiff completes in a mass tort or MDL, and it replaces much of the early written discovery.
- Most fact sheets cover background, product use or exposure, injuries, treating providers, prior claims and damages, plus signed records authorizations.
- Late or incomplete fact sheets usually trigger a deficiency notice, and problems that aren’t cured can lead to dismissal under the MDL’s case management order.
- Follow-up is the real cost: on a 1,500-plaintiff docket, about 3,150 calls and texts can land before the same deadline.
- HelloCounsel calls and texts claimants until fact sheets, signatures and documents are in, and logs every follow-up in your case management system.
A plaintiff fact sheet is a court-approved questionnaire each plaintiff completes in a mass tort or MDL, covering their background, product use, injuries and treatment. It replaces much of the early written discovery. Fact sheets have deadlines, and missing or incomplete ones can lead to deficiency notices and, if not fixed, dismissal.
- HelloCounsel calls and texts claimants until fact sheets, signatures and documents are in.
- It works medical records requests at docket volume.
- Every follow-up is logged in your case management system.
Why are plaintiff fact sheets hard to collect?
A fact sheet asks a lot of a claimant who may have signed months ago. It needs detailed answers about product use, medical history and providers, plus signed authorizations. Claimants put it off, leave sections blank or stop answering calls, and the firm has thousands of them on the same deadline.
Common problems:
- Long questionnaires: Fact sheets can run many pages of detailed questions.
- Missing details: Claimants don’t remember dates, doses or providers.
- Unsigned authorizations: Records authorizations come back unsigned or not at all.
- Claimants who go quiet: People stop answering once the paperwork starts.
- Tight deadlines: Court-set deadlines apply to every plaintiff at once.
What does a plaintiff fact sheet ask?
Each MDL sets its own form, but most cover the same ground. Expect questions on personal background, product use or exposure, the injury and diagnosis, treating providers, prior claims, and damages, plus signed authorizations so defendants can request the plaintiff’s records directly.
The court and the parties agree on the form, so always use the version entered in your MDL.
What happens if a plaintiff fact sheet is late or incomplete?
Defendants usually send a deficiency notice, and the plaintiff gets time to fix it. If the problems aren’t cured, the court can dismiss the claim. The exact process is set by the case management order in each MDL, so track every deadline.
Keep each fact sheet on track:
- Start early. Send the fact sheet as soon as the claimant signs.
- Follow up on a schedule. Call and text until it’s back.
- Check for gaps. Review answers before the deadline, not after a deficiency notice.
- Collect records. Request records to support the answers.
What does fact sheet follow-up cost a mass tort firm?
The cost is mostly follow-up time across a large, busy docket. Each incomplete fact sheet can take several calls and texts, and a deficiency notice adds another round on top. The example below shows the scale for a mid-size docket.
Worked example · mid-size firm
| Input | Example |
|---|---|
| Plaintiffs with fact sheets due | 1,500 |
| Share late or incomplete | 35% |
| Fact sheets needing follow-up | 525 |
| Calls or texts each | 6 |
| Touches before the deadline (525 × 6) | 3,150 |
Illustrative figures; replace with the firm’s own numbers.
Those touches all land in the weeks before the same deadline. See mass tort intake services for how firms handle the volume.
Get every fact sheet in before the deadline
HelloCounsel calls and texts claimants until fact sheets, signatures and documents are in, and logs every follow-up in Filevine, Litify, Neos or CasePeer. HIPAA compliant, and every engagement starts with a pilot.
Schedule DemoShould staff, a vendor or AI agents chase fact sheets?
Firms collect fact sheets in three ways: their own staff follow up, a litigation support vendor takes it on, or AI agents call and text claimants. All three can work. They differ in cost at volume, how persistent the follow-up is, and where the record ends up.
| In-house staff | Litigation support vendor | AI agents | |
|---|---|---|---|
| Cost | Staff time that grows with the docket | Vendor fees | Custom pricing, no per-minute billing |
| Follow-up | When staff have time | Set by the vendor | Calls and texts until it’s in |
| Records | Separate requests | Often included | Records requests worked at volume |
| In your CMS | Only if staff log it | Vendor portal | Logged in your CMS |
| Best for | Small dockets | Firms that want to hand off the work | Firms that want every claimant chased |
Whichever you use, track every fact sheet against its deadline.
How does HelloCounsel get fact sheets in?
HelloCounsel calls and texts claimants until fact sheets, signatures and documents are in. It works records requests at docket volume and logs every follow-up in your case management system, so your team can see which files are complete and focus on the ones that need a lawyer.
Here’s what HelloCounsel does for mass tort firms:
- Reaches every claimant: Calls and texts each claimant with a fact sheet due.
- Keeps following up: Continues until the fact sheet is back.
- Gets signatures: Chases unsigned authorizations and documents.
- Works records at volume: Requests and follows up on records across the docket.
- Logs everything: Notes every follow-up in the case file.
- Works inside your CMS: Filevine, Litify, Neos or CasePeer, with no new training for your team.
What do firms say about working with HelloCounsel?
“Working with HelloCounsel has been an outstanding experience. Their commitment to client service and innovation is evident in everything they do.”
Anthony Ramos, COO, Pendergast Law
Frequently Asked Questions
1. What is a plaintiff fact sheet?
It’s a standard questionnaire each plaintiff completes in a mass tort or MDL. It covers background, product use or exposure, injuries, treatment and damages, and replaces much of the early written discovery.
2. Who fills out the plaintiff fact sheet?
The plaintiff provides the answers, usually with help from their law firm, and signs it under oath. The firm reviews it and serves it on the defendants by the court’s deadline.
3. What happens if a plaintiff fact sheet is not completed?
Defendants usually send a deficiency notice and the plaintiff gets time to fix it. If the problems aren’t cured, the court can dismiss the claim under the MDL’s case management order.
4. How long does a plaintiff have to complete a fact sheet?
The deadline is set by the case management order in each MDL. Track it from the day the claimant signs, because follow-up takes time.
5. Can AI help collect plaintiff fact sheets?
Yes. HelloCounsel calls and texts claimants until fact sheets, signatures and documents are in, and logs each follow-up in your case management system.
6. Does HelloCounsel work with my case management system?
HelloCounsel works inside Filevine, Litify, Neos and CasePeer, so every follow-up is logged where your team works. If your firm uses a different system, raise it on a demo call.
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