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The Plaintiff Fact Sheet (“PFS”) in a Mass Tort Setting

SKU: TRN1200
General Credits
1.5
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Description

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.

Lecturer Bio

Michael Pederson, Esq.

Michael E. Pederson fights for the rights of adults and children who become injured by pharmaceuticals and medical products purported to be safe. He conducts this work in his capacity as an associate attorney assigned to our Drugs & Medical Devices Litigation group.

Mr. Pederson holds privileges to represent clients in the courts of the state of New York and in the federal District Court’s New York Southern and Eastern jurisdictions. Mr. Pederson is a member of the City of New York Bar Assn.

He received a juris doctor degree from St. John’s University School of Law in 1988. As an undergraduate, he attended the University of Washington. In 1980, that institution conferred upon him a bachelor of arts degree in history; the following year it bestowed a certification in secondary education; in 1982, it handed him a degree in political science.

From 1983-89, Mr. Pederson served in the U.S. Army Reserve.

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