Mass tort litigation checklist

Mass tort and MDL cases move fast, span multiple firms, and generate mountains of overlapping data. This checklist walks through five phases, from matter intake to trial, so your team stays organized as the case scales.

What this mass tort litigation checklist covers:

Our mass tort and MDL checklist addresses the full arc of a case that scales across firms and grows over multiple years: auditing and reusing data from prior related matters, negotiating ESI protocols anchored in proportionality, building a document review workflow around case-specific issues, centralizing deposition transcripts and video across all participating firms, and building the timelines, exhibit libraries, and trial materials that carry a bellwether case to verdict.

Five reasons to download this checklist:

Reuse what your firm already has

Audit prior related matters and build a master repository, so you're not starting from a blank page on every new mass tort or MDL matter.

Negotiate ESI protocols that don't compound costs

Anchor custodians, date ranges, and production formats in proportionality before an overly broad protocol creates costs and delays that spiral over a multi-year matter.

Build a review workflow around your case, not a template

Custom-tag for causation evidence, corporate knowledge, and regulatory conduct — not just relevance and privilege.

Centralize depositions across every firm in the case

Manage designations, synced video, and platform access for lead counsel, local counsel, and tag-along firms in one place.

Start building your trial narrative during discovery

Timelines, exhibit libraries, and demonstratives developed early carry the case all the way to a bellwether verdict.

This checklist gives you a practical reference for every phase of a mass tort or MDL matter, from intake through verdict. Download it and revisit it as your case develops.

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