The essential playbook for mass tort and MDL litigation

Built for cases that outlast a single case team

Picture this: your firm just got retained on a new pharmaceutical MDL. 40,000 documents to review, 12 plaintiff firms to coordinate, a Plaintiff Steering Committee standing order, and a bellwether trial date already on the calendar. You've handled something like this before, but the medical literature from that prior matter sits in a platform your firm no longer subscribes to, and the exhibit list from your last trial is a spreadsheet on someone's old laptop.

That's the operational reality of mass tort litigation for most firms: not a lack of experience, but a lack of infrastructure to carry it forward. Mass tort and MDL matters aren't just bigger versions of standard litigation. Discovery happens once and is shared across every plaintiff. New cases join as tag-along actions throughout the matter's life. Bellwether trials test the entire litigation theory, with settlements for hundreds or thousands of plaintiffs hinging on the result. And the whole thing can run five, seven, or ten years.

What's inside this guide:

1. Data reuse and case infrastructure
Treat prior work product as an asset, not an archive. Master repositories of recurring medical literature, expert transcripts, and exhibits are the single most undervalued advantage in mass tort litigation.

2. eDiscovery strategy for mass tort
Negotiate ESI protocols with proportionality in mind, run early data assessment before review begins, and structure phased review around the legal theories driving your case.

3. Deposition and transcript management at scale
Designation rounds, video clips, and co-counsel coordination all multiply with transcript count. Learn how to centralize transcripts and video, keep designations in sync, and triage new transcripts without reading each one sequentially.

4. Case building and trial preparation
Build the master chronology and two-tier exhibit library that support an entire MDL, then translate a complex causation theory into a story a jury can actually follow. This guide covers how firms like Burns Charest built a workflow that kept every round of designations, counters, and objections in one place.

Building infrastructure that compounds

The firms that succeed in mass tort litigation aren't the ones fighting hardest on any single matter. They're the ones building infrastructure that carries institutional knowledge from one case to the next, from the first document collected to the verdict that shapes every settlement behind it. This guide will help you build that infrastructure.

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