Practicing in an MDL: A Practical Guide for Plaintiff and Defense Counsel

Summary. This guide is written for the lawyer who has cases in an MDL and needs to know what to do rather than what an MDL is. It covers the JPML petition and opposition, applying for leadership and what the role requires, keeping common benefit time in a form that will be approved, reading the case management orders that govern everything, fact sheet and registry compliance that determines whether your cases survive, the general causation fight, bellwether strategy, and the settlement participation decision including the informed consent obligations applying to every case in your inventory.

There are two entirely different jobs inside a multidistrict litigation, and confusing them is the most common mistake lawyers make when they arrive.

The leadership job is running a national litigation: taking corporate depositions, retaining epidemiologists, briefing preemption and Daubert, negotiating with a defendant's national counsel, and trying bellwethers. Perhaps thirty lawyers do it in any given MDL.

The individual counsel job is running an inventory: intaking clients, collecting medical records, completing fact sheets on deadline, responding to registry and show-cause orders, tracking product identification, and — at the end — obtaining informed consent from each of several hundred clients. Thousands of lawyers do this, and almost nothing written about MDLs describes it.

This guide covers both.

Part 1 — Before centralization: the JPML

The petition. A motion under 28 U.S.C. § 1407 with a supporting brief, a schedule of the actions involved, and copies of the complaints. Briefs are short — the Panel's rules impose a tight page limit — and argument at the hearing is a few minutes.

What to argue for centralization: the number of pending and anticipated actions; the common factual questions (design, testing, corporate knowledge, warnings, general causation); the duplication of corporate discovery; the risk of inconsistent pretrial rulings; and the inadequacy of informal coordination.

What to argue against it: too few actions; genuinely different products, time periods, or defendants; individual issues predominating even at the pretrial stage; and the sufficiency of voluntary coordination among a handful of cooperating counsel.

Choosing a district. Argue: where the largest number of actions is pending; where the defendant is headquartered and the documents and witnesses are; the proposed judge's experience with complex litigation and current docket; the district's caseload statistics and time-to-trial; and accessibility. Be candid that the Panel weighs judicial capacity heavily, and that a strong argument for a specific judge is more effective than an argument for a city.

Practical notes. Tag-along actions are transferred by conditional transfer order, which becomes effective unless opposed within a short window — calendar it. A party opposing transfer of a particular case must move to vacate the CTO promptly, and the usual grounds are that the case lacks the common questions or that transfer would prejudice a case near trial.

Part 2 — Applying for leadership

What the court is looking for, in roughly this order: experience in comparable MDLs; the capacity to commit substantial time; the financial capacity to fund common expenses for years without reimbursement; a demonstrated ability to work cooperatively with other counsel; and, increasingly, a leadership slate reflecting a range of firms, geographies, and backgrounds rather than the same names.

What an application should contain: the specific MDLs and roles held, with the transferee judges named; the number of cases in the applicant's inventory and how they were developed; the resources committed — lawyers, staff, capital; a statement of willingness to be bound by the court's common benefit protocols; and a description of the applicant's proposed contribution, tied to a specific role rather than a general offer to help.

What the role actually costs. Leadership in a large MDL is a multi-year, multi-million-dollar commitment funded up front against an uncertain recovery. Firms without the capital to carry that should apply for a defined subcommittee role rather than a co-lead position, and courts respect the candor.

The defense side. Defendants appoint national coordinating counsel, liaison counsel, and trial counsel, and the structure is negotiated internally rather than by the court. What the court expects is a single voice for scheduling and negotiation and a defined point of accountability for discovery.

Part 3 — Common benefit time, kept correctly

If you hold a leadership or committee role, this determines whether your work is compensated.

Read the common benefit order first. It will specify which categories of work qualify, what documentation is required, the deadline for periodic submissions, whether pre-appointment work counts, and who audits.

Record contemporaneously, in the format the order requires. Time reconstructed at year-end is routinely reduced or disallowed.

Categorize by task code, matching the order's categories: document review, depositions, expert work, briefing, science, bellwether, settlement, administration.

Distinguish common benefit from individual work. Work that benefits only your own clients — intake, individual records, your own client's fact sheet — is not common benefit and should never be submitted as such. Submissions blending the two invite reduction of the whole.

Track expenses separately, with receipts, and know which categories the order treats as shared versus individually borne.

Submit on time, every period. Late submissions are cut.

And understand the assessment from the other direction. If you are individual counsel, the holdback applies to your clients' recoveries whether or not you did any common work. Explain that in the retainer and again before settlement, in writing.

Part 4 — Reading the case management orders

The CMOs are the procedural law of your case. Read all of them, in order, before doing anything.

The ones that matter most to individual counsel:

• The direct filing order — whether you may file in the MDL district, and what district you must designate as the one where the case would otherwise have been filed. That designation drives choice of law and the eventual remand venue, and getting it wrong is a real problem years later.
• The plaintiff fact sheet order — the form, the deadline (usually measured from filing or from the order), the authorization requirements, and the deficiency and cure process.
• The census or registry order — what must be submitted for filed and unfiled claims, and when.
• The records collection protocol — which records are required, from whom, and in what format.
• The protective order — confidentiality tiers and what you may share with your own client.
• The common benefit order — the assessment percentage and its scope.
• The tolling agreement, if one exists, and its termination provisions.
• Show-cause procedures — how a deficient case is dismissed and how to cure before that happens.

Calendar every deadline in every CMO for every case in your inventory. This is a database problem, not a calendar problem, once you have more than a few dozen cases.

Part 5 — Fact sheets and registries: the compliance job

This is where individual counsel lose cases, and it is entirely avoidable.

The plaintiff fact sheet typically requires: identifying information; product identification with supporting evidence; dates and duration of use or exposure; the injury and its diagnosis date; treating providers with dates; prior medical history; other potential causes; damages; and signed authorizations.

How to do it well:

• Start records collection at intake, not when the fact sheet is due. Records take sixty to ninety days to arrive and providers routinely produce incomplete sets.
• Product identification is the single most common fatal gap. Pharmacy records, implant cards, operative reports, device stickers, purchase records, insurance claim histories. A case without product identification will not survive vetting, and it should not be filed.
• Answer every question. Blank fields generate deficiency notices, and unresolved deficiencies generate dismissals.
• Build a tracking system — a spreadsheet at minimum, a case management database in practice — with, for each case: filing date, fact sheet due date, submitted date, deficiency notices, cure deadlines, records requested and received, and product identification status.
• Respond to deficiency notices immediately. Courts dismiss for failure to cure, and reinstatement is discretionary and often refused.

Census registries demand the same information earlier and frequently for unfiled claims. Treat a registry order as a directive to vet your entire inventory: cases that cannot satisfy it should be closed with the client informed, not carried forward.

Lone Pine orders, when entered, require a prima facie expert showing on exposure, injury, and causation. If one is likely, budget for expert review of your inventory well before the order issues.

The uncomfortable but necessary point. An inventory containing cases without product identification, without a qualifying injury, or without a plausible causal claim damages the litigation, damages the lawyer's credibility with leadership and the court, and ultimately damages the clients with real claims by depressing the settlement. Vet at intake.

Part 6 — The general causation fight

If you are on the science team, this is the case. If you are individual counsel, this is the event that determines whether your inventory is worth anything.

Building the plaintiffs' case: epidemiological studies with adequate power and controlled confounding; dose-response evidence; mechanism and biological plausibility; animal and in vitro data with an articulated basis for extrapolation; the Bradford Hill considerations applied explicitly; and experts whose methodology is independent of the litigation.

The defense attack under Fed. R. Evid. 702 and Daubert: methodology developed for litigation; cherry-picked studies; unexplained reliance on a subset of the literature; failure to account for confounders; extrapolation from animal data without justification; relative risk below the threshold the jurisdiction requires; and — the 2023 amendment's focus — an opinion that does not reliably apply the stated methodology to the facts, judged by a preponderance of the evidence.

Practical points for both sides:

• Science day matters. It is the court's education, and the side that teaches more clearly starts ahead.
• The literature is the record. Assemble and organize it early; both sides will litigate from the same set of studies for years.
• Regulatory history is evidence and is not dispositive. An agency's conclusion is admissible and persuasive; it does not answer the Rule 702 question, and it may cut both ways.
• Prepare for a split ruling. Courts frequently admit causation opinions for some injuries and exclude them for others, which reshapes the inventory rather than ending the case.

Part 7 — Bellwethers

If your case is selected, it becomes an individual case again, with full discovery, depositions of your client and their physicians, specific causation experts, and a trial date.

Selection strategy. Advocate for the process that suits your position: random selection produces representativeness; party picks produce outliers; stratified pools produce useful comparative data. Defendants generally prefer cases with alternative causes and weak damages; plaintiffs prefer strong causation and sympathetic facts. Courts increasingly resist both.

The Lexecon question. The MDL court cannot try a transferred case without consent. Decide deliberately whether to waive: waiving gives you a trial before a judge who knows the science, in a forum that may or may not favor you; declining means remand to the transferor court, with delay and a different jury pool.

What bellwether verdicts actually do. They price the litigation. Understand that your client's individual verdict — favorable or not — is being used by everyone as a data point, and prepare the client for that reality.

Part 8 — Settlement, and the obligations that come with it

Evaluate the structure, not just the number. Read: the matrix and its point values; the eligibility criteria and required proof; the participation threshold and the defendant's walk-away right; the appeal mechanism from a claims administrator's determination; the lien resolution program; the common benefit holdback; the timing of payments; and any release of unfiled or unknown claims.

Then do the arithmetic for a real client. Gross matrix award, less common benefit assessment, less your fee (frequently capped by the court below your retainer rate), less case costs, less liens after resolution. Present it that way, in writing.

The aggregate settlement rule is not optional. Model Rule 1.8(g) requires informed consent, in a writing signed by each client, after disclosure of the existence and nature of all claims involved and the participation of each person in the settlement. In practice:

• Each client must be told the total settlement, the matrix, their own allocation, and how others are being treated.
• Each client decides individually. You cannot decide for the inventory.
• You cannot agree in advance to recommend the settlement to all clients, and provisions requiring you to withdraw from representing non-participants raise serious conflict issues.
• Document the disclosure and the consent for every single client.

Plan for the client who declines. Their case continues, possibly toward remand and trial, and you remain their lawyer unless withdrawal is permitted and appropriate. Build that into your capacity planning before the settlement is announced.

Part 9 — Liens, funds, and administration

Start lien identification at intake, not at settlement. Medicare conditional payments, Medicaid, ERISA plans, TRICARE, VA, workers' compensation, hospital liens, and letters of protection.

Medicare under 42 U.S.C. § 1395y(b) requires conditional payment resolution and mandatory insurer reporting; a set-aside may be required where future care is anticipated.

Medicaid recovery is governed by Ahlborn, Wos, and Gallardo v. Marstiller, 596 U.S. 347 (2022), which permits recovery from amounts allocated to future medical expenses as well as past — making the settlement allocation a matter of real consequence.

ERISA plan reimbursement is governed by the plan document under McCutchen, with the tracing limits of Montanile.

Qualified settlement funds hold and distribute proceeds with defined tax treatment and allow lien resolution to proceed while payments are staged.

Screen for public benefits. A lump sum can terminate SSI and Medicaid eligibility; a special needs trust preserves both. See Special Needs Trusts and Medicaid Planning.

Part 10 — Remand, and the cases that do not settle

Section 1407 contemplates remand at the conclusion of pretrial proceedings, and the Panel remands on the transferee judge's suggestion.

What travels with the case: the common discovery record, the rulings on common issues, and the case-specific discovery. What does not: the MDL court's familiarity, and — importantly — the transferor court's own view of the case, which may differ.

Prepare for remand by ensuring case-specific discovery is complete, specific causation experts are disclosed and defensible under the transferor circuit's law (which may differ from the MDL circuit's), and the choice-of-law designation from the direct filing order is correct.

A candid note. Very few cases are actually remanded and tried. But the credible possibility of remand is what gives an individual plaintiff any leverage against a settlement matrix, and counsel who have prepared their strongest cases for remand negotiate from a different position than counsel who have not.

Part 11 — Running an inventory as a business

A firm with three hundred cases in an MDL is operating a production system, and the firms that do well treat it that way.

The intake gate. Every case should pass four screens before it is signed, and each is cheaper to run before signing than after:

1. Product identification. Is there a document that proves this person used or received this product? Pharmacy printout, implant card, operative report, purchase record, insurance claim history. If the answer is "the client says so," the case is not yet viable.
2. Qualifying injury. Does the diagnosis fall within the injury categories the litigation actually covers, established by a medical record rather than a client's description?
3. Timing. Does the exposure precede the injury by a plausible latency, and is the claim within the applicable limitations period — which is the transferor state's period, not the MDL forum's? See Statutes of Limitations, Accrual, and Tolling.
4. Alternative causes. Are there obvious confounders — smoking history, prior surgery, family history, a different product — that will defeat specific causation?

The records engine. Records are the rate-limiting step in every inventory. Build a process: authorizations signed at intake in the form the CMO requires; requests sent within seventy-two hours; a follow-up at thirty days and again at sixty; a vendor for high-volume collection; and a log showing, for each case, every provider, the date requested, the date received, and whether the production was complete.

The case management database. At a minimum, one row per case with: client, filing date, MDL docket number, transferor district designation, product ID status and source, injury category, fact sheet due and submitted dates, deficiency notices and cure deadlines, registry submission, lien types identified, and settlement status. Spreadsheets fail above roughly a hundred cases.

Client communication at scale. Clients in an MDL wait years with nothing visible happening, and the resulting frustration produces bar complaints and malpractice claims out of proportion to anything that went wrong legally. A quarterly written update — even one that says only that common discovery continues, that no trial date affects their case, and that no action is required of them — prevents most of it. Keep a record that it was sent.

Staffing. The work is paralegal-heavy and lawyer-light until settlement, at which point it inverts abruptly: several hundred individual informed-consent conversations, each documented, over a compressed period. Firms that have not planned for that surge handle it badly.

Part 12 — The defense inventory, from the other side

Defense counsel in an MDL run a parallel production system with different pressures.

Document infrastructure. A single, well-built document depository serving the MDL, the state court proceedings, and any government investigation avoids the most expensive failure mode in mass tort defense — producing inconsistent sets in different forums. Build the privilege log once, defensibly, with a Rule 502(d) order in place.

Witness management. The same corporate witnesses will be deposed repeatedly across proceedings over years. Prepare them once, thoroughly, with a consistent factual record, and track every prior transcript by topic so that testimony does not drift. Inconsistency across depositions taken three years apart is the most reliably damaging material a plaintiff's lawyer obtains.

Vetting as strategy, not complaint. The most effective defense posture on inventory quality is to seek an early census or fact-sheet order and enforce it, rather than to accumulate grievances and raise them at the settlement table when the denominator is already fixed. Vetting reduces the inventory, improves the accuracy of the reserve, and materially improves the eventual settlement economics.

Coordination with parallel proceedings. State court consolidations, government investigations, insurance coverage litigation, securities suits, and derivative actions frequently run alongside. A single coordinating counsel with visibility across all of them prevents the position taken in one from becoming the admission used in another.

Reserve discipline. For a public company, the litigation reserve is a disclosed number with securities implications, and it signals valuation to the plaintiffs' bar. Its timing and size are strategic decisions requiring counsel, finance, and auditors in the same room. See Securities Fraud Litigation Under Rule 10b-5.

And the settlement architecture is the defense's document. The participation threshold, the walk-away right, the release scope covering unfiled and future claims, the lien resolution program, and the claims administration process are all negotiated to purchase peace — and a settlement that does not actually end the exposure is worse than no settlement.

Part 13 — A first-ninety-days plan

For a lawyer whose cases have just been transferred into an MDL:

Week 1.

• Pull every case management order from the court's MDL page and read them in order.
• Build the deadline matrix: fact sheet dates, registry dates, records protocol requirements.
• Confirm whether direct filing is permitted and what transferor district designation applies to each case.
• Identify liaison counsel and get on the service list.

Weeks 2–4.

• Audit every case for product identification and qualifying injury. Close the ones that fail, in writing, with the client informed and the limitations consequences explained.
• Begin or complete records collection on the survivors.
• Set up the case management database.
• Send a client update explaining what an MDL is, what will happen, and how long it will take.

Weeks 5–8.

• Complete and serve fact sheets for the cases nearest their deadlines.
• Respond to every deficiency notice within its cure period.
• Identify lien types for each case and open the Medicare conditional payment process where applicable.
• If seeking a role, prepare a leadership or committee application addressing experience, capacity, and a specific proposed contribution.

Weeks 9–12.

• Attend or listen to the status conference; read the transcripts of prior ones.
• Review the common benefit order and set up time-recording in the required format if you hold a role.
• Calendar the next several months of MDL deadlines against your whole inventory.
• Confirm the retainer agreements in your inventory disclose the common benefit assessment and the possibility of a court-set fee cap.

Part 14 — Ten mistakes that damage MDL inventories

1. Filing cases without product identification. They will be dismissed, they damage credibility, and they depress settlement values for everyone.
2. Missing the fact sheet deadline or ignoring a deficiency notice.
3. Getting the transferor district designation wrong on a directly filed case, producing the wrong choice of law and the wrong remand venue.
4. Failing to calendar the transferor state's limitations period, which governs regardless of where the case is filed.
5. Recording common benefit time late, or blending it with individual work.
6. Not identifying liens until settlement, which delays every client's payment by months.
7. Failing to communicate with clients for years, which produces bar complaints unrelated to the merits.
8. Not reading the settlement documents before recommending them, particularly the release scope and the appeal mechanism.
9. Treating aggregate settlement consent as a formality. Rule 1.8(g) requires individual, informed, signed consent after disclosure of the whole picture, and it is the most commonly disciplined failure in this practice.
10. Having no plan for the client who declines the settlement, whose case continues and whose lawyer you remain.

Part 15 — Working with the state court proceedings

Most large mass torts run in federal MDL and in one or more consolidated state proceedings simultaneously. Ignoring the state side is a strategic error on both sides of the table.

Why state proceedings matter. They frequently reach trial first, because state consolidations do not carry the Lexecon problem and state dockets sometimes move faster. An early state verdict — in either direction — resets valuation for the entire litigation, including the federal cases. State courts may also apply different expert admissibility standards; a number of states have not adopted the federal Rule 702 framework, and a general causation ruling that goes one way in the MDL may go the other way in a state proceeding on the same science.

Coordination in practice is informal and depends on judicial cooperation: cross-noticed depositions so that a corporate witness is deposed once for both proceedings; a shared document depository; coordinated expert discovery; and, occasionally, joint status conferences between the federal and state judges. Leadership on both sides usually overlaps deliberately for this reason.

Common benefit across the divide. Whether an MDL common benefit assessment reaches cases resolved in state court, or resolved by counsel who never appeared in the MDL, is genuinely contested. Some transferee judges have asserted authority over funds passing through the settlement; others have not. Read the order, and if you have a mixed inventory, understand the assessment exposure on each case before you settle any of them.

Personal jurisdiction limits the state option. After Bristol-Myers Squibb Co. v. Superior Court, 582 U.S. 255 (2017), a state court generally lacks specific jurisdiction over the claims of non-resident plaintiffs who were not injured in the forum. Nationwide consolidated filings in a favorable state forum are therefore no longer available in the way they once were, and plaintiffs' counsel now file resident claims in state court and everything else federally.

Removal skirmishing. Defendants remove; plaintiffs move to remand. The recurring fights are fraudulent joinder of a non-diverse defendant (a local pharmacy, a sales representative, a treating institution), the CAFA mass action provision in 28 U.S.C. § 1332(d) when one hundred or more claims are proposed to be tried jointly, and the timing rules for removal after an amended pleading. Note that a remand motion pending when a conditional transfer order issues generally travels to the MDL judge to decide. See Removal and Remand.

Part 16 — Frequently asked questions from counsel

"My client's case was transferred and I've never practiced in this district. Do I need local counsel?" Check the MDL's initial order — most transferee judges waive local counsel requirements and admit counsel of record from transferred cases without a separate pro hac vice application. Confirm rather than assume, and get on the electronic service list immediately.

"Do I have to attend the status conferences?" Usually not, and most courts make transcripts or recordings available. Read them. The status conference is where the court signals what it expects next, and lawyers who are surprised by an order were usually not reading.

"Can I settle my individual cases outside the global settlement?" Sometimes, and the answer depends on the defendant's willingness and on whether the court's orders restrict individual settlements while a global process is pending. Common benefit assessments generally still apply. Be careful: an individual settlement negotiated for a strong case within a larger inventory raises the same aggregate settlement concerns if it is part of a bundled negotiation.

"What if I disagree with leadership's strategy?" Leadership owes duties to the litigation, not to you, and courts give it substantial deference. The available routes are participation in committee work, objections filed on the docket, and — rarely and reluctantly granted — a motion to opt a case out of some common process. Choose those fights carefully; credibility with the court is worth more than any single objection.

"How do I value my client's case before there is a settlement matrix?" You cannot, precisely. What you can do is know the injury category, the strength of product identification, the presence of alternative causes, and the bellwether results, and explain the range honestly rather than quoting a number you cannot support. Clients who were given a number early and a smaller one later account for a large share of the complaints in this practice.

"Should I take third-party funding?" It exists, it is common for inventory financing, and it carries real questions about privilege, work-product, control, disclosure obligations under some courts' standing orders, and the effect on client recovery. Read the term sheet with the same care you would give a client's settlement agreement. See Third-Party Litigation Funding.

"What is the single highest-value thing I can do with a new inventory?" Vet it. Product identification and qualifying injury, documented, on every case, before filing. Everything downstream — fact sheets, registries, Lone Pine orders, settlement eligibility — tests the same two facts, and the cases that fail were always going to fail.

Part 17 — A worked example: one firm, four years

Year 0. A twelve-lawyer plaintiffs' firm signs 240 clients on a hernia mesh device through referrals and advertising. Centralization is granted in month five.

What they do first. They read all thirty-one case management orders issued to date. They discover three things that change their plan: the direct filing order requires designating the district where each case would otherwise have been filed; the plaintiff fact sheet is due ninety days from filing with a fourteen-day cure period; and a records protocol requires operative reports and implant identification before the fact sheet will be deemed complete.

The vetting. They audit all 240 files against product identification and qualifying injury. Sixty-one fail — no operative report identifying the device, or an injury outside the covered categories. They close those files, in writing, explaining the limitations consequences and advising the clients to consult other counsel promptly. It is an uncomfortable month and it saves the firm two years of deficiency litigation.

The records engine. For the remaining 179, they send authorizations and requests within a week, log every provider, and follow up at thirty and sixty days. Average time to a complete set: seventy-one days. Eleven cases require subpoenas to hospitals that will not respond to authorizations.

Fact sheets. All 179 served on time. Nineteen deficiency notices, all cured within the window. Zero dismissals.

Year 2 — the census registry. The court orders registration of filed and unfiled claims with supporting product identification. Because the firm vetted at intake, registration takes three weeks. Firms that did not spend six months and lose cases.

Year 3 — general causation. The court admits plaintiffs' experts as to two injury categories, excludes them as to a third. Twenty-two of the firm's cases fall in the excluded category. They advise those clients in writing, explain the ruling and the appeal posture, and hold the cases pending resolution.

Year 4 — settlement. A four-tier matrix with adjustments for revision surgery, implant duration, and comorbidities. Participation threshold 93%. Common benefit holdback 9%. Court-set fee cap of 30% for individual counsel, below the firm's 40% retainer rate.

The settlement work. The firm runs 157 individual informed-consent conversations over ten weeks. Each client receives, in writing: the total settlement, the matrix, their tier and allocation, the common benefit assessment, the capped fee, itemized case costs, an estimate of lien repayment, and the projected net. Each signs an individual consent. Nine clients decline; those cases continue.

A representative client's arithmetic:

What made this go well. Vetting at intake. A records process that ran on a schedule. Fact sheets served on time with deficiencies cured. Quarterly client letters over four years. And a settlement process in which every client saw the whole picture before signing, which is what the rule requires and what prevents the complaints that follow the ones that do not.

Part 18 — Timing and budget expectations

Two observations. First, the aggregate is four to eight years, and an individual lawyer's cash flow over that period is entirely front-loaded on the plaintiffs' side — which is why capital, not skill, determines who can hold a leadership role. Second, the administration phase is routinely underestimated by both sides: lien resolution, appeals from claims administrator determinations, and distribution frequently take longer after the settlement is announced than the parties told their clients it would.

What to tell a client about timing, at intake. "This will likely take four to seven years. For most of that time, nothing will visibly happen in your case, and no action will be required of you beyond completing forms and providing records. Your case will very probably not be tried. It will most likely resolve through a settlement in which an amount is assigned based on your injury and circumstances, and you will decide individually whether to accept it." Every sentence of that is true, and saying it at the beginning prevents most of what goes wrong at the end.

Related documents

• Multidistrict Litigation and Mass Torts
• MDL Case Management and Bellwether Checklist
• Mass Tort and MDL Toolkit
• Class Actions Under Rule 23
• Expert Witnesses After the 2023 Amendment to Rule 702
• Product Liability for Manufacturers, Distributors, and Sellers
• Personal Injury Claim Toolkit
• Third-Party Litigation Funding
• Legal Ethics in Practice
• Attorneys Fees and Costs

This guide is educational and not legal advice. MDL practice is governed primarily by case management orders specific to each proceeding and by ethical rules that vary by jurisdiction. Read the orders in your MDL and consult qualified counsel.