Who Are We Doing This For?

• Which best describes the primary claimant population you are referring right now? Options: Individual clients, Multiple unrelated individuals, A cohort from the same employer/site, Class or mass cohort, State Attorney General / public entity, Case screening firm / intake vendor, Other
• How were these referrals triggered (pick the single most important trigger)? Options: FDA safety communication, Product recall, Peer-reviewed epidemiology, Whistleblower disclosure, Media coverage, Direct client outreach, Other
• Who is the ultimate decision-maker for co-counseling or referral partnerships in your organization? Options: Lead trial partner, Managing partner, Claims committee, General counsel (state AG), Intake director, Other
• Roughly how many potential claimants do you expect to have in scope over the next 6–18 months? Options: 1–10, 11–50, 51–200, 201–1,000, 1,000+
• What confidentiality or information-sharing constraints apply to these referrals? Options: Full client consent available, Limited consent; need layered sharing, State AG protective order constraints, Vendor-screening NDAs only, Unknown / need to confirm

Tell Me About Today — How This Really Feels

• If you had to name the single biggest problem your clients face getting justice today, what would it be?
• How often have past referrals ended up in a global, discounted settlement that you felt undervalued individual claims? Options: Never, Rarely, Occasionally, Frequently, Almost always
• When cases stall for years with no interim recovery, how does that affect your willingness to refer new claimants? Options: Significantly reduces referrals, Somewhat reduces referrals, No change, Not sure
• Describe a recent referral or collaboration that felt mishandled: what happened and how did it impact client outcomes?
• Which failure modes have you actually experienced with past partners? (select all that apply) Options: High claimant attrition, Unclear fee splits at settlement, Case bundling that reduced individual value, Poor communication cadence, Inadequate expert support, Slow medical record retrieval, Other
• How does that experience make you feel when deciding whether to sign a new referral agreement? Options: Wary / guarded, Cautiously optimistic, Neutral, Eager to try new partners, Other

Where the Evidence Is Thin — What Keeps You Up at Night

• What single evidentiary gap do you think is most likely to derail the claims you’re bringing forward?
• Which medical record types are commonly missing or incomplete for your claimants? Options: Hospital records, Specialist notes (e.g., oncology, cardiology), Diagnostic imaging, Pathology reports, Primary care records, Occupational health records, Other
• How accessible are medical records for your clients right now? Options: Immediate access (authorizations in hand), Accessible but delayed (30–90 days), Difficult — frequent denials, Unknown / varies widely
• Do you currently have trusted expert witnesses in the relevant specialties, or will you need the firm to recruit them? Options: Trusted experts in-house/known, Need firm to recruit experts, Some experts known, some needed, Unsure
• How confident are you that the current clinical record will survive a Daubert-style challenge? Options: Very confident, Somewhat confident, Not confident, Don't know yet
• Tell us about one claimant whose file you think is strong evidence—what specifically in their records makes you optimistic?

When the Stakes Are Highest — What Would Success Really Look Like?

• If one outcome could define success for your clients, which would it be? Options: Individual trial wins, Substantial individual settlements, Injunctive or corrective action, Medical monitoring programs, Interim relief / quicker recovery, Other
• Rank the priorities for claimants in your cohort (select up to three). Options: Maximize monetary compensation, Preserve right to individual trials, Fast interim relief, Public accountability / deterrence, Medical monitoring / ongoing care, Avoid prolonged litigation
• What timeline would feel acceptable for meaningful interim outcomes before a final resolution (choose one)? Options: < 1 year, 1–2 years, 2–3 years, 3–5 years, > 5 years
• What early success signals would make you continue investing resources and client patience? (select all that apply) Options: Favorable expert reports, Successful Daubert defense, Interim settlement offers that respect individual values, Positive bellwether verdicts, Court-ordered disclosures that strengthen causation, Preservation of individual case rights
• How would you describe the emotional needs of your claimants during long litigation—what do they need most from counsel? Options: Clear communication, Interim financial assistance, Medical coordination, Fast answers on progress, Reassurance about fairness at settlement, Other

What Would Make Us a Partner You Trust?

• What would feel like an unacceptable surprise from a co-counsel relationship? Options: Opaque fee-sharing at settlement, Bundling cases without consent, Changing litigation strategy unilaterally, Poor claimant outreach, Breaching confidentiality, Other
• Which governance features are non-negotiable for you before signing on? (select all that apply) Options: Transparent fee-sharing formula, Joint decision committee, Preserved opt-out for individual trials, Regular reporting cadence, Dispute resolution clause, Data access controls, Other
• Which fee-sharing model do you prefer as a starting point for discussion? Options: Percentage split per case, Lump-sum referral fee, Sliding scale by outcome tier, Allocation tied to role (intake vs trial), Open to multiple models, Undecided
• How often and in what format would you expect updates on case development and finances? Options: Weekly written updates, Biweekly calls + dashboard, Monthly reporting, Quarterly summaries, Ad-hoc for milestones only, Other
• Describe a single trust-building action a firm could take in the first 30 days that would convince you they’re different.

Practical Readiness — Records, Funding, and Staff

• If we had to start active case development tomorrow, what one resource would be the bottleneck for you? Options: Signed authorizations, Medical record access, Funding for expert work, Local counsel availability, Client engagement/retention, Other
• How many signed authorizations or releases do you currently have available for rapid record pull? Options: None, Some (1–10), Moderate (11–50), Substantial (51+)
• Are claimants able and willing to attend local depositions and trial preparations if needed? Options: Yes, most can, Some can, Few can, Not sure
• What level of funding commitment would you expect from a co-counseling firm to feel confident in pre-trial development? Options: Full funding for expert and discovery, Shared funding model, Minimal funding (records only), Funding contingent on milestones, Undecided / need proposal
• How do you currently track intake and retention metrics, and what would you be willing to share to evaluate program health? Options: Automated dashboard exports, Manual spreadsheets, Verbal summaries only, Willing to create shared reports, Prefer not to share

Signals That Tell Us a Claim Is Bellwether-Ready

• What early-case characteristics have you seen that most reliably predict a bellwether-worthy matter?
• Which of these elements would you consider mandatory before elevating a case to bellwether consideration? Options: Complete medical records, Strong expert affirmation, Clear liability document trail, Consistent symptom chronology, Low risk of competing claims, Client willingness for trial
• How do you weigh representative sampling vs. selecting the strongest test-case when shaping bellwether strategy? Options: Choose strongest representative, Prioritize general representativeness, Blend both deliberately, Undecided / need guidance
• What red flags would immediately disqualify a case from bellwether selection? Options: Gaps in causation timeline, Unreliable medical documentation, Conflicting comorbidity issues, Weak expert support, High attrition risk, Client unwilling to testify
• Tell us about a bellwether that changed leverage positively or negatively—what signal shifted the whole case set?

Exit Triggers, Safeguards, and Interim Remedies

• Under what exact circumstances should a claimant be allowed to exit the program without penalty? Options: New settlement offer they reject, Loss of contact for 90+ days, Change in medical condition, Ethical conflict discovered, Court-ordered consolidation that alters rights, Other
• What interim remedies (if any) would you expect the firm to pursue while cases develop? Options: Pre-trial settlements for high-need claimants, Medical monitoring injunctions, Interim fee advances, Preservation orders, Early injunctive relief
• How should fee disputes be handled to avoid harming clients at settlement? Options: Pre-agreed formula + arbitration, Joint committee decision, Third-party mediator required, Court approval for allocations, Other
• What protections do you want to preserve for individual-case value during mass settlements? Options: Reserved opt-out rights, Case-level allocation methodology, Independent counsel review, Transparency in claim valuation, Other
• Describe a fair and workable process for resolving disagreements about whether a settlement preserves individual value.

Decision & Next Steps — How Do You Want to Move Forward?

• If everything we just discussed were addressed, how ready would you be to move to a mutual-commit discussion? Options: Ready now, Ready in 2–4 weeks, Need 1–3 months, Need more time / uncertain
• What specific documents or materials would you want us to review before a mutual-commit conversation? Options: Sample medical records, Client intake forms, Prior settlement agreements, Authorization templates, Screening reports, Other
• Who should be present from your side for a governance and commercial terms meeting? Options: Lead trial counsel, Managing partner, Claims committee member, Intake director, State AG deputy, Other
• What outstanding questions would you need answered to recommend this partnership to your clients or leadership?
• What’s the single best way for us to demonstrate short-term value in the next 30 days? Options: Deliver a prioritized list of bellwether candidates, Pull and share critical medical records, Provide a proposed fee-sharing term sheet, Run a small-sample causation assessment, Other

• Solution Experience — Pre‑Work & Diagnosis
• Representative Claimant Walkthrough — From Limited Capacity to Funded Case
• Expert Validation & Bellwether Design — Proof & Risk Mitigation
• Commercial Transparency & Case‑Value Preservation — Decision Session
• Validation, Mutual Commit & Pilot Agreement

• Define clear exit triggers and holdback rules to preserve individual claimant value.
• Customer to confirm any additional evidentiary leads or witnesses within 3 business days to refine expert scope.
• Jointly identify the bellwether selection pool criteria and threshold retention metrics.
• Evidentiary Gap Analysis for the Scenario
• Agree on an expert roster and engagement plan that proves causation pathways and survives Daubert scrutiny.
• Finalize bellwether cohort selection rules that create leverage without forcing unwanted global settlements.
• Define mitigation mechanisms for attrition and case-value erosion during litigation.
• Host to produce short bios, fee estimates, and availability windows for each proposed expert.
• Customer to confirm any objections to proposed experts or bellwether criteria within 4 business days.
• Draft a proposed escrow/holdback structure and distribution triggers tied to bellwether outcomes.
• Recap How Operations Protect Case Value
• Obtain provisional agreement on a transparent commercial and fee‑sharing template tied to case milestones.
• Agree governance and confidentiality controls that reassure referring counsel about bundling and opaque fees.
• Introductions & Objectives
• Host to draft a one‑page term sheet (commercial + governance + holdback template) reflecting the agreed examples.
• Customer to review and mark any non‑negotiables within 5 business days.
• Legal teams to be looped in to draft confidentiality and case‑handling protocol language.
• Review Diagnosis→Proof Findings
• Obtain explicit customer validation that the Solution Experience proved the agreed future state for their representative claimant.
• Secure mutual agreement on pilot scope, success metrics, and owners to proceed to Pre‑Deployment Readiness.
• Document any remaining open issues with owners and timelines for resolution prior to pilot launch.
• Execute or circulate the pilot term sheet and NDA/data access agreement to enable records retrieval.
• Schedule the Pre‑Deployment Readiness meeting and assign owners for each readiness item (data, funding, experts).
• Host to deliver a one‑page pilot KPI dashboard template to track intake, expert milestones, and retention metrics.
• Produce and record a one‑sentence current state that all participants agree describes their situation today.
• Quantify the consequence of the current state in operational terms (cost, time, risk).
• Agree a one‑sentence future state outcome we will prove during the Solution Experience.
• Confirm representative claimant and complete list of required materials for the walkthrough.
• Customer to deliver representative claimant dossier (intake form, available records, prior settlement notes) within 5 business days.
• Host to prepare a one‑page template showing how consequence (cost/time/risk) maps to measurable KPIs for the cohort.
• Schedule the Representative Claimant Walkthrough within 7–10 days after receipt of materials.
• Recap One‑Sentence Current/Future State
• Prove a clear, milestoneized path from intake to funded case development using the customer's own claimant data.
• Demonstrate the expert validation sequence and expected timelines/costs required for Daubert readiness.
• Show concrete mechanisms that prevent unwanted bundling and preserve individual claimant value.
• Host to produce a case development Gantt (milestones, owners, estimated costs) for the representative claimant.
• Metrics, SLAs, and Success Signals for Pilot
• Transparent Commercial Model Example
• Expert Roster, Roles, and Selection Criteria
• Present Representative Claimant Dossier
• Craft the One‑Sentence Current State
• Intake & Triage → Funded Development Timeline
• Quantify Consequence (Money/Time/Risk)
• Live Validation (Customer Confirmation)
• Mock Expert Report & Daubert Readiness Check
• Governance & Case‑Handling Protocols
• Define the One‑Sentence Future State
• Mutual Commit: Pilot Scope, Timeline, and Owners
• Expert Validation Path (Evidence to Opinion)
• Exit Triggers & Preservation Mechanisms
• Bellwether Cohort Design and Statistical Considerations
• Close & Next Steps
• Agree Representative Claimant and Required Data
• Mitigations: Attrition, Bundling, Interim Remedies
• Bellwether Strategy & Case‑Value Preservation
• Decision: Provisional Terms & Next Steps
• Decision Points & Validation Questions
• Validation Checkpoint
• Pre‑work, Roles, and Timing

• Collect and Process Plaintiff Intake Records
• Procure Complete Medical Records and Billing
• Summarize Medical Records into Medical Chronologies
• Retain and Manage Causation and Toxicology Experts
• Commission and Oversee Epidemiological Studies
• E-Discovery Processing, Review, and Production
• Draft and File Complaints, Pleadings, and Motions
• Conduct Fact and Expert Depositions
• Prepare and Try Bellwether Cases to Verdict
• Serve as Plaintiffs' Leadership in MDL Proceedings
• Negotiate and Structure Case-Wide Settlements
• Administer Settlement Allocation and Distribution
• Provide Litigation Financing and Expense Advances
• Implement Confidentiality and Privilege Redactions

Collect and Process Plaintiff Intake Records

• What are the primary intake sources we should expect (select all that apply)? Options: Referring attorneys, Direct claimant outreach, Screening firms/call centers, State AG intake, Online forms/ads, Other
• Estimated number of claimant files to intake during the initial intake window (6-18 months)? Options: Less than 100, 100-500, 500-1,000, 1,000-5,000, More than 5,000
• What intake data elements are required for each record (e.g., demographics, product exposure dates, treating providers)?
• Are executed retention/representation agreements and HIPAA authorizations already collected? Options: Yes, for most files, Partially – some files, No, not collected
• Do you require intake-level screening for fee-sharing transparency and referral conflicts? Options: Yes, No, Partial — only for referral attorneys
• Preferred intake processing cadence and SLA for triage (e.g., 48 hours, weekly batch)? Options: 48 hours, 72 hours, Weekly, Bi-weekly, Other

Procure Complete Medical Records and Billing

• Which categories of medical documentation must be obtained for each claimant? Options: Hospital records, Primary care & specialists, Surgical records, Diagnostic imaging, Pharmacy/medication records, Billing/EOBs
• Are HIPAA authorizations and provider release forms available for record retrieval? Options: Yes – executed and valid, Some executed, some missing, No – need assistance obtaining
• Preferred approach for record retrieval? Options: Request letters and subpoenas, Third-party retrieval vendor, Direct EHR portal access, Combination
• What time range of records is relevant (e.g., onset to present, last X years)? Options: Onset to present, Last 2 years, Last 5 years, Custom — specify in comments
• Estimate total pages or GB per case for planning retrieval and OCR processing. Options: <500 pages, 500-2,000 pages, 2,000-10,000 pages, >10,000 pages, Unknown
• Are billing / EOB / charge data required for causation or damages analysis? Options: Yes — required, Optional — preferred, No

Summarize Medical Records into Medical Chronologies

• What level of medical summary do you need per case? Options: High-level timeline (key events), Detailed chronological narrative, Problem-list with citations, Custom template
• Which fields should be included in each chronology (e.g., diagnosis dates, procedures, providers, causation notes)?
• Desired turnaround time per case for an initial chronology? Options: 48-72 hours, 1 week, 2 weeks, Custom
• Do you require coding or mapping to standardized terms (ICD, CPT, SNOMED)? Options: Yes, No, Only for selected cases
• Preferred deliverable format for chronologies (select all that apply). Options: Word narrative, Structured spreadsheet, Database record / CSV, PDF summary, Other
• Do you want expert-ready excerpts/highlighted pages attached to chronologies for fast review? Options: Yes — include key exhibits, Optional — case-by-case, No

Retain and Manage Causation and Toxicology Experts

• Which expert specializations are needed initially? Options: Toxicologists, Clinical specialists (e.g., cardiology, neurology), Pharmacologists, Epidemiologists, Occupational medicine, Other
• Are there pre-identified experts or a preferred roster we should engage first? Options: Yes — roster provided, No — recruit de novo, Open to both
• What is the expected timeline from engagement to report for a retained expert? Options: 2-4 weeks, 4-8 weeks, 8-12 weeks, Custom
• Do experts need Daubert/prejudice readiness assessments before retention? Options: Yes — mandatory, Optional — case-dependent, No
• Is there a budget range per expert opinion we must observe? Options: <$10k, $10k-$25k, $25k-$50k, >$50k, Flexible
• Do you require management services (scheduling, invoices, conflict checks) or only retention introductions? Options: Full management, Introduction + negotiation, Introduction only

Commission and Oversee Epidemiological Studies

• What study designs are you considering to support causation? Options: Case series, Case-control, Cohort, Cross-sectional, Systematic review/meta-analysis, Other
• Are there existing datasets or registries we should leverage? Options: Yes — details available, No — need to source, Unknown
• Target primary endpoints or outcomes the study must address (e.g., diagnosis incidence, severity metrics).
• Expected timeline and milestones for the study (draft protocol, data collection, interim analysis)? Options: 3-6 months, 6-12 months, 12-24 months, Custom
• Is IRB review or patient consent required for the proposed work? Options: Yes — IRB required, No — de-identified data only, Unsure — need guidance
• What is the available budget range for epidemiological work and ongoing oversight? Options: <$50k, $50k-$200k, $200k-$500k, >$500k

E-Discovery Processing, Review, and Production

• What types of ESI/data sources are anticipated (select all that apply)? Options: Email, Documents (share drives), Databases, EHR/EHR extracts, Text messages/mobile, Cloud apps (Slack, Teams)
• Estimated volume of ESI for initial custodian set? Options: <100 GB, 100-500 GB, 500 GB-2 TB, >2 TB, Unknown
• Would you like near-duplicate detection, TAR/ML-assisted review, or manual linear review? Options: TAR/ML-assisted, Near-duplicate + sampling, Linear manual review, Combination
• Preferred production format and load file standard (e.g., TIFF/OPT, native, CSV, Concordance)? Options: Native + metadata, PDF/TIFF + load file, CSV/CSV with links, Other
• Do you require privilege/redaction workflows and privilege log generation? Options: Yes — full workflow, Limited — high-level, No
• Are there security/compliance requirements for ESI hosting (e.g., FedRAMP, SOC2)? Options: SOC2, FedRAMP, State AG standards, No special requirements, Other

Draft and File Complaints, Pleadings, and Motions

• What jurisdictions or courts are potential filing targets? Options: State courts, Federal district courts, MDL/JPML, Special tribunals/regulatory
• Do you have a preferred pleading strategy (e.g., consolidated complaints, tag-along individual complaints)? Options: Consolidated class/MDL complaint, Individual complaints with coordinated strategy, Hybrid
• Are short-fuse filing deadlines or statute concerns present for any claimants? Options: Yes — specify in comments, No, Unknown
• What supporting evidence should accompany initial filings (medical chronologies, expert declarations, studies)?
• Do you require assistance with local counsel identification or pro hac vice management? Options: Yes — identify and manage, We have local counsel, No
• Preferred timeline from complaint drafting to filing? Options: 2 weeks, 4 weeks, 6-8 weeks, Custom

Conduct Fact and Expert Depositions

• Estimated number of fact and expert depositions anticipated in first phase? Options: 0-10, 10-25, 25-50, 50+
• Do you prefer in-person depositions, remote (video), or a hybrid approach? Options: In-person, Remote, Hybrid
• Who will manage scheduling, subpoena service, and locale logistics? Options: We need full support, We will manage scheduling, Split responsibilities
• Are demonstrative exhibits or expert report bundles required for each deposition? Options: Yes — standardized bundle, Case-by-case, No
• What are your budget or travel constraints for deposition witness appearances? Options: Low — minimal travel, Moderate — regional travel ok, Flexible
• Do you require deposition transcripts, rough read, or expedited delivery? Options: Standard transcript, Expedited same-day page, Rough read only, Other

Prepare and Try Bellwether Cases to Verdict

• How many bellwether trials do you anticipate conducting in the initial wave? Options: 1, 2-3, 4-6, More than 6
• What criteria should be used to select bellwether cases (medical clarity, demonstrative evidence, jurisdictional fit)?
• Do you require trial-ready bundles (expert reports, demonstratives, witness prep) prepared by the vendor? Options: Yes — full trial bundles, Partial — select cases, No
• Preferred timeline from bellwether selection to trial readiness? Options: 3 months, 6 months, 9-12 months, Custom
• What is the acceptable budget range per bellwether trial (including expert costs and trial support)? Options: <$250k, $250k-$500k, $500k-$1M, >$1M
• If a bellwether verdict is unfavorable, what are the pre-defined fallbacks or exit triggers? Options: Reassess study design, Pause further trials, Pursue settlement talks, Other — specify

Serve as Plaintiffs' Leadership in MDL Proceedings

• Are you seeking a formal leadership role (PSC/PSC co-chair) or support/advisory participation? Options: Formal leadership, Co-lead/shared leadership, Advisory/support role, No leadership role desired
• Do you have conflicts or case-specific exclusions that would limit leadership responsibilities? Options: Yes — provide details, No
• What governance model do you prefer for the plaintiff leadership team (voting rules, transparency, subcommittees)?
• What staffing levels and skillsets should leadership commit (liaison counsel, discovery leads, experts coordinator)?
• Are there reporting or meeting cadence expectations for leadership (weekly touchpoint, monthly report)? Options: Weekly, Bi-weekly, Monthly, Ad-hoc
• Do you require assistance preparing leadership credential packages or PSL motions? Options: Yes — full support, Partial assistance, No

• Non-Disclosure Agreement (NDA)
• Statement of Work (SOW)
• Fee-Sharing & Allocation Agreement
• Case-Handling Protocol
• Governance & Steering Committee Charter
• Data Access & Security Addendum
• Funding & Advance Agreement
• Escrow / Settlement Trust Agreement
• Exit Triggers & Termination Terms
• Conflicts & Compliance Certification
• Expert Retention & Cost Allocation Addendum
• Bellwether & Trial Selection Protocol
• Settlement Approval & Distribution Protocol
• Dispute Resolution & Arbitration Clause
• Insurance & Indemnity Terms
• Signatures & Authorized Representative Form
• Timeline & Milestones Appendix

• Post-Bellwether Litigation Outcomes Review
• Settlement Allocation & Fee-Sharing Workshop
• Individual-Case Value Preservation & Exit Trigger Review
• Shared Governance & Issue Escalation Standing Meeting
• Final Settlement Readiness & Distribution Planning

• Maintain timely escalation paths to resolve cross-party disputes.
• Engage an independent auditor/neutral to review allocation methodology if requested by stakeholders.
• Current Retention & Bundling Practices
• Lock in exit triggers and contractual protections that preserve individual-case value.
• Produce an operational SOP that implements valuation thresholds and notification flows.
• Assign accountable owners for monitoring and executing preservation controls.
• Agree interim-recovery mechanisms to deploy if full settlement is delayed.
• Draft a 'Case Preservation SOP' including exit triggers, checklist, and notification templates for counsel and claimants.
• Create a prioritized list of claims meeting high-value thresholds for special handling.
• Implement a tracking field in the claims database for preservation status and trigger events.
• Opening & Protocol Reminder
• Keep a shared, single source of truth for issues and their remediation status.
• Approve priority continuous-improvement pilots with owners and timelines.
• Ensure transparency on risks that could materially affect settlement value or timelines.
• Opening & Objectives
• Update the shared issue tracker with current statuses and owners after the meeting.
• Launch one prioritized CI pilot (e.g., faster medical-record turnarounds) and report KPIs at next meeting.
• Produce a short risk-mitigation memo for any newly escalated material risks.
• Recap Settlement Terms & Approvals
• Certify that all operational, legal, and financial prerequisites for distribution are satisfied.
• Finalize the distribution timeline, reserve strategy, and administrator assignments.
• Approve claimant communications and the appeals/dispute process to reduce downstream litigation risk.
• Define post-distribution monitoring metrics and ownership to capture lessons and flag anomalies.
• Prepare and distribute the final distribution spreadsheet and reconciliation checklist to all governance parties.
• Finalize claimant notices, FAQs, and schedule the communication send date.
• Confirm reserve fund amount and transfer instructions to the escrow administrator.
• Ensure all parties share a single factual account of bellwether results and their legal import.
• Decide the short-term litigation posture and which scenario to pursue.
• Assign accountable owners for executing the agreed next steps within defined timelines.
• Surface any data or expert gaps that require immediate remediation.
• Produce a one-page outcome memo summarizing bellwether findings, legal impact, and recommended posture.
• Run and circulate updated financial/timeline scenario models with sensitivity to attrition and adverse outcomes.
• Compile and distribute redacted expert excerpts that were determinative at bellwether for referencing in future filings.
• Context & Constraints
• Select a primary settlement-allocation model and one fallback approach for negotiations.
• Agree on a clear fee-sharing structure and disclosure process acceptable to referring counsel.
• Identify any unresolved legal or ethical constraints requiring outside counsel or court input.
• Define a short list of data points needed to finalize allocation calculations.
• Build allocation calculator templates for the chosen models and apply them to the current claims sample.
• Draft a settlement-allocation & fee-sharing term sheet and circulation plan for referring counsel approval.
• Bellwether Results Summary
• Define Exit Triggers & Protective Clauses
• Allocation Models Overview
• Distribution Mechanics & Timeline
• Open Issues Triage
• Fee-Sharing Frameworks & Transparency Mechanisms
• Interim-Remedy & Interim Recovery Options
• Claims Validation & Documentation Checklist
• Causation/Daubert Impact Analysis
• Risk Register Update
• Dispute Resolution & Governance Protections
• Case Valuation Checklist & Thresholds
• Continuous Improvement Proposals
• Tax, Lien Resolution & Regulatory Steps
• Claimant Pool Metrics & Attrition
• Operational Controls & Notification Flow
• Validation Scenarios & Stakeholder Walkthrough
• Financial & Timeline Scenarios
• Communications Plan & Notice Materials
• Operational Metrics Review