Michelle Carroll
A claim inventory is not yet evidence.A mass tort portfolio can hold thousands of claimants and millions of pages of records. An intake statement repeated in a questionnaire, a fact sheet, and three later histories is still one statement. A pharmacy printout can stop months before the injury. An automated filter can merge two separate admissions into one. Strong claims sit unnoticed in weak cohorts while weak claims absorb time and money, and the defects surface at the worst moment: a deposition, a Daubert challenge, a bellwether pool, or a settlement audit.The Mass Tort Evidence Portfolio shows plaintiff and defense teams how to turn a claim inventory into tested, claimant-level evidence. Michelle Carroll, Founder and Chief Clinical Strategist of Lexcura Summit, draws on more than four decades in healthcare to apply the seven pillars of the Lexcura Clinical Intelligence Model to mass tort work: Record Integrity, Baseline Profiling, Imaging Analysis, Timeline Reconstruction, Standard of Care Review, Regulatory and Compliance Overlay, and Causation Mapping. Every finding is stated as Established, Supported but disputed, Inferential, or Unresolved, and every file receives a clear decision label, so counsel knows what to advance, what to develop, and what to stop.Inside, readers will find:How MDLs test claimant evidence: 28 U.S.C. 1407, new Rule 16.1, fact sheets, census orders, and Lone Pine ordersExposure proof from dispensing records, implant logs, and industrial hygiene dataBaseline, imaging, and timeline analysis that separates pre-existing risk from new injuryWhat FDA adverse-event data, recalls, and labeling can and cannot proveGeneral and specific causation and expert reliability under Rule 702 as amended in 2023Tiered intake, cohorts, outliers, bellwether selection, and settlement readinessQuality assurance and responsible use of technology and AIFour complete worked files: a drug claim with weak exposure proof, a hip implant with conflicting imaging, a toxic exposure with competing causes, and a strong claim hidden in a weak cohortReview protocols, checklists, a glossary, and a table of authoritiesWritten for mass tort counsel, MDL teams, legal nurse consultants, clinical reviewers, claims administrators, and experts, this book replaces page-volume thinking with a visible, reproducible method that keeps uncertainty in view and gives counsel evidence that can withstand scrutiny.Part of the Clinical Intelligence series by Michelle Carroll.
