Compilation and Analysis of Plaintiff Medical Records

We constructed a comprehensive plaintiff database to permit statistical analysis of thousands of plaintiffs’ medical records. We developed a medical-data input sheet to permit systematic compilation of relevant data from the plaintiff medical files, compared these data to plaintiffs’ self reports, and found consistent overstatement in the nature and extent of injury. In addition, we assessed the extent to which preset causation criteria (e.g., injury occurring within window following last known use of drug) agreed to by defendant and plaintiff counsel, were present in the plaintiff medical records. This data set also formed the basis for our projections of the likely number of different types of adverse drug-related events in the entire population.