Defense lawyers and insurers often treat this as a tool for finding inconsistencies, gaps, prior injuries, missed treatment, or anything else they can use to question credibility or reduce the value of a claim. In practice, a plaintiff fact sheet is a standardized written questionnaire, usually required in a mass tort, multidistrict litigation, or coordinated proceeding, that asks each injured person for core case information. It commonly covers identity, medical history, product use or exposure, dates of injury, treating providers, lost wages, and supporting records. It functions like streamlined discovery and is often served under a court order or case management order.

For an injured person, accuracy matters because the answers can be used much like sworn written responses. A fact sheet may be checked against medical records, pharmacy records, employment files, prior claims, and social media. If dates, symptoms, body parts, or treatment history do not match, the defense may argue lack of causation, challenge damages, or seek dismissal for noncompliance. In large cases, deadlines for submitting a complete fact sheet are often strict.

In New Mexico injury matters, the same practical risk exists even outside formal mass torts: incomplete records about treatment, wage loss, or prior conditions can affect settlement value. That can be especially significant after a motor vehicle crash because New Mexico's minimum auto liability limits are only 25/50/10 under NMSA 1978, Section 66-5-208, leaving little room for disputes over proof in a modest policy case.