In multidistrict litigation (MDL), two or more separate but
related cases are coordinated in a single proceeding for pretrial
purposes of discovery and motion practice. The MDL court and
parties often agree early in the litigation that plaintiffs will
file a master complaint, which contains allegations suitable for
adoption by reference in each individual case. Parties agree to
file a master compliant and a master answer because it is efficient
to do so. Otherwise, they would have to draft individual complaints
and answers in every case coordinated before the MDL – which
could require filing hundreds or thousands of pleadings.
Master pleadings promote judicial efficiency and economy. They
provide the MDL court with a summary of the claims and defenses,
and they alleviate the administrative burden of managing
potentially hundreds or thousands of individual complaints and
answers.
