A Checklist setting out issues a plaintiff should consider for proving a common law fraud claim (fraudulent misrepresentation or fraud by omission) under Massachusetts law. This Checklist explains the elements of a fraud claim and sets out the types of discovery requests that a plaintiff asserting a fraud claim should seek to prove those elements. It also sets out what discovery requests a plaintiff can expect to receive and provides guidance on the factors a court may consider when assessing the sufficiency of the plaintiff's fraud evidence during summary judgment or at trial.