Drafts a federal or state court order certifying a class action under Rule 23. Triggers when formalizing class certification after a granted motion, drafting certification orders, or preparing rulings for appellate review. Covers Rule 23(a) findings, Rule 23(b) analysis, class definition, counsel appointment under Rule 23(g), and notice provisions.
Drafts a court order certifying a class action with appellate-ready analysis and clear administration guidance.
Each factor requires specific record citations (exhibit numbers, deposition pages, expert declarations):
Rule 23(a): Apply findings to each element with controlling circuit and Supreme Court authority. Key precedent:
Rule 23(b):
| Subsection | Required Showing |
|---|---|
| (b)(1) | Separate actions create incompatible standards or impair other members' interests |
| (b)(2) | Defendant acted on grounds generally applicable; injunctive/declaratory relief appropriate |
| (b)(3) | Common questions predominate + class action superior; address: (i) individual control interests, (ii) existing litigation, (iii) forum desirability, (iv) manageability |
Include: