Case and claims selection, other first considerations
Forum selection
Class arbitration
Choosing the class definition
Drafting the complaint
Plaintiff's preliminary actions to protect the class
The defendant's response : preliminary motions, individual settlement offers, counterclaims, and more
Discovery
Representing the named plaintiff at deposition
Class certification
Appeals of certification rulings
Class notice
Negotiations and settlement
The court settlement approval process
Claims administration and distribution of benefits
The class action trial
Res judicata and collateral estoppel
Attorney fees
Federal Rules of Civil Procedure 23 and advisory committee notes
Federal class action legislation
Survey of state class action law : 2009
New NACA class action guidelines
Sample agreements with named plaintiffs, co-counsel
Sample complaints
Motion for remand under the Class Action Fairness Act
Multi-district litigation
Sample discovery
Sample response to defendant's motion to stay discovery
Sample pleadings to compel discovery
Sample motions and proposed orders for protection of class members' files
Defense communications with class members
Protective orders for confidential information
Trial plans
Requests for class certification
Appeals of certification rulings under Rule 23(f)
Challenges to Rule 68 offers of judgment
Rule 23(c) notice of certification
Sample jury charge in class action
Sample stipulations of proposed settlements
Rule 23(e) settlement notices
Cy Pres materials
Sample memoranda in support of approval of class settlement
Documents relating to objections to settlement
Attorney fee documents
Consumer class action web addresses
Finding pleadings, primary sources on the companion website.