Local Rule LR 23.2: Class Actions, Contents of Complaints

LR 23.2 Class Actions, Contents of Complaints. The complaint shall contain under a separate heading, styled "Class Action Allegations":

(a) A reference to the portion or portions of Fed.R.Civ.P.23 under which it is claimed that the suit is properly maintainable as a class action.

(b) Appropriate allegations thought to justify such claim, including, but not necessarily limited to:

(1) The size (or approximate size) and definition of the alleged class,

(2) The basis upon which the plaintiff (or plaintiffs) claims

(A) To be an adequate representative of the class, or

(B) If the class is comprised of defendants, that those named as parties are adequate representatives of the class,

(3) The alleged questions of law and fact claimed to be common to the class, and

(4) In actions claimed to be maintainable as class actions under subdivision (b)(3) of Fed.R.Civ.P.23, allegations thought to support the finding required by that subdivision.