Local Rule LR 23.1: The Complaint

LR 23.1 The Complaint. In any case sought to be maintained as a class action, the complaint shall include next to its caption the legend, "Complaint-Class Action," and in its body, a separate heading styled "Class Action Allegations."

(a) The "Class Action Allegations" shall include a reference to the portions of Rule 23 of the Federal Rules of Civil Procedure under which the suit is brought as a class action.

(b) The "Class Action Allegations" shall also include appropriate allegations supporting entitlement to class relief, including but not limited to:

(i) the approximate size and definition of the alleged class,

(ii) the basis upon which the plaintiff (or plaintiffs) claims to be an adequate representative of the class, or if the class is composed of defendants, that those named as parties are adequate representatives of the class,

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

(iv) in actions claimed to be maintainable as class actions under subdivision (b)(3) of Rule 23 of the Federal Rules of Civil Procedure, allegations thought to support the findings required by that subdivision, and

(v) in actions requiring a jurisdictional amount, the basis of determining that amount.