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.
LOCAL RULES for the SOUTHERN DISTRICT of GEORGIA
Page 23 of 60
Rev. June 2016
