In any case sought to be maintained as a class action:
(a) The complaint shall bear next to its caption "Complaint -- Class
Action."
(b) The complaint shall contain under a separate heading, styled "Class
Action Allegations":
(1) A reference to the portion or portions of Federal Rule of Civil
Procedure 23 under which it is claimed that the suit is properly
maintainable as a class action.
(2) Appropriate allegations thought to justify such claim, including,
but not necessarily limited to:
A. the size (or approximate size) and definition of the
alleged class,
B. the basis upon which the plaintiff (or plaintiffs) claims,
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(i) to be an adequate representative of the class, or
(ii) if the class is comprised of defendants that those
named as parties are adequate representatives
of the class.
C. the alleged questions of law and fact claimed to be
common to the class, and
D. In actions claimed to be maintainable as class actions
under Federal Rule of Civil Procedure 23(b)(3),
allegations thought to support the findings required by
that subdivision.
(c) As early as practicable, and after considering the views of counsel, the
Court shall issue an order scheduling all proceedings relating to the
filing of the motion for class certification including, but not limited to,
class and related merits fact discovery, expert witness discovery, the
filing of the motion for class certification and responses, and, if
warranted, the convening of any hearing on the class certification
motion.
(d) The foregoing provisions shall apply, with appropriate adaptations, to
any counterclaim or crossclaim alleged to be brought for or against a
class.
