E.D. La. LR 23.1

In any case sought to be maintained as a class action:

(A) The caption of the complaint must bear the designation, “Complaint-Class Action.” The

complaint must also:

1. Refer to the portions of FRCP 23 under which it is claimed that the suit is properly

maintainable as a class action;

2. Make allegations thought to justify the maintenance of the claim as a class action,

including, but not necessarily limited to:

a. the size and definition of the alleged class;

b. the basis upon which the plaintiff claims:

(i) to be an adequate representative of the class, or

(ii) if the class is composed of defendants, that those named are adequate

representatives of the class;

3. The alleged questions of law or fact claimed to be common to the class; and

4. In actions claimed to be maintainable as class actions under FRCP 23(b)(3),

allegations that support the elements required by that subdivision.

(B) In all civil actions in which a class action is pleaded, the party alleging the class action

must, at a time directed by the case management or scheduling order approved by the

court, move for class certification under FRCP 23(c)(1).

(C) The foregoing provisions apply, with appropriate adaptations, to any counterclaim or

cross claim alleged to be brought for or against a class.

(D) 1. Whenever a party or counsel seeks to prohibit another party or counsel from

communicating concerning a class action with any potential or actual class member not a

formal party to the action, he or she must file a motion that sets forth with particularity

the consequences that will result from such communication and the remedy sought.

2. To obtain an order prohibiting communication with class members, the movant must

establish a clear record reflecting:

a. specific consequences the motion seeks to prevent;

b. the need for the order, weighing the consequences sought to be corrected and

the effect of the order on the right of a party to proceed pursuant to Rule 23

without interference.

3. Any attorney who communicates with the class must preserve and retain a copy of all

communications that he or she has with any members of the class or potential class until

final conclusion of the action.