23.1 Class Actions

(a) Designation

Any filing asserting a class action shall include the words "Class Action" in the title.

(b) Settlements

(1) Form and Filing of Proposed Settlement

Any proposal to dismiss or compromise a class action shall be signed by a representative of each party and filed with the court. The proposal shall be entitled "Proposed Class Action Settlement."

(2) Joint Motion for Preliminary Approval and Proposed Notice Order

The parties shall file a motion entitled "Joint Motion for Preliminary Approval of Proposed Class Action Settlement" with the proposed settlement.  A proposed notice order and samples of all proposed notices shall be submitted with the motion.  The proposed notice order shall:

(A) state that the court has preliminarily approved the proposed settlement;

(B) describe the form, manner, and time by which the class shall be notified of the proposed settlement and the time by which any objections to the proposed settlement shall be filed with the court;

(C) stay the entry of final judgment until the time for class members to file objections to the proposed settlement has expired; and

(D) establish a date and time for a hearing to determine whether the proposed settlement should be approved.

(3) Joint Motion for Final Approval and Proposed Order

The parties shall file a motion entitled "Joint Motion for Final Approval of Proposed Settlement" and a proposed order directing the entry of judgment no later than thirty (30) days prior to the final approval hearing.  The proposed order shall:

(A) identify the date of the court's preliminary approval of the consent decree;

(B) identify the date by which class members were required to file any objections to the proposed settlement;

(C) identify the date of the final approval hearing;

(D) state that the court has considered any objections that have been raised to the proposed settlement;

(E) state that the court has determined that the settlement is fair, reasonable, and  in the best interests of the class; and

(F) state that the court has approved the proposed settlement.

(4) Motion for Attorney's Fees

Plaintiff's counsel shall file a motion for attorney's fees and costs seeking court approval of any fees or costs to be paid from settlement proceeds no later than thirty (30) days prior to the final approval hearing.