Try Para
← All workflows

Class Certification Motion

Draft Class Certification Motions in Minutes, Not Days

14 minutes with Para

Explore this workflow

Get started with Para

Para is an AI colleague for legal teams. Send it this work by email, Teams or Slack, and it hands back the finished document.

14 minutes with Para

What you'll need

  • Pleadings
  • Discovery Materials
  • Expert Reports & Declarations

Plans from $20 a month, with usage included.

Workflow

Overview

CaseMark's Class Certification Motion skill transforms your case materials into a comprehensive, evidence-grounded FRCP 23 motion ready for judicial scrutiny. The AI analyzes pleadings, discovery, expert reports, and depositions to construct rigorous arguments across every certification factor, complete with record citations and preemptive defense rebuttals.

Drafting a class certification motion is one of the most labor-intensive tasks in complex litigation. Attorneys must synthesize thousands of pages of discovery, expert analyses, and depositions into a cohesive brief that rigorously addresses every Rule 23 factor while preempting defense attacks—a process that often consumes weeks of attorney time and significant firm resources.

CaseMark automates the heavy lifting of class certification drafting by ingesting your entire case file and producing a structured, evidence-supported motion in minutes. The AI identifies the strongest arguments for each certification factor, drafts an administrable class definition, and builds preemptive rebuttals—letting attorneys focus on strategy and refinement rather than document assembly.

How to hand this to Para

  1. 1. Send Para the files

    Email them, drop them in a Teams or Slack message, or upload them.

  2. 2. Para runs the Class Certification Motion skill

    It works from your files and checks its citations against the record.

  3. 3. The finished document comes back

    Para returns it where you asked, usually as a DOCX, and offers the next step.

Example request · email, Teams or Slack
Para, run the Class Certification Motion skill for the Garcia matter. I've attached the Pleadings, Discovery Materials and Expert Reports & Declarations. Send the finished draft back here as a DOCX.

What Para does

  1. 1. Upload your pleadings, discovery materials, expert reports, declarations, and deposition transcripts
  2. 2. AI analyzes your case file to identify the uniform policy, class scope, and supporting evidence for each Rule 23 factor
  3. 3. Review and customize the fully drafted motion with record citations and preemptive defense rebuttals
  4. 4. Export the polished motion in your preferred format (DOCX, PDF)

What you get

  • Introduction & Proposed Class Definition

  • Rule 23(a) Prerequisites Analysis

  • Rule 23(b) Certification Arguments

  • Defense Rebuttal Section

  • Notice & Administration Plan

  • Conclusion & Proposed Order

What it handles

  • Precise class definition drafting tied to liability theory

  • Full Rule 23(a) analysis covering numerosity, commonality, typicality, and adequacy

  • Rule 23(b) subsection briefing with predominance and superiority arguments

  • Preemptive rebuttal of anticipated defense arguments with record citations

  • Notice and administration plan with case management recommendations

  • Evidence-grounded arguments drawn directly from uploaded case materials

Required documents

  • Pleadings

    Complaint, answer, and any amended pleadings establishing the claims and defenses at issue

    .pdf, .docx

  • Discovery Materials

    Interrogatory responses, document productions, RFAs, and defendant business records showing scope of conduct

    .pdf, .docx

  • Expert Reports & Declarations

    Expert reports with damages models, statistical analyses, and named plaintiff declarations

    .pdf, .docx

Supporting documents

  • Deposition Transcripts

    Transcripts of named plaintiff, corporate designee, and key witness depositions

    .pdf, .docx, .txt

  • Class Counsel Qualifications

    Attorney CVs, firm resumes, and documentation of prior class action experience and resources

    .pdf, .docx

  • Prior Court Orders

    Relevant scheduling orders, discovery rulings, or prior certification decisions in related cases

    .pdf, .docx

Why teams use it

Dramatically reduce the time spent drafting complex class certification briefing from days to minutes

Ensure no Rule 23 factor is overlooked with systematic coverage of numerosity, commonality, typicality, adequacy, predominance, and superiority

Strengthen your motion with AI-identified evidence and record citations pulled directly from your uploaded case file

Proactively address defense challenges with built-in rebuttal sections grounded in case-specific facts

Questions

Does CaseMark handle both federal FRCP 23 and state class certification standards?

Yes. CaseMark's class certification skill is designed to draft motions under FRCP 23 as well as state equivalents. The AI adapts its analysis framework to match the applicable procedural rules based on your case materials.

How does the AI construct the Rule 23(a) arguments?

CaseMark extracts evidence from your uploaded discovery materials, expert reports, and depositions to build arguments for numerosity, commonality, typicality, and adequacy. Each factor is supported with specific record citations drawn from your case file.

Can the motion address anticipated defense arguments?

Absolutely. CaseMark identifies common defense challenges to class certification—such as individualized issues, atypicality, or manageability concerns—and drafts preemptive rebuttals grounded in your case record.

What types of documents should I upload for the best results?

For optimal output, upload your complaint and answer, discovery responses and document productions, expert reports with damages models, deposition transcripts of named plaintiffs and corporate designees, and named plaintiff declarations. CaseMark produces stronger motions with more comprehensive case files.

Does the AI draft a proposed class definition?

Yes. CaseMark drafts a precise, administrable class definition tied to your liability theory, incorporating temporal scope, geographic boundaries, and objective membership criteria that require no individualized inquiry.

How long does it take to generate a class certification motion?

CaseMark typically generates a comprehensive draft class certification motion in approximately 14 minutes, compared to the days or weeks this complex briefing traditionally requires. You can then review and refine the output before filing.

Related

30b6 Corporate Rep

Master 30(b)(6) Depositions in Minutes, Not Hours

30b6 Deposition

Master 30(b)(6) Depositions in Minutes, Not Hours

Abstract of Judgment

Draft Judgment Abstracts in Minutes, Not Hours