Final Settlement Approval

Draft Class Action Settlement Motions in Minutes

14 minutes with CaseMark

Run this workflow

Run it in CaseMark

Upload your documents and get a finished work product in minutes. New accounts get $5 free to run their first skill.

14 minutes with CaseMark

What you'll need

Executed Settlement Agreement
Preliminary Approval Order
Notice Materials & Claims Data

SOC 2 Type II · HIPAA compliant · $5 free credit

Workflow

Overview

This skill drafts a comprehensive Motion for Final Approval of Class Action Settlement under FRCP 23(e) or state equivalents. It produces a court-ready motion covering the full fairness analysis, procedural compliance documentation, notice adequacy, claims data, objection responses, and attorney fee requests—all tailored to your jurisdiction's controlling legal standards.

Drafting a motion for final approval of a class action settlement is one of the most document-intensive tasks in litigation. Attorneys must synthesize settlement terms, claims data, notice compliance records, objections, fee calculations, and multiple declarations into a single cohesive motion that satisfies jurisdiction-specific multi-factor tests. The process typically consumes days of attorney time and carries significant risk of omitting critical elements that could delay or derail court approval.

CaseMark automates the heavy lifting of final settlement approval motions by ingesting your settlement agreement, preliminary approval order, claims data, and supporting materials, then producing a structured, citation-ready motion. The AI identifies your jurisdiction's controlling fairness test, organizes the procedural history, analyzes notice compliance, drafts objection responses, and builds fee request sections—flagging any items requiring attorney verification so you can focus on strategy rather than assembly.

How it works

1. Upload your settlement agreement, preliminary approval order, notice materials, claims data, and supporting declarations
2. AI identifies the controlling fairness test for your jurisdiction and analyzes all settlement terms against multi-factor standards
3. Review the fully drafted motion with fairness analysis, notice compliance, fee requests, and flagged items requiring verification
4. Export the court-ready motion and supporting documents in your preferred format (DOCX, PDF)

What you get

Caption & Introduction
Procedural & Litigation History
Settlement Terms Summary
Fairness, Reasonableness & Adequacy Analysis
Notice Compliance & Claims Data Report
Objection & Opt-Out Analysis
Attorney Fees & Costs Request
Supporting Declarations Framework
Proposed Order for Final Approval

What it handles

Multi-factor fairness analysis tailored to your jurisdiction's controlling test
Automated procedural and litigation history narrative from docket entries
Notice compliance documentation with claims administrator data integration
Attorney fee and cost analysis using lodestar or percentage-of-fund methodology
Objection and opt-out rate analysis with substantive response drafting
Supporting declarations framework for class counsel, representatives, and administrators

Required documents

Executed Settlement Agreement
The fully executed settlement agreement including material terms, release provisions, and distribution methodology
.pdf, .docx
Preliminary Approval Order
The court's preliminary approval order with date, docket number, and any conditions imposed
.pdf, .docx
Notice Materials & Claims Data
Proof of notice dissemination, claims administrator reports, submission rates, and eligible class member data
.pdf, .docx, .xlsx

Supporting documents

Case Docket
Key filings, rulings, and discovery milestones with dates for the procedural history section
.pdf, .docx
Objection & Opt-Out Records
All filed objections, opt-out notices, counts, and substantive details
.pdf, .docx, .xlsx
Fee Records & Lodestar Data
Attorney time records, hourly rates, litigation costs, and any fee agreement terms
.pdf, .docx, .xlsx
Declarations
Draft or executed declarations from class counsel, class representatives, claims administrators, or experts
.pdf, .docx

Why teams use it

Reduce drafting time from days to minutes while maintaining the rigor required for fairness hearings

Ensure no critical element is missed with a structured workflow covering every component courts expect in final approval motions

Automatically apply the correct multi-factor fairness test for your jurisdiction with citations to binding authority

Generate consistent, professional declarations and supporting documentation that align with the motion's factual assertions

Questions

Which jurisdictional fairness tests does this skill support?

CaseMark identifies and applies the controlling multi-factor fairness test for your jurisdiction, including Churchill factors (Ninth Circuit), Girsh/Prudential factors (Third Circuit), and other federal and state equivalents. The AI flags any factors requiring additional verification against current circuit law.

Does the motion include attorney fee analysis?

Yes. CaseMark drafts a complete fee request section supporting either a lodestar analysis (with hours and rates) or a percentage-of-fund methodology, depending on your case. It also addresses litigation costs and cross-checks against benchmark percentages in your jurisdiction.

How does CaseMark handle objections and opt-outs?

CaseMark analyzes the objection and opt-out data you provide, calculates participation rates, categorizes objection themes, and drafts substantive responses to each objection. Low opt-out rates are highlighted as evidence of class support for the settlement.

Will the motion address CAFA compliance requirements?

Yes. CaseMark includes a CAFA compliance section addressing 28 U.S.C. § 1715 notice requirements when applicable, and flags any items that need verification to ensure all federal and state procedural prerequisites are met.

Can I use this for state court class action settlements?

Absolutely. While CaseMark defaults to FRCP 23(e) standards, it adapts the motion framework to state equivalents. You should specify your jurisdiction so the AI applies the correct procedural rules and fairness factors.

Does CaseMark generate supporting declarations?

CaseMark produces declaration frameworks for class counsel, class representatives, claims administrators, and experts. These include the key factual assertions needed to support the motion, which you can then finalize with declarants for execution.