Calculate deadlines for multi-district litigation (MDL), class actions, mass torts, and complex federal litigation with specialized case management procedures.
Complex litigation or MDL proceeding deadline
Federal CourtsMotion for MDL coordination/transfer
120 daysFrom initial complaint filing (typical)
Rule 23 class certification
As soon as practicableAfter adequate investigation under Rule 23
Test case trial preparation
Court-orderedPer case management order timeline
Settlement facilitation reporting
As orderedPer court's case management schedule
Complex litigation requires comprehensive early case assessment including potential for coordination, class certification viability, and MDL transfer likelihood. Develop coordinated defense strategies early to avoid inconsistent positions across jurisdictions.
Seek appointment to leadership positions in MDL or class action proceedings to influence case direction and strategy. Coordinate with co-counsel to present unified positions and avoid duplicative discovery requests.
Bellwether trials serve as key settlement drivers in complex litigation. Carefully select representative cases, develop trial strategies that account for broader implications, and use results to inform settlement negotiations.
Complex litigation often resolves through global settlements requiring coordination among multiple parties and potentially competing interests. Consider allocation mechanisms, opt-out rights, and fairness standards early in settlement discussions.
Determine the type of complex litigation: MDL proceedings, class action certification, mass tort coordination, or complex commercial litigation.
Input the date of case management orders, MDL transfer, class certification motion, or other key procedural events in complex litigation.
Consider unique complex litigation procedures including MDL rules, class action requirements, and specialized case management protocols.
Account for coordinated discovery, joint filings, leadership appointments, and other multi-party litigation management requirements.
Apply court-ordered deadlines for bellwether trials, motion practice, expert discovery, and other complex litigation milestones.
Track settlement negotiation deadlines, allocation procedures, and other resolution mechanisms common in complex litigation.