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An order that certifies a class action must define the class and the class claims, issues, or defenses, and must appoint class counsel under Rule 23(g). Instant access to fillable Microsoft Word or PDF forms.Minimize the risk of using outdated forms and eliminate rejected fillings. Today, courts generally permit pre-certification communications and settlements with absent class members. This Certification of Counsel Upon Enrollment of Clients into the Settlement Program (the "Certification") is required pursuant to Section 16.2. You also can choose a private mediator. Both parties can hire a lawyer to advise them of their rights during mediation. Filing: If you are efiling any of these forms, you will need to "flatten" the form so it cannot be changed after you complete it. Filing: If you are efiling any of these forms, you will need to "flatten" the form so it cannot be changed after you complete it. 49 : No. 1 , Article 3.