Litigating a class action lawsuit is a daunting prospect, for class members and defendants alike.

Start with conducting an early evaluation of the claims and start an internal investigation in the course and scope of litigating the case. 

Maintain a privilege log for all documents assembled in anticipation for litigation, and assert your work product protections.

Hire consulting experts if needed to render opinions on the reasonableness of the claims and to evaluate the merits of the cause of action. 

Prepare a challenge to the certification of the class members in the action, and conduct reasonable investigation into the class members using third party social media sweeps, and other private surveillance.

After all of the necessary evidence and investigatory reporting has been assembled and reviewed, prepare a defense with articulable facts with the help of your counsel, and begin settlement negotiations with opposing counsel.