Effective Co-Counsel at Your Finger Tips
Why Maddox & Cisneros
Maddox & Cisneros, PLLC, is Nevada’s premier co-counsel for originating attorney class action proceedings.
As the state’s top-tier class action firm, we have years of experience supporting originating counsel. We assist or lead, as needed, every step or the way, from case evaluation through settlement and fee applications. Below is a practical menu of “co-counsel services” we offer to other attorneys.
Front-end case development
- Substantive case evaluation: assessing merits, certification potential, damages modeling, defendant collectability, jurisdiction/venue strategy
- Statutory and regulatory issue-spotting: looking at CAFA, arbitration/FAA, preemption, choice-of-law, standing, cy pres, and so on
- Factual investigation and evidence preservation: document review plans, early custodial interviews, and data mapping
- Claim structuring and defendant mapping: direct vs indirect purchaser, consumer vs derivative claims, multi-defendant joint venture/cartel theories
Pleadings, motions, and certification
- Drafting and arguing high-stakes motions: Motions to Dismiss, to Compel Arbitration, to Strike Class Allegations, Daubert, summary judgment
- Designing and prosecuting the class certification strategy: class definition, subclasses, Federal Rule 23(a)/(b) theory, expert reports on predominance and damages
- Appellate-style briefing on dispositive or Federal Rule 23 issues: including interlocutory appeals and petitions such as Rule 23(f)
- Coordinating parallel state/federal filings: including tag-along actions and MDL transfer/centralization briefing
Leadership, coordination, and infrastructure
- Seeking and serving in court-appointed roles: interim or permanent Lead, Co-Lead, Liaison, Steering Committee, or Executive Committee on behalf of the group, while protecting originating counsel’s role and fee
- Building and managing plaintiffs’ leadership structures and work allocation protocols: law and briefing, discovery, experts, settlement, trial teams
- Liaison/administrative functions: docket management, agenda setting, joint status reports, centralized communications with court and defense counsel
- Coordination across parallel class and mass actions: including sharing work products and avoiding duplication or intra-plaintiff conflicts
Discovery, experts, and data management
- Designing and running large-scale written discovery: as well as ESI protocols and deposition programs, including 30(b)(6) and expert depositions
- Setting up and administering common databases and litigation-support platforms: document review systems, coding protocols, evidence repositories
- Retaining and managing experts: economists, statisticians, industry experts, survey experts, including report development and Daubert defense
- Handling third-party discovery and subpoenas: vendors, competitors, regulators in support of class-wide impact and damages
Settlement strategy and administration
- Leading settlement negotiations and mediations: including term sheet drafting and dealing with objectors and competing counsel
- Structuring class settlements: relief design, injunctive terms, allocation plans among subgroups, and/or release scope, with attention to intra-class conflicts and separate representation where needed
- Drafting settlement approval papers: preliminary/final approval, fee petitions, service awards, notice plans and then defending them upon appeal
- Overseeing claims administration and distribution: claims process design, fraud controls, cy pres, reversion risk, and then working with administrators
Trial and appellate work
- Taking lead or co-lead on class action trials: jury selection, trial themes, demonstratives, expert and fact witness examinations
- Developing trial packages that can be re-used in related or remanded cases: exhibit lists, witness kits, deposition designations
- Handling appeals and mandamus petitions on class certification, summary judgment, or settlement approval issues
Financial, risk-sharing, and consulting support
- Financing litigation expenses: experts, discovery vendors, administration costs and then sharing contingency risk consistent with ethics rules
- Transparent fee-sharing or referral arrangements that respect originating counsel’s client relationship and comply with jurisdictional rules
- Behind-the-scenes consulting for lawyers who want to remain lead on the docket: focus groups, mock arguments, jury consulting, demonstrative development, and intensive “workday” case-strategy sessions
- Ongoing education and co-branding opportunities: joint presentations, CLEs, co-authored client alerts to help referring counsel grow their own class practice
Our Approach to Class Representation
Maddox & Cisneros PPLC is structured around clear communication, disciplined case strategy, and meticulous case management, so referring counsel never gets left in the dark.
We start with a practical assessment of class viability in numerosity, commonality, predominance, and adequacy, and grounded facts. From there, we take responsibility for the tasks you wish for: pleadings, motion practice, discovery strategy, expert development, and class certification briefing, while coordinating with you on client‑facing decisions and litigation milestones.
We understand that your client relationships are your most valuable asset. Our team treats your clients and potential class representatives as partners in the prosecution. We take time to explain the process, expectations, and risks in plain language. We reduce friction, increase cooperation, and reflect well on the referring firm.
Mastery of Class Action Mechanics
- Drafting and refining complaints that frame both individual and class‑wide theories of liability.
- Navigating motions to dismiss and early dispositive challenges without sacrificing class allegations.
- Conducting targeted discovery that develops numerosity, typicality, and commonality while managing cost.
- Preparing and arguing motions for class certification, including managing evidentiary hearings and expert challenges.
- Structuring and documenting settlements that withstand judicial scrutiny and maximize class and client value.
We also handle the intensive logistics that overwhelm firms not set up for class practice: working with notice administrators, managing claims processes, dealing with objectors, and shepherding settlements through preliminary approval, notice, final approval, and distribution.
Protect and Enhance Referring Counsel’s Role
We know you are entrusting your client and your reputation. Our co‑counsel and referral arrangements are designed to:
Keep you actively involved in strategic decisions at the level you choose.
Ensure your clients recognize your role in identifying and pursuing the broader case.
Provide fair, transparent fee‑sharing consistent with ethical rules in your jurisdiction.
Class Action Settlements
Turning Individual Cases into Impactful Class Actions
When you see repeat patterns such as identical junk fees, recurring misrepresentations, uniform contract language, or systemic practices that keep showing up in your intakes, have us check for a viable class action hiding in what looks like “just another” individual case. Rather than walking away from small dollar claims or litigating them one by one, work with Maddox & Cisneros. We
- Evaluate whether a class vehicle is appropriate and economically sensible.
- Identify potential class representatives from your existing client base.
- Build a case that not only compensates your clients but also pushes the defendant to change its practices.
We are happy to informally consult about the pattern‑recognition stage, long before anything is filed, so you can advise your clients with confidence and without committing your firm to an unfamiliar litigation structure.
When your practice wants to expand reach or impact without reinventing your main focus and systems, Maddox & Cisneros, PLLC is ready to partner with you. We will handle the class mechanics and heavy lifting while you retain the trusted position with your clients.
Here’s what courts typically look for in allowing class action cases
Numerosity
Enough people are affected to make a class action lawsuit practical. This number might range between a few dozen up to thousands.
Commonality
Everyone’s claims are rooted in the same legal issues and facts. These issues might be about the same defective products, policies, fees, misrepresentations, or damages.
Typicality
The proposed class or group of people are representative of the same situation as the rest of the people in the group. The same kind of harm happened for the same reasons.
Adequate Representation
The plaintiffs and their lawyers for the group are able to fairly and adequately protect the interests of the entire class or group of people.