Notice of Tag-Along Actions for Multidistrict Litigation
(MDL) (Federal)

Summary

This template is a Notice of Tag-Along Actions that can be filed before the Judicial Panel on Multidistrict Litigation (JPML). This template contains practical guidance and drafting notes. A “tag-along” action is one pending in a district court that involves common questions of fact with either: (1) actions in a pending motion to transfer to create an MDL, or (2) actions in an existing MDL. J.P.M.L. R. P. 1.1(h). File this notice if you or your client has a separate action under consideration for transfer to a related MDL or already transferred to the related MDL. J.P.M.L. R. P. 6.2(d), 7.1(a). However, if the potential tag-along action is filed in the transferee court—that is, the court to which the MDL has been assigned—you do not need to file this notice, but should simply request reassignment to the MDL judge pursuant to local rules. J.P.M.L. R. P. 7.2(a). All filings before the JPML must be electronically signed and filed by an attorney who has or will make an appearance in the case. J.P.M.L. R. P. 3.2(b)–(c). Do not serve courtesy copies of the Notice of Tag-Along Actions. J.P.M.L. R. P. 3.2(d). For more about the Multidistrict Litigation Process, see Motion for Multidistrict Litigation (MDL) Transfer: Seeking an MDL Transfer Checklist (Federal) and Multidistrict Litigation (MDL) Flowchart (Federal).