What is the proper litigation plan for a class action?

Matters that may be covered in a proper litigation plan include: the manner in which class members will be identified if not known already; the particulars of the notice program, including a sample notice and how and where the notice will be [page289] published and made available to the public; how those who choose to opt out will be dealt with; the scheduling of times for delivery of such things as statements of defence, productions, delivery of expert reports and trial date; the method of communication with the class; the possibility of settlement; what will happen if the common issues are decided in favour of the class; the method for valuation of damages; the details of the process for distribution of the damage award; the use of claims forms or other procedures for the distribution; what will happen to any surplus funds; how insufficient funds will be dealt with; and how the individual issues will be dealt with: Poulin v. Ford Motor Co. of Canada, [2006] O.J. No. 4625, 35 C.P.C. (6th) 264 (S.C.J.), at para. 100.