Law360, New York ( November 10, 2014, 10:30 AM EST) -- Courts and practitioners have long used Lone Pine case management orders successfully to manage toxic tort and other putative class and mass actions.[1] Such orders often require plaintiffs to substantiate key aspects of their claims, either before general discovery has taken place or in the early stages of discovery process. In a recent published opinion, the Eleventh Circuit rejected a Florida's district court's use of a Lone Pine order to dismiss a class of plaintiffs. The Eleventh Circuit did not question the use of a Lone Pine order generally, but rather addressed the narrow issue of whether Lone Pine orders are appropriate before a district court has considered the adequacy of a plaintiff's complaint....