If There Was Never a Real Plaintiff, No Discovery to Find a New One.

CVS Pharmacy, Inc. v. Superior Court, No. C077622 (D3 Oct. 15, 2015)

This case addresses if and when it is appropriate to permit pre-certification discovery to locate absent class members in a so-called “headless” class action. That is, a case where the court has determined that the original named plaintiff lacks standing the pursue the case on her own behalf.