Mealey's (January 21, 2021, 1:55 PM EST) -- MIAMI — A borrower’s failure to satisfy the commonality requirement under Federal Rule of Civil Procedure 23(a)(3) and her failure to sufficiently plead that class certification is appropriate under Rules 23(b)(2) or 23(b)(3) are fatal to her motion seeking certification of two borrower classes in a lawsuit alleging that a loan servicer violated Florida law by charging convenience fees for making monthly mortgage payments over the phone and online, a federal judge in Florida ruled Jan. 19....