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Endress v. Gentiva Health Services, Inc.

Citations: 278 F.R.D. 78; 2011 WL 5220475Docket: Nos. 10-CV-5064 (ADS)(WDW), 11-CV-4433 (ADS)(AKT), 11-CV-4906 (ADS)(AKT), 11-CV-05126 (ADS)(WDW), 11-CV-05199 (ADS)(AKT)

Court: District Court, E.D. New York; November 2, 2011; Federal District Court

Narrative Opinion Summary

The case involves a series of consolidated securities fraud class actions against Gentiva Health Services, initiated by Steve Endress and followed by other plaintiffs, alleging fraudulent billing practices that inflated stock prices. These actions, including those filed by the Minneapolis Police Relief Association (MPRA), Cement Masons, International Union, Arkansas, and Dahlgard, sought to address alleged misconduct under Section 10(b) and Section 20(a) of the Securities Exchange Act of 1934. The court addressed procedural matters related to consolidation and the appointment of a lead plaintiff under the Private Securities Litigation Reform Act (PSLRA). Endress's motion to withdraw as a named plaintiff was granted, and the court consolidated the actions under a single docket number, recognizing the identical legal issues and common class period. The court also considered motions for lead plaintiff status, emphasizing compliance with the PSLRA's procedural requirements, and allowed additional class members to apply for lead plaintiff status following Endress's withdrawal. The MPRA's prior timely motion and subsequent renewal were deemed sufficient for eligibility, despite opposition from other plaintiffs. The court established a new schedule for lead plaintiff applications, aligning with the PSLRA's intent to ensure genuine representation for the class.

Legal Issues Addressed

Consolidation of Actions under Federal Rule of Civil Procedure 42(a)

Application: The court consolidated five securities class actions against Gentiva Health Services due to overlapping legal and factual issues to conserve judicial resources.

Reasoning: Federal Rule of Civil Procedure 42(a) allows a court to consolidate actions involving common questions of law or fact to promote judicial efficiency and reduce unnecessary costs or delays.

Lead Plaintiff Appointment under the PSLRA

Application: The court considered the appointment of a lead plaintiff in the consolidated securities actions, emphasizing the PSLRA's requirement to prioritize genuine investors over figurehead plaintiffs.

Reasoning: The lead plaintiff appointment process in securities class actions is initiated by a notice from the plaintiff within twenty days of filing, detailing the claims and proposed class period, as mandated by 15 U.S.C. 78u-4(a)(3)(A)(i).