UNITED STATES DXSTIUCT COURT
FOR THE EASTERN DISTRKT OF MISSOU'KI
MA.M L. WRONG, on BehalfofHimself and On : CASE NO.
Belralfof all Others Similarly Situated,
Plaintiff,
VS.
REH.4BCARLE GROW, INC., H. EDWIN ; CLASS ACXION
TRLJSHEZM and A.'LAN C. HENDERSON, : FOR VIOLATION
: SBCURITIES I,AWS
Defendants. mY TRIAL
Pltlinriff has alleged the followirrg based upon the investigation of plaintiff's
which included a review of United States Securities md Exchange Commission ("SECY,)
by R,ehabCare Group, Inc. ("RehabCara" or the "Company"), u well as regulatory filings
reports, securiries analysts reports and advisories about the Company, press releoscs
public sratemcnts issued by the Company, end media reports about the Company, and
believes Ihat substantial addiiional evident&y support will erist for the
herein afier a reasonable opportunity for discovery.
OF THE ACTION
1. This is a federal class action on behalf of purchasers of the securities
RehabCare between February 7,2002 to January 21,2002, inclusive (the "CJass Period"),
Yeeking to pursue rernedics under the Securities Exchange Act of 1934 (tha `%xchango
JURISDICTION AND VENUE
3
-. The claims alleged herein arise under Sections 1 O(b) and 20(a) of the
SNIPPETS:
which included a review of United States Securities md Exchange Commission fiiirtgs
reports, securiries analysts reports and advisories about the Company, press releoscs and
RehabCare between February 7,2002 to January 21,2002, inclusive,
Yeeking to pursue rernedics under the Securities Exchange Act of 1934
Preparation and dissemination to the investing public of false and misleading information,
In connection with the acts, transactions and conduct alleged herein, defendants,
the United States mails, interstate telephone communications and the facilities of the
Plaintiff, Mark L. Wrong, as set forth in the accompanying certification,
staffing services and physical rehabilitation program management for hospitals,
During the Class Period, each of the Individual Defendants, as senior executive
concerning RehabCare, its operations, finances, financial condition, present and future
The members of the Class are so numerous that joinder of all members is
of common stock outstanding, which were actively traded on the New York Stock Exchange (the
Company to tap into a new market - theper diem supplemental staffing market.
supplemental staffing division was being adversely impacted by numerous factors,
The completion of the Secondary Offering on favorable terms was
net earnings for the quarter were 48% higher
Our contract therapy services to nursing homes have thrived under the new prospective payment
fact experiencing severe operational problems stemming from its inadequate but
Offering, hled with the SEC, which incorporated a prospectus became
materially false and misleading when made as they misrepresented and/or omitted the following
RehabCare common stock traded at artificially inflated prices during the
misleading statements and omitting to disclose material facts necessary to make defendants'
Under these circumstances, all purchasers
their mcaking of affirmative statements and reports, or participation in the making of
the Individual Defendants were high-level executives and/or
defendants' material misrepresentations and/or omissions were done knowingly or recklessly
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