In re Tyco Internt’l Securities

2000 DNH 268
CourtDistrict Court, D. New Hampshire
DecidedJuly 27, 2000
Docket00-MD-1335-B
StatusPublished

This text of 2000 DNH 268 (In re Tyco Internt’l Securities) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Tyco Internt’l Securities, 2000 DNH 268 (D.N.H. 2000).

Opinion

In re Tyco Internt’l Securities 00-MD-1335-B 07/27/00

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

In re Tyco International, Ltd. MDL N o . 00-MD-1335-B Securities Litigation ALL CASES Opinion N o . 2000 DNH 268

MEMORANDUM AND ORDER

This multidistrict litigation consolidates for pretrial

purposes securities fraud actions brought in multiple federal

districts. A group of four plaintiffs (the “Tyco Shareholder

Group” or “TSG”), who together seek appointment as lead

plaintiff, have moved for an order that (1) memorializes the

parties’ agreement as to the preservation of documents and data

in the possession of the defendants, and (2) grants the

plaintiffs authority to serve subpoenas on certain third parties

for the limited purpose of putting those third parties on notice

of this action and placing them under an obligation to preserve

relevant evidence in their possession.

As explained below, I deny the TSG’s request for a

preservation order directed at the defendants. I f , however, the

TSG presents this court with preservation subpoenas that

1 appropriately particularize the relevant evidence to be

preserved, I will grant the TSG leave to serve such subpoenas on

specified third parties.

I. The Statutory Framework: The PSLRA of 1995

This action is subject to the Private Securities Litigation

Reform Act of 1995, 15 U.S.C. § 78u-4 (the “PSLRA” or the “Act”).

Congress enacted the PSLRA to redress certain perceived abuses in

securities class actions, including “the abuse of the discovery

process to coerce settlement.” SG Cowen Secs. Corp. v . United

States Dist. Court for the N . Dist. of California, 189 F.3d 909,

911 (9th Cir. 1999) (quoting In re Advanta Corp. Secs. Lit., 180

F.3d 525, 530-31 (3d Cir. 1999)). Congress was reacting to

testimony that “[t]he cost of discovery often forces innocent

parties to settle frivolous securities class actions.” H.R.

Conf. Rep. N o . 104-369, at 37 (1995), reprinted in 1995

U.S.C.C.A.N. 730, 736. Congress also was concerned that

“plaintiffs sometimes file frivolous lawsuits in order to conduct

discovery in the hopes of finding a sustainable claim not alleged

in the complaint.” S. Rep. N o . 104-98, at 14 (1995), reprinted

2 in 1995 U.S.C.C.A.N. 679, 693.

Congress sought to remedy these abuses of the discovery

process by including within the PSLRA a stay provision, codified

at 15 U.S.C. § 78u-4(b)(3)(B), which provides that

In any private action arising under this chapter, all discovery and other proceedings shall be stayed during the pendency of any motion to dismiss, unless the court finds upon the motion of any party that particularized discovery is necessary to preserve evidence or to prevent undue prejudice to that party.

15 U.S.C. § 78u-4(b)(3)(B) (Supp. 1996). Accordingly, unless

certain exceptional circumstances are present, discovery in

securities class actions is permitted “only after the court has

sustained the legal sufficiency of the complaint.”1 SG Cowen,

1 Courts applying the PSLRA’s stay provision have reached different conclusions as to whether it applies before a motion to dismiss is filed. See, e.g., In re Carnegie Int’l Corp. Secs. Lit., Civil N o . L-99-1688, 2000 U.S. Dist. LEXIS 6137, at *23 (D. Md. Apr. 1 1 , 2000) (“[T]his Court rejects plaintiffs’ argument that the automatic stay provision of the PSLRA does not apply because the defense has not yet filed its motion to dismiss. Until the deadline for filing a motion to dismiss passes, or the defendants otherwise waive their rights to file a motion, or the Court rules on a motion to dismiss, the stay provisions are available.”); Dartley v . Ergobilt, Inc., 3-98-CV-1442-G, 1998 U.S. Dist. LEXIS 17737, at *2-3 (N.D. Tex. Nov. 3 , 1998) (“In interpreting the mandatory stay provision of the Reform Act, courts have stayed discovery against defendants where the filing of a motion to dismiss is imminent. However, under the plain language of the statute no stay is mandated where a motion to dismiss has yet to be filed. Therefore, in my opinion whether a

3 189 F.3d at 913 (quoting S . Rep. N o . 104-98, at 14 (1995),

reprinted in 1995 U.S.C.C.A.N. 679, 693) (internal quotation

marks omitted).

At the same time, Congress included a preservation provision

in the PSLRA “in recognition that ‘the imposition of a stay of

discovery may increase the likelihood that relevant evidence may

be lost.’” In re Grand Casinos, Inc. Secs. Lit., 988 F. Supp.

1270, 1271 (D. Minn. 1997) (quoting S . Rep. N o . 104-98, at 14

(1995), reprinted in 1995 U.S.C.C.A.N. 679, 6 9 3 ) . The

preservation provision mandates that

stay should be granted under such circumstances is addressed to the broad discretion of the court.”), appeal denied by 1998 U.S. Dist. LEXIS 17751 (N.D. Tex. Nov. 4 , 1998); In re Trump Hotel Shareholder Derivative Lit., N o . 96CIV.7820 (DAB)(HBP), 1997 WL 442135, at *2 (S.D.N.Y. Aug. 5 , 1997) (finding that stay provision applies where dismissal motion had not yet been filed solely as a result of parties’ pleading schedule). In the present action, motions to dismiss had been filed in some of the individual actions prior to consolidation, the parties and the court have established a schedule for the filing of an amended consolidated complaint and a motion to dismiss that complaint, and the defendants have indicated that they intend to file such dismissal motion. Under these circumstances, the stay provision applies even though a motion to dismiss is not pending. Cf. Powers v . Eichen, 961 F. Supp. 233, 236 (S.D. Cal. 1997) (“[I]t is clear that Congress did not contemplate a restrictive reading of the term ‘pendency’ in [the PSLRA’ stay provision].”).

4 During the pendency of any stay of discovery pursuant to this paragraph, unless otherwise ordered by the court, any party to the action with actual notice of the allegations contained in the complaint shall treat all documents, data compilations (including electronically recorded or stored data), and tangible objects that are in the custody or control of such person and that are relevant to the allegations, as if they were the subject of a continuing request for production of documents from an opposing party under the Federal Rules of Civil Procedure.

15 U.S.C. § 78u-4(b)(3)(C)(i) (Supp. 1996). The statute provides

for the possibility of court-ordered sanctions for a party’s

“willful failure” to comply with the duty to preserve relevant

evidence. Id. § 78u-4(b)(3)(C)(ii) (Supp. 1996).

These provisions reflect a careful balance between

Congress’s effort to shield defendants facing frivolous claims

from the burdens of discovery, on the one hand, and its desire to

ensure the preservation of evidence relevant to legally

cognizable claims, on the other. As one court has noted, in

crafting the stay and preservation provisions of the PSLRA

“Congress’s intent was to preserve the status quo, pending a

judicial determination of the legal sufficiency of [the

complaint].” In re Grand Casinos, Inc. Secs. Lit., 988 F.

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Related

In Re Grand Casinos, Inc. Securities Litigation
988 F. Supp. 1270 (D. Minnesota, 1997)
Mishkin v. Ageloff
220 B.R. 784 (S.D. New York, 1998)
Value House, Inc. v. MCI Telecommunications Corp.
917 F. Supp. 5 (District of Columbia, 1996)
Powers v. Eichen
961 F. Supp. 233 (S.D. California, 1997)
In Re Carnegie International Corp. Securities Litigation
107 F. Supp. 2d 676 (D. Maryland, 2000)
In Re Advanta Corp. Securities Litigation
180 F.3d 525 (Third Circuit, 1999)

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