According to the filed complaint, defendants made false statements and/or concealed that certain contracts used in ModivCare’s NEMT segment caused the Company’s free cash flow to deteriorate and as a result, (1) contract renegotiations and pricing accommodations negatively impacted the Company’s adjusted EBITDA; (2) the Company had insufficient liquidity; and (3) defendants’ positive statements about the Company’s business, operations, and prospects were materially misleading and/or lacked a reasonable basis.