It may not become clear whether a class action would be appropriate in the Levy case until more facts come to light, lawyers said. For example, there may be differences among the women, including whether they were videotaped, photographed, neither or both, said Gregory Dolin, co-director of the Center for Medicine and Law at the University of Baltimore.

The number of patients who step forward also could play a role. There is no set figure on how many cases merit a class action designation, Dolin said.

Stephen D. Sugarman, a professor at the University of California, Berkeley School of Law, said he doesn't consider circumstances like those in the Levy case to be candidates for class action because experiences may vary among plaintiffs. Similar cases have rarely been class actions in recent years, he said.

If lawyers don't pursue a class action — in which all potential victims would be considered plaintiffs by default — a judge could agree to hear some cases together based on their similarities.

Lawyers may be jockeying for clients because those with the longest list could wield more power in court, whether in a class action or not, Pettit said. "The number of clients will dictate which law firms are in the driver's seat in terms of the litigation process," he said.

It can be complicated to determine who will take the lead when multiple plaintiffs and attorneys are involved, according to one attorney who recently resolved a class action against a Connecticut hospital that involved a doctor found to have photographed child patients in sexual poses. The case settled for about $50 million.

Richard Kenny, who represented 43 of about 150 people suing St. Francis Hospital in Hartford, Conn., said that case involved forming a committee of three or four lawyers from 17 firms. Kenny was selected to be the liaison to the court in the case, and said his firm took the lead, deposing 50 to 70 people. He said the such arrangements make sense.

"The case gets assigned to the judge, and the judge will say, 'I'm not dealing with 15 law firms,' " Kenny said. "There was an awful lot of work done on behalf of other law firms."

Baltimore Sun reporter Jessica Anderson contributed to this article.

  • Text NEWS to 70701 to get Baltimore Sun local news text alerts