In re: Agilon Health, Inc. 2025 Securities Litigation — Entry #21: Letter regarding Joint Stipulation and Proposed Order for Schedule to File Plaintiff's Amended Complaint and Defendants' Responses Thereto and Other Relief by…

Case 1:25-cv-07167-HG                            Document 21                      Filed 05/04/26                    Page 1 of 2 PageID #: 199


                                                                     90 Park Avenue
                                                                New York, NY, 10016-1387
                                                             212-210-9400 | Fax: 212-210-9444


  Elizabeth Gingold Clark                                         Direct Dial: 212-210-9568                         Email: [email protected]


                                                                      May 4, 2026

  VIA ECF

   Hon. Hector Gonzalez, U.S.D.J.
   United States District Court
   Eastern District of New York
   225 Cadman Plaza East
   Brooklyn, NY 11201

               Re:        Jeremy Vandersluis v. agilon health, inc., et al.; No. 1:25-cv-07167-HG


  Dear Judge Gonzalez:

          We represent Defendants agilon health, inc., Steven Sell, and Jeffrey Schwaneke
  (collectively, “Defendants”) in the above-referenced action. In accordance with Rule
  1.C(2) of the Court’s Individual Rules and Practices, we respectfully submit this letter to
  request that the Court enter the enclosed Joint Stipulation and [Proposed] Order for (1)
  Schedule to File Plaintiff’s Amended Complaint and Defendants’ Responses Thereto and
  (2) Other Relief (“Stipulation”). Lead Plaintiff HR & Sons LLC (“Plaintiff,” and with
  Defendants, the “Parties”) jointly submit this request.

           On April 28, 2026, the Court entered an Order that, among other things, appointed
  HR & Sons LLC as Lead Plaintiff, approved its selection of The Rosen Law Firm, P.A. as
  Lead Counsel, and directed the Parties to meet-and-confer and submit a proposed schedule
  for the filing of an amended complaint and briefing schedule for any responses thereto on or before
  May 12, 2026.

         Accordingly, the Parties have met and conferred and respectfully request that the
  Court enter the enclosed Stipulation setting the proposed schedule outlined below:

               1. Plaintiff shall file its Amended Complaint (“AC”) on or before June 29, 2026;

         2. Defendants shall move to dismiss, answer, or otherwise respond to the AC on
  or before August 28, 2026; and

          3. If Defendants move to dismiss the AC, Plaintiff shall file its opposition to the
  motion to dismiss on or before October 27, 2026, and Defendants shall file their reply
  brief in support of their motion to dismiss on or before December 3, 2026.
  Alston & Bird LLP                                                                                                                          www.alston.com

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Case 1:25-cv-07167-HG        Document 21        Filed 05/04/26     Page 2 of 2 PageID #: 200
  Jeremy Vandersluis v. agilon health, inc., et al., No. 1:25-cv-07167-HG
  May 4, 2026
  Page 2


         Further, the Parties request that the action be renamed to: In re: agilon health,
  inc. 2025 Securities Litigation.

        The Parties previously requested, and the Court granted, an extension of time for
  Defendants to respond to the Complaint, pending the appointment of Lead Plaintiff and
  Lead Counsel. (See DCKT #8).

         We appreciate the Court’s attention to this matter and we are available at the
  Court’s convenience should Your Honor have any questions.

                                               Sincerely,


                                               Elizabeth Gingold Clark

  Enclosure

  cc:    Counsel of Record (via ECF)