Lunstrum v. Centene Corporation — Entry #45: STIPULATION AND ORDER: IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned parties, subject to the Court's approval, as follows: 1

Case 1:25-cv-05659-ALC              Document 45    Filed 09/01/26      Page 1 of 3


                          UNITED STATES DISTRICT COURT
                     FOR THE SOUTHERN DISTRICT OF NEW YORK


MICHAEL LEHIANI, Individually, and on Behalf )       Case No. 1:25-cv-05659
of All Others Similarly Situated,            )
                              Plaintiff,         )
                                                 )   STIPULATION AND
       v.                                        )   ORDER
                                                 )
CENTENE CORPORATION, SARAH M.                    )
LONDON, and ANDREW LYNN ASHER,                   )
                                                 )
                                                 )
                              Defendants.        )
                                                 )


       WHEREAS, on July 9, 2025, this putative securities class action was filed (ECF 1);

       WHEREAS, on July 23, 2025, this Court entered an Order (ECF 15) (the “July 2025

Order”) granting the letter-motion of Centene Corporation, Sarah M. London, and Andrew Lynn

Asher (collectively, “Defendants”) for “an adjournment of any deadline to answer or otherwise

respond to the Complaint until after the Court appoints a lead plaintiff and lead counsel”;

       WHEREAS, on August 11, 2026, this Court appointed Michael Lehiani (“Lead Plaintiff”)

as lead plaintiff and approved Lead Plaintiff’s selection of counsel (ECF 38) (the “August 2026

Order”);

       WHEREAS, the August 2026 Order also directed the parties to “submit a joint status report

by Thursday, August 25, 2026, regarding Lead Plaintiff’s intent to amend the complaint,

Defendants’ anticipated response to the operative Complaint, outlining a proposed briefing

schedule, if any”;

       WHEREAS, Lead Plaintiff intends to file an amended complaint, and Defendants

anticipate moving to dismiss that amended complaint;


       Case 1:25-cv-05659-ALC           Document 45        Filed 09/01/26      Page 2 of 3


       WHEREAS, pursuant to the Court’s July 2025 and August 2026 Orders, Lead Plaintiff and

Defendants have contemporaneously filed with this Stipulation and Proposed Order a joint letter

proposing a schedule for filing an amended complaint and briefing a motion to dismiss consistent

with the below;

       IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned parties,

subject to the Court’s approval, as follows:

       1.      Lead Plaintiff’s amended complaint is due on or before November 3, 2026.

       2.      Pursuant to Rule 2 of the Court’s Individual Practices, Defendants will file a letter

requesting a pre-motion conference in connection with their anticipated motion to dismiss the

amended complaint on or before January 15, 2027.

       3.      Pursuant to Rule 2 of the Court’s Individual Practices, Lead Plaintiff will file a

response to Defendants’ pre-motion conference letter on or before January 20, 2027.

       4.      Defendants’ motion to dismiss the amended complaint will be due 5 days from the

date of the pre-motion conference or the date of the Court’s order declining to hold a pre-motion

conference; Lead Plaintiff’s opposition will be due 77 days after Defendants’ motion to dismiss is

filed; and Defendants’ reply will be due 40 days after Lead Plaintiff’s opposition is filed.


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         Case 1:25-cv-05659-ALC      Document 45     Filed 09/01/26   Page 3 of 3


Dated: August 25, 2026

    BLEICHMAR FONTI & AULD LLP                     DAVIS POLK & WARDWELL LLP

             /s/ Joseph A. Fonti                        /s/ James P. Rouhandeh

 Joseph A. Fonti                             James P. Rouhandeh
 Evan A. Kubota                              Antonio J. Perez-Marques
 Thayne Stoddard                             Patrick W. Blakemore
 Thomas F. Allen                             Marie Killmond
 300 Park Avenue, Suite 1301                 Davis Polk & Wardwell LLP
 New York, New York 10022                    450 Lexington Avenue
 Telephone: (212) 789-1340                   New York, New York 10017
 Facsimile: (212) 205-3960                   Telephone: (212) 450-4000
 [email protected]                           Facsimile: (212) 701-5800
 [email protected]                          [email protected]
 [email protected]                        [email protected]
 [email protected]                           [email protected]
                                             [email protected]
 -and-
                                             Counsel for Defendants
 Adam C. McCall (pro hac vice pending)
 15301 Ventura Boulevard, Suite U1
 Sherman Oaks, California 91403
 Telephone: (415) 445-4003
 Facsimile: (212) 205-3960
 [email protected]
 Lead Counsel for Lead Plaintiff and the
 Class


 IT IS SO ORDERED.


       September 1, 2026
 DATED____________________________
                                            THE HONORABLE ANDREW L. CARTER, JR.
                                                UNITED STATES DISTRICT JUDGE


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