[ UsDC SDNY The Court DENIES the requested adjournment, DOCUMENT and defers ruling on the other issues raised in ELECTRON the letter. Deadlines between the date of this ICALLY FILED endorsement and the date of the conference are DOC #0 stayed.

Kk 09/03/2025 Keir tt Feuker HON. KATHARINE H. PARKER UNITED STATES MAGISTRATE JUDGE Re: In re Lemonade, Inc. Data Disclosure Litig., No. 1:25-cv-04106-JHR-KHP Joint Letter Motion Requesting to Adjourn September 10, 2025, Conference and Stay Deadlines Pending Mediation Dear Judge Parker: The parties respectfully submit this letter motion, pursuant to the Court’s Individual Practices in Civil Cases (§ I.b.), jointly requesting that the Court: (1) adjourn the September 10, 2025, initial case management conference (“Conference,” ECF No. 15) and (2) stay all deadlines in this case pending the parties’ upcoming mediation. On August 6, 2025, the parties participated in an initial meet-and-confer call pursuant to Fed. R. Civ. P. 26(f). Since that meeting, the parties have agreed to participate in mediation. They have exchanged the names and dates of availability for several potential mediators. The parties anticipate that they will be able to schedule a mediation to take place in the next 90 days. In addition, the parties have discussed the exchange of certain pre-mediation discovery and will collaborate on the scope of such discovery. The parties are hopeful that a potential compromise exists that may resolve the disputed claims short of the expense and resources of further litigation. The parties thus jointly request that the Court exercise its authority to manage its docket and to stay this case pending completion of private mediation. See Landis v. North American Co.,

(1936). Accordingly, the parties respectfully request that the Court adjourn the Conference and stay all deadlines, including: e The parties’ September 3, 2025, deadline to file their 26(f) report; e Defendants’ September 12, 2025, deadline to file their response, if any, to the plaintiffs’ motion to appoint interim lead counsel (see ECF No. 19); e Defendants’ September 29, 2025, deadline (see ECF No. 14) to answer or otherwise respond to the consolidated complaint filed August 28, 2025 (ECF No. 25). The parties agree that the stay of deadlines should not impact their ability to seek pre-mediation discovery from one another, or to seek general discovery from third parties.

The parties further agree that either party may seek to lift the stay by notifying the other. If that occurs, the parties will file a joint letter with the Court, within 7 days of the notice that a party would like to lift the stay, proposing deadlines for the filing of the above submissions. The parties will file a letter with the Court within 14 days of mediation, advising the Court of the outcome of the mediation, and, if the case is not resolved, propose new case deadlines. Additionally, one of plaintiff’s counsel has a conflict with the September 10, 2025, Conference date and, if the Court determines that an initial case management conference should be held at this time, respectfully requests that it be adjourned to a later day. Respectfully submitted, /s/ Tiana Demas /s/ Melissa Clark Tiana Demas Melissa Clark Anne Bigler AHDOOT & WOLFSON, PC COOLEY LLP 521 5th Avenue, 17th Floor 55 Hudson Yards New York, NY 10175 New York, NY 10001 Telephone: (917) 336-0171 Telephone: (212) 479-6000 Facsimile: (917) 336-0177 Facsimile: (212) 479-6275 [email protected] [email protected] [email protected] Ronald Podolny John A. Yanchunis (admitted pro hac vice) Counsel for Defendants Antonio Arzola, Jr. (pro hac vice forthcoming) MORGAN & MORGAN COMPLEX LITIGATION GROUP 201 N. Franklin Street, 7th Floor Tampa, FL 33602 Tel: (813) 275-5272 [email protected] [email protected] [email protected] Mark B. DeSanto (admitted pro hac vice) BERGER MONTAGUE PC 1818 Market Street, Suite 3600 Philadelphia, PA 19103 Tel: (215) 875-3000 Fax: (215) 875-4604 [email protected] Counsel for Plaintiffs and the Putative Class