IN RE eHEALTH INC. SECURITIES LITIGATION

I. BACKGROUND

1 In the Joint Discovery Letter, the following litigation history is set forth. On August 12, 2 2021, the Court granted in part and denied in part Defendants’ Motion to Dismiss. ECF No. 64. 3 The Court held that the Complaint had sufficiently alleged that Defendants’ statements on April 4 26, 2018, and February 20, 2020, were actionable. Id. Defendants filed an Answer on October 1, 5 2021. ECF No. 76. A suggestion of death was filed shortly thereafter for then-Lead Plaintiff Billy 6 White. ECF No. 78. Chicago & Vicinity Laborers’ District Council Pension Fund was appointed 7 as Lead Plaintiff and filed a Motion to Supplement the Complaint. ECF Nos. 113, 116. Lead 8 Plaintiff served the RFPs on December 19, 2022, and sent a draft of an ESI Protocol to Defendants 9 on December 21, 2022, asking to meet and confer. Defendants declined to engage in any meet and 10 confer, and served their responses and objections to the RFPs on January 18, 2023, stating they 11 would not engage in discovery while their Motions for Judgment on the Pleadings were pending.2

II. DISCUSSION

13 Under the PSLRA, “all discovery and other proceedings shall be stayed during the…