Cress v. Nexo Financial LLC et al

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JOINT STIPULATION AND ORDER REGARDING SUMMARY JUDGMENT SCHEDULE
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Max Ambrose (SBN 320964)
maxambrose@taylorcopelandlaw.com
James Taylor-Copeland (SBN 284743)
james@taylorcopelandlaw.com
TAYLOR-COPELAND LAW
501 W. Broadway, Suite 800
San Diego, CA 92101
Telephone: 619-734-8770
Facsimile: 619-566-4341
Attorneys for Plaintiff John Cress
Ian S. Shelton (SBN 264863)
BAKER & MCKENZIE LLP
ian.shelton@bakermckenzie.com
10250 Constellation Boulevard, Suite 1850
Los Angeles, CA 90067
Phone: (310) 299-8535
Fax: (310) 201-4721
Matthew C. Rawlinson (admitted pro hac vice)
BAKER & MCKENZIE LLP
matthew.rawlinson@bakermckenzie.com
800 Capitol, Suite 2100
Houston, Texas 77002
Phone: (713) 427-5000
Fax: (713) 427-5067
Attorneys for Defendant Nexo Capital, Inc.
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
JOHN CRESS,
Plaintiff,
vs.
NEXO CAPITAL, INC.
Defendant.
CASE NO. 3:23-cv-00882-TSH
JOINT STIPULATION AND ORDER TO
EXTEND SUMMARY JUDGMENT
DEADLINES AND HEARING DATE BY
14 DAYS TO ACCOMMODATE
MEDIATION
Case 3:23-cv-00882-TSH Document 169 Filed 09/02/26 Page 1 of 4

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JOINT STIPULATION AND PROPOSED ORDER REGARDING SUMMARY JUDGMENT SCHEDULE
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STIPULATION
Plaintiff John Cress (“Cress”) and Defendant Nexo Capital, Inc. (“Nexo”), by and through
their undersigned counsel, jointly stipulate and request that the Court extend the current deadlines
associated with the parties’ summary judgment and Daubert motions, including the hearing date, by
fourteen (14) days, to accommodate a September 15, 2026 mediation, as set forth below.
1. 	The parties have met and conferred and agree that good cause exists for a 14-day extension
of the current briefing deadlines and hearing date associated with the parties’ summary
judgment and Daubert motions.
2. 	Under the current schedule, responses to both summary judgment motions and Mr. Cress’s
Daubert motion are due September 11, 2026; replies to both summary judgment motions and
the response to Nexo’s anticipated Daubert motion are due September 30, 2026; and the
hearing is set for October 22, 2026 at 10:00 a.m.
3. 	The parties are scheduled to participate in mediation in San Francisco on September 15,
2026 before the Hon. Gary A. Feess (Ret.), a former United States District Judge from the
Central District of California.
4. 	Good cause exists to extend the briefing schedule by 14 days to reduce the burden on the
parties and the Court and allow the parties to focus their efforts on preparing for and
participating in the mediation.
5. 	Good cause also exists because the parties believe that extending the current deadlines will
maintain the status quo and increase the likelihood of a mediated resolution.
6. 	Accordingly, the parties stipulate and respectfully request that the Court extend the
applicable deadlines by 14 days, to and including the following dates: responses to both
summary judgment motions and Mr. Cress’s Daubert motion shall be due September 25,
2026; Nexo’s anticipated Daubert motion for purposes of Summary Judgment shall be due
September 25, 2026; replies to both summary judgment motions and the response to Nexo’s
anticipated Daubert motion shall be due October 14, 2026; and the hearing shall be continued
to November 5, 2026 at 10:00 a.m.
Case 3:23-cv-00882-TSH Document 169 Filed 09/02/26 Page 2 of 4

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JOINT STIPULATION AND PROPOSED ORDER REGARDING SUMMARY JUDGMENT SCHEDULE
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IT IS SO STIPULATED.
Dated: September 1, 2026 	BAKER & MCKENZIE LLP
By: _/s/ Ian S. Shelton_________________
Ian. S. Shelton
Attorneys for Defendant Nexo Capital Inc.
Dated: September 1, 2026 	TAYLOR-COPELAND LAW
By: _/s/ James Taylor-Copeland__________
James Taylor-Copeland
Attorneys for Plaintiff John Cress
ATTESTATION
Pursuant To Civil Local Rule 5-1(i)(3) regarding signatures, I attest that concurrence in the
filing of this document has been obtained from the other signatories.
Dated: September 1, 2026 	BAKER & MCKENZIE LLP
By: _/s/ Ian S. Shelton_________
Ian. S. Shelton
Attorneys for Defendant Nexo Capital Inc.
Case 3:23-cv-00882-TSH Document 169 Filed 09/02/26 Page 3 of 4

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JOINT STIPULATION AND PROPOSED ORDER REGARDING SUMMARY JUDGMENT SCHEDULE
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ORDER
Pursuant to stipulation, IT IS SO ORDERED.
Dated: September 2, 2026
_____________________________________
HON. THOMAS S. HIXSON
UNITED STATES MAGISTRATE JUDGE
Case 3:23-cv-00882-TSH Document 169 Filed 09/02/26 Page 4 of 4