Cress v. Nexo Financial LLC et al

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NOTICE OF SETTLEMENT AND JOINT STIPULATION AND PROPOSED ORDER
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
NOTICE OF SETTLEMENT
JOINT STIPULATION AND [PROPOSED]
ORDER EXTENDING SUMMARY
JUDGMENT DEADLINES TO
EFFECTUATE SETTLEMENT
Case 3:23-cv-00882-TSH Document 171 Filed 09/25/26 Page 1 of 5

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NOTICE OF SETTLEMENT AND JOINT STIPULATION AND PROPOSED ORDER
STIPULATION
Plaintiff John Cress (“Cress”) and Defendant Nexo Capital, Inc. (“Nexo”) (collectively, the
“Parties”), by and through their undersigned counsel, hereby provide notice of settlement and jointly
stipulate and request that the Court take the following actions to effectuate that settlement:
1. 	On August 7, 2026, the Parties filed cross-motions for summary judgment and related filings
(ECF 150-156, 162, 165). Opposition briefs are currently due on September 25, and reply
briefs are due on October 14 (ECF 169).
2. 	On September 15, 2026, the Parties participated in a mediation before the Hon. Gary Feess
(Ret.) in San Francisco.
3. 	After the mediation, the Parties reached a settlement, which, provided all Parties comply
with the terms of the settlement agreement, will result in the filing of a stipulation of
dismissal with prejudice of the above-referenced action, with the Parties to bear their own
attorney’s fees and costs.
4. 	Nexo requires additional time to comply with one of the terms of the settlement.
5. 	The Parties stipulate and agree to a seven-day extension of the summary judgment deadlines
to allow for completion of the settlement.
NOW, 	THEREFORE, 	IT 	IS 	STIPULATED 	AND 	AGREED, 	SUBJECT 	TO 	THE
APPROVAL OF THE COURT:
1. 	Good cause exists to extend the summary judgment deadlines by seven days to allow for
completion of the settlement. As to the summary judgment motions (ECF 153, 155 and 156),
responses are due by October 2, replies due by October 21, and motion hearing is set for
November 12, 2026 at 10:00 a.m. in San Francisco, Courtroom E, 15th Floor.
IT IS SO STIPULATED.
Case 3:23-cv-00882-TSH Document 171 Filed 09/25/26 Page 2 of 5

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NOTICE OF SETTLEMENT AND JOINT STIPULATION AND PROPOSED ORDER
Dated: September 25, 2026 	BAKER & MCKENZIE LLP
By: /s/ Ian S. Shelton__________________
Ian. S. Shelton
Attorneys for Defendant Nexo Capital Inc.
Dated: September 25, 2026 	TAYLOR-COPELAND LAW
By: /s/ James Taylor-Copeland__________
James Taylor-Copeland
Attorneys for Plaintiff John Cress
Case 3:23-cv-00882-TSH Document 171 Filed 09/25/26 Page 3 of 5

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NOTICE OF SETTLEMENT AND JOINT STIPULATION AND PROPOSED ORDER
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 25, 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 171 Filed 09/25/26 Page 4 of 5

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NOTICE OF SETTLEMENT AND JOINT STIPULATION AND PROPOSED ORDER
ORDER
Pursuant to stipulation, IT IS SO ORDERED.
Dated: September 25, 2026
_____________________________________
HON. THOMAS S. HIXSON
UNITED STATES MAGISTRATE JUDGE
Case 3:23-cv-00882-TSH Document 171 Filed 09/25/26 Page 5 of 5