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Status Report 

Case No. 4:17-cv-00755-CW

Mohammed Wael Aly (CA #312419)

1515 E Katella Ave, # 4138, 

Anaheim, CA 92805-7901

mohammed.w.aly@gmail.com

mohammedwaly@gmail.com

Tel: 714-414-3736

John M. Shoreman, Esq. (Pro Hac Vice)

McFADDEN & SHOREMAN LLC

1050 Connecticut Avenue, NW, Suite 500 

Washington, DC 20036 

jmshoreman@verizon.net

Tel: 202-772-3188

Counsel	for	Defendant	Libre	by	Nexus,	Inc.

IN THE UNITED STATES DISTRICT COURT

THE NORTHERN DISTRICT OF CALIFORNIA

OAKLAND DIVISION

JUAN QUINTANILLA VASQUEZ, 

GABRIELA PERDOMO ORTIZ, VICTOR 

HUGO CATALAN MOLINA, AND KEVIN 

CALDERON, INDIVIDUALLY AND ON 

BEHALF OF ALL OTHERS SIMILARLY 

SITUATED,

Plaintiff,

v.

LIBRE BY NEXUS, INC. and JOHN DOES 1- 50,

Defendants.

Case No. 4:17-cv-00755-CW

Action Filed: Status Update

TO THE COURT AND ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

On November 4, 2022, the Court issued an order for each side to file a status report 

addressing the status of LBN’s compliance with the Court’s October 3, 2022 Order. The following 

status updates are made in accordance with the Court’s Order:

Case 4:17-cv-00755-CW Document 230 Filed 11/14/22 Page 1 of 5
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Status Report 

Case No. 4:17-cv-00755-CW

1. The Court ordered LBN to pay the amounts it owes under various terms of the 

settlement agreement:

On November 14, 2022, LBN sent a payment of $2,000.00 to the settlement 

administrator. Due to current financial shortcomings, LBN will be making weekly payments of 

$2,000.00 until all payments are completed. Should LBN’s financial performance improve, the 

amount paid will increase accordingly. This amount constitutes the maximum amount of money 

LBN can possibly pay and remain open and able to continue to indemnify tens of thousands of 

existing immigration bonds.

LBN has suffered revenue losses because of the pandemic and the increased and

unconventional immigration enforcement activities of the Trump administration, many of which 

have continued under the present administration. Obviously, a reduction in the number of people 

needing Libre’s assistance is a positive development, but unfortunately scores of people who 

would need Libre’s help are held in cross border detention camps or find themselves held in 

immigration custody without the possibility of posting bond. LBN provides the following 

revenue information for the prior 5 years to effectively demonstrate the significance of the 

revenue shortfalls. LBN is in the process of preparing financial documentation that show the 

following revenue information. 

Revenue Totals

October 2018: $3,353,058.02

October 2019: $3,838,477.70

October 2020: $1,847,927.05

October 2021: $1,145,348.00

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Status Report 

Case No. 4:17-cv-00755-CW

October 2022: $503,353.00

LBN’s reduction in revenue have made it impossible for LBN to make the 

payments ordered by the Court. In fact, these same revenue shortfalls made it impossible for 

LBN to comply with the Court’s prior orders related to the payments of money. LBN is not in 

contempt of Court for its failure to pay the monies ordered, because LBN is and was unable to 

make the payments because of these revenue shortfalls. 

2. The Court ordered LBN to provide Plaintiffs business records and documents 

sufficient to show that it has implemented various discounts and credits required under the terms 

of the settlement agreement:

On November 14, 2022, LBN send Plaintiffs 25 participant files that show DEBT 

RELIEF CREDITS applied to participants accounts. Unfortunately, Lightspeed does not offer 

easy export features to just send all Debt Relief recipients. LBN continues to work diligently with 

limited staff to get final documents to Plaintiffs. LBN estimates to have the remaining 25 

documents to Plaintiffs within 2 weeks.

In addition to the rolling production of the remainder of the above files over the next 

two weeks, LBN will also produce the remaining reports on a rolling basis, as follows: Remaining 

reports – begin producing December 1, 2022, with complete production by January 30, 2023. LBN 

apologizes to the Court for the delay. LBN asserts that the records the Court requires are being 

created in a new database system and are not records it currently has in an exportable format. As 

a result, these records will be produced as the new database system is updated with a full data 

migration from prior systems.

3. The Court imposed on LBN a fine of $1000.00 per day of continued nonCase 4:17-cv-00755-CW Document 230 Filed 11/14/22 Page 3 of 5
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28 3

Status Report 

Case No. 4:17-cv-00755-CW

compliance as to each of the subject matters regarding which the Court separately ordered LBN to 

take certain actions: 

Due to the lack of financial resources, LBN has been unable to pay the fine. LBN is 

booking the fine into its books as monies owed. Additionally, LBN anticipates filing a motion to 

reconsider and/or a motion for interlocutory appeal, upon its acquisition of new counsel in this 

case.

4. Finally, as the Court is aware we have had difficulty in receiving legal guidance 

from current counsel. In fact, only undersigned counsel has been assisting in the ministerial filing 

of responses ordered by the Court. The majority of the attorneys who have been required to remain 

in this case by the Court have no contact with LBN or its principals regarding legal 

guidance/strategy. LBN has asked counsel to convey to the Court that the presence of multiple 

attorneys in this matter, and the Court’s refusal to permit them to withdraw, is making it nearly 

impossible for LBN to acquire new counsel. Given the tenor of the litigation at present, all parties 

have an interest in LBN retaining counsel of their choice, and counsel willing to work with LBN. 

LBN respectfully requests that the Court permit the withdraw of all (or most) of its current 

attorneys so that the company may more efficiently hire replacement counsel, and that the Court 

permit LBN 30 days to retain new counsel.

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1

[Type Pleading Short Title Here]

Case No. [Type Case Number Here]

[LAW FIRM NAME, ADDRESS,

PHONE, FAX]

DATED: November 14, 2022

JOHN M. SHOREMAN, ESQ. (PRO HAC 

VICE)

MCFADDEN & SHOREMAN LLC

1050 CONNECTICUT AVENUE, NW, 

SUITE 500 

WASHINGTON, DC 20036

JMSHOREMAN@VERIZON.NET

TEL: 202-772-3188

By: /s/ John M. Shoreman

John M. Shoreman, Esq. (Pro Hac Vice)

Attorneys for Counsel for Defendant Libre by 

Nexus, Inc.

Case 4:17-cv-00755-CW Document 230 Filed 11/14/22 Page 5 of 5