Associated Industries Insurance Company, Inc. v. Bay Area Drainage, Inc et al

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DEFENDANT/CROSS-CLAIMANT’S REQUESTS FOR PRODUCTION OF DOCUMENTS, SET ONE
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28	MILES WESTBROOK
& DEAL LLP
Attorneys at Law
Joel M. Westbrook (SBN: 196578)
joel@mileswestbrook.com
M ILES W ESTBROOK & D EAL LLP
3390 Mt. Diablo Blvd., Suite 220
Lafayette, CA 94549
(925) 938-4500 Phone
(925) 938-7007 Fax
Attorney for Defendant/Cross-Claimant
BAY AREA DRAINAGE, INC.
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
ASSOCIATED INDUSTRIES
INSURANCE COMPANY, INC.,
Plaintiff,
v.
BAY AREA DRAINAGE, INC and PARI
DARABI,
Defendants.
Case No.: 24-CV-06745-HSG
STIPULATION TO AMEND
BRIEFING SCHEDULE FOR
PARTIAL MOTION FOR SUMMARY
JUDGMENT AND ORDER
AND ALL RELATED CROSS-ACTIONS
Plaintiff/Cross-Defendant Associated Industries Insurance Company, Inc. (“AIIC”) and
Defendant/Cross-Claimant Bay Area Drainage, Inc. (“BADI”) hereby stipulate as follows:
WHEREAS, on December 5, 2025, AIIC filed a motion for partial summary judgment
(“the Motion”), which is currently set to be heard on February 19, 2026;
WHEREAS, the opposition to the Motion is currently due by December 19, 2025, and the
reply is due by December 26, 2025;
WHEREAS, the parties have a discovery dispute regarding AIIC’s responses to BADI’s
Request for Production of Documents, Set One, and AIIC’s document production;
Case 4:24-cv-06745-HSG Document 42 Filed 12/15/25 Page 1 of 2

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DEFENDANT/CROSS-CLAIMANT’S REQUESTS FOR PRODUCTION OF DOCUMENTS, SET ONE
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28	MILES WESTBROOK
& DEAL LLP
Attorneys at Law
WHEREAS, without any admission as to the merits of BADI’s contentions, which AIIC
disputes, and solely as an effort to compromise, AIIC has agreed to produce certain additional
documents by December 19, 2025;
WHEREAS, in conjunction with this document production, and subject to the Court’s
approval, the parties have agreed that BADI’s opposition to the Motion shall now be due by
January 6, 2026, and AIIC’s reply to the opposition shall be due by January 16, 2026.
WHEREAS, the parties hereby stipulate as follows:
1. 	The new deadline for BADI’s opposition to the Motion is January 6, 2026;
2. 	The new deadline for AIIC’s reply to the opposition to the Motion is January 16,
2026
IT IS SO STIPULATED
MORALES FIERRO & REEVES
By: 	/s/ Christine Fierro
Christine Fierro
Attorneys for Plaintiff
MILES WESTBROOK & DEAL LLP
By: 	/s/ Joel Westbrook
Joel M. Westbrook
Attorneys for Defendant Bay Area
Drainage, Inc.
ORDER
The above is approved and all parties shall comply with its provisions.
IT IS SO ORDERED.
Dated:
_____________________________________
JUDGE HAYWOOD S. GILLIAM, JR.,
UNITED STATES DISTRICT JUDGE
12/15/2025
Case 4:24-cv-06745-HSG Document 42 Filed 12/15/25 Page 2 of 2