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

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1 Case No.: 24-cv-06745-HSG	STIP TO CONTINUE HEARING PENDING
MOTION/DEADLINES
William C. Reeves – 183878
Christine Fierro – 191660
MORALES FIERRO & REEVES
1440 Maria Lane, Suite 200
Walnut Creek, CA 94596
Telephone: 925/288-1776
Facsimile: 925/288-1856
Email: wreeves@mfrlegal.com
cfierro@mfrlegal.com
Attorneys for Plaintiff and Cross-Defendant
Associated Industries Ins. Co., Inc.
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
ASSOCIATED INDUSTRIES INS. CO.,
INC.,
Plaintiff,
vs.
BAY AREA DRAINAGE, INC, et al.,
Defendants.
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Case No.: 24-cv-06745-HSG
STIPULATION TO CONTINUE
HEARING ON PENDING MOTION
AND OTHER DEADLINES AND
ORDER (as modified)
and related cross-claims )
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Plaintiff/Cross-Defendant Associated Industries Insurance Company, Inc. (“AIIC”) and
Defendant/Cross-Claimant Bay Area Drainage, Inc. (“BADI”) have reached a settlement in
principle, resolving all issues raised in this action (in conjunction with a settlement reached in the
underlying action, Pari Darabi v. Eaglelift, Inc., and Bay Area Drainage, Inc., Contra Costa County
Superior Court Case No. C24-00970 (the “Underlying Action”)). In light of the settlement, AIIC
and BADI, hereby stipulate as follows:
WHEREAS, AIIC and BADI anticipate that they will memorialize the settlement
concurrently with the memorialization of the settlement in the Underlying Action, and will dismiss
the complaint and counter complaint filed in this action within the next 45 days;
WHEREAS, AIIC has a dispositive motion currently pending before this Court, with a
hearing date of February 19, 2026 (at 2 p.m.);
Case 4:24-cv-06745-HSG Document 51 Filed 01/22/26 Page 1 of 2

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2 Case No.: 24-cv-06745-HSG	STIP TO CONTINUE HEARING PENDING
MOTION/DEADLINES
WHEREAS, the parties hereby stipulate as follows:
1. to continue the hearing date on the pending dispositive motion by 45 days, to a date
of the Court’s choosing, no sooner than March, 6, 2026;
2. to continue the following deadlines by 45 days: Exchange of Opening Expert
Reports from February 13, 2026, to March 30, 2026; Exchange of Rebuttal Expert Reports from
March 6, 2026, to April 15, 2026; and Close of Expert Discovery from March 27, 2026 to May 4,
2026.
IT IS SO STIPULATED
MORALES FIERRO & REEVES
By: /s/Christine Fierro
Christine Fierro
Attorneys for Plaintiff Associated
Industries Ins. Co., Inc.
MILES WESTBROOK & DEAL LLP
By: /s/Joel M. 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. The new hearing date on the pending dispositive motion is March 12,
2026 at 2 p.m.
Dated: _____________________________________
JUDGE HAYWOOD S. GILLIAM, JR.,
UNITED STATES DISTRICT JUDGE
1/22/2026
Case 4:24-cv-06745-HSG Document 51 Filed 01/22/26 Page 2 of 2