The following excerpt is from Bel Marin Driwall, Inc. v. Grover, 470 F.2d 932 (9th Cir. 1972):
We have previously held that "The right to a set-off has been recognized by the courts even though payment is not made until after the adjudication." Hayden v. Standard Acc. Ins. Co. (9 Cir. 1963) 316 F.2d 598, 602.
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