Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Jariwala v. Enterprise Leasing Company-West, LLC

United States District Court, D. Nevada

March 22, 2019

CHETNABEN JARIWALA, an individual; HARDIK JARIWALA, an individual; POOJA JARIWALA, an individual; KRISHNABEN JARIWALA, an individual; TOGESH JARIWALA, an individual; PENUKA PATEL, an individual; DAXABEN JARIWALA, individually and as her to the Estate of KIRITKUMAR JARIWALA; HERISAN JARIWALA as heir to the Estate of KIRTIKUMAR JARIWALA; ABHISEK JARIWALA as heir to the Estate of KIRITKUMAR JARIWALA ROBERT ANSAR as Special Administrator to the Estate of KIRTKUMAR JARIWALA, deceased, Plaintiffs,
v.
ENTERPRISE LEASING COMPANY-WEST, LLC, a foreign limited liability company; ENTERPRISE RENT-A-CAR COMPANY OF LOS ANGELES, LLC, a foreign limitedliability company; KIA MOTORS AMERICA, INC., a foreign corporation; DOES 1 through 100; ROE BUSINESS ENTITIES 1 through 100, inclusive jointly and severally, Defendants. ENTERPRISE LEASING COMPANY-WEST, LLC, a foreign limited liability company, Counter-Plaintiff,
v.
KRISHNABEN JARIWALA, an individual, Counter-Defendant.

          MATTHEW T. DUSHOFF, ESQ. Nevada Bar No. 004975 WILLIAM D. SCHULLER, ESQ. Additional Counsel (Pro Hac Vice) JEFFREY A. SOBLE, ESQ. STEPHANIE ADAMO, ESQ. FOLEY &LARDNER LLP NICHOLAS J. FOX, ESQ. FOLEY &LARDNER LLP Attorneys for Defendants Enterprise Leasing Company-West, LLC, and Enterprise Rent-A-Car Company of Lost Angeles, LLC

          LEANNE SANDERS, ESQ. Nevada Bar No. 00390 COURTNEY CHRISTOPHER, ESQ. THOMAS M. KLEIN, ESQ. - (Pro Hac Vice) KLEIN THOMAS Attorneys for Defendant Kia Motors America, Inc.

          LADAH LAW FIRM JOSEPH C. CHU, ESQ. Attorneys for Plaintiffs

          MESSNER REEVES LLP VIRGINIA T. TOMOVA, ESQ. Attorneys for Counter-Defendant Krishnaben Jariwala

          STIPULATED PROTECTIVE ORDER AND PROPOSED ORDER ON SAME

          HON. CAM FERENBACH UNITED STATES MAGISTRATE JUDGE

         STIPULATED PROTECTIVE ORDER

         This Stipulated Protective Order (“Protective Order”) is stipulated to by and between Plaintiffs Chetnaben Jariwala, Hardik Jariwala, Pooja Jariwala, Krishnaben Jariwala, Yogesh Jariwala, Renuka Patel, Daxaben Jariwala, Herisan Jariwala, Abhisek Jariwala, and Robert Ansara (as Special Administrator of the Estate of Kiritkumar Jariwala, deceased); Defendants Enterprise Leasing Company-West, LLC, Enterprise Rent-A-Car Company of Los Angeles, LLC, and Kia Motors America, Inc.; Counter-Claimant Enterprise Leasing Company-West, LLC; and Counter-Defendant Krishnaben Jariwala; by and through the undersigned counsel, in order to facilitate the exchange of information and documents that may involve production of confidential, proprietary, and/or private information for which special protection from public disclosure and from use for any purpose other than use in this litigation may be warranted, the Parties stipulate as follows:

         Definitions

          1. “Document, ” whether used in the singular or plural, means any document or electronically-stored information as set forth in the Federal Rules of Civil Procedure.

         2. “Designating Party” means a Party or third party that produces information during the course of this litigation that is deemed “Confidential” pursuant to this Protective Order.

         3. “Confidential Information” means any information that is designated as such by a Designating Party. Information may be designated “Confidential” only if the Designating Party has a good-faith basis for believing the information: (a) is confidential under federal or state law or regulations; or (b) contains sensitive personal, financial, or professional information, or confidential or proprietary business information, that is generally unavailable to the public and that, if made available to the public, may be injurious to that Party's personal, financial, professional, or business interests.

         4. “Filing Party” shall mean any Party who seeks to file with the Court documents or other papers reflecting information designated as “Confidential Information.”

         5. “Privilege” shall mean the attorney-client privilege, the attorney work-product doctrine, or any other legally recognized privilege, doctrine, or protection that may apply to documents or information in this case.

         Use of Confidential Information

         6. All Confidential Information produced or exchanged in the course of this litigation shall be treated as confidential and shall be used solely to investigate, analyze, prosecute, and defend that claims raised in this litigation and for no other purpose.

         7. Except as specifically provided for in this Protective Order or subsequent Court orders, no Confidential Information shall be revealed, disclosed, or otherwise made known to any person, or made available for inspection and copying to any person, who is not permitted to see such Confidential Information pursuant to the terms of this Protective Order without express written consent of the Designating Party. Before receiving access to any Confidential Information, each person identified below shall execute an agreement to be fully bound by this Protective Order in the form of Exhibit A, attached hereto.

a. Court reporters employed in connection with this litigation;
b. Outside vendors who are necessary to assist counsel of record in this action in the preparation and trial of this action;
c. Experts retained by counsel of record in this action;
d. Deposition witnesses;
e. Any person or entity to the extent required by operation of law, lawful subpoena, or Court order; and f Any other person with the consent, in writing, of all parties.

         8. The Parties agree that the following individuals do not have to execute the agreement contained in Exhibit A hereto on the basis that the below individuals have been informed of the terms of this Protective Order and have agreed to be bound by the terms set forth herein as a result of their immediate relationship to this lawsuit:

a. Counsel of record in this action, including in-house counsel of the Parties as applicable;
b. Employees of counsel of record in this action; c. The ...

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.