United States District Court, D. Nevada
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,
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,
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
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.
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
CAM FERENBACH UNITED STATES MAGISTRATE JUDGE
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
“Document, ” whether used in the singular or
plural, means any document or electronically-stored
information as set forth in the Federal Rules of Civil
“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.
“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.
“Filing Party” shall mean any Party who seeks to
file with the Court documents or other papers reflecting
information designated as “Confidential
“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.
of Confidential Information
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
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
b. Outside vendors who are necessary to assist counsel of
record in this action in the preparation and trial of this
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.
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
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