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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 1:20-CV-22603-GOODMAN [CONSENT CASE]

ERIC CHAVEZ, ET AL.,

Plaintiff, 

v. 

GRILL ENTERPRISES, LLC AND 

RUBEN SIERRA, 

Defendants.

_______________________/

[DEFENDANTS’ PROPOSED] VERDICT FORM

(For Leonel Diaz)

Do you find from a preponderance of the evidence:

1. That Grill Enterprises, LLC failed to pay Leonel Diaz the 

minimum wages required by law:

Answer Yes or No _____________

If you answered “NO” to Question 1, you are to answer no more 

questions, and please sign and date your verdict form.

If you answered “YES” to Questions 1, please answer Question 

2.

Case 1:20-cv-22603-JG Document 191-1 Entered on FLSD Docket 05/19/2023 Page 1 of 5
2. That Grill Enterprises, LLC required Leonel Diaz to participate 

in a “tip pool”?

Answer Yes or No _____________

If you answered “NO” to Question 2, you are to answer no more 

questions, and please sign and date your verdict form.

If you answered “YES” to Question 2, please answer Question 3.

3. That the “tip pool” during “Phase I” (from 6/23/17 to 1/4/19) was 

invalid?

Answer Yes or No _____________

4. That the “tip pool” during “Phase II” (from 1/18/19 – 3/27/20) 

was invalid?

Answer Yes or No _____________

If you answered “NO” to Questions 3 and 4, you are to answer 

no more questions, and please sign and date your verdict form.

If you answered “YES” to Questions 3 and/or 4, please answer 

Question 5.

Case 1:20-cv-22603-JG Document 191-1 Entered on FLSD Docket 05/19/2023 Page 2 of 5
5. That one or both Defendants “willfully” violated the minimum 

wage laws?

Answer Yes or No _____________

6. That Leonel Diaz waived his right to recover any damages owed 

to him before the workweek ending March 9, 2019 by signing the DOL WH58 form: 

Answer Yes or No _____________

7. That Leonel Diaz should be awarded damages?

Answer Yes or No _____________

If your answer is “No,” you are to answer no more questions, and 

please sign and date your verdict form.

If your answer is “Yes” you must answer one of the following 

Questions, depending on your answers to Questions 3 through 6.

Phase I Questions:

Phase I: If your answer to Question 3

is “No,” answer no more “Phase I” questions

and go to the “Phase II” questions.

Phase I: If your to Question 6 is “Yes”

answer no more “Phase I” questions

and go to the “Phase II” questions.

Case 1:20-cv-22603-JG Document 191-1 Entered on FLSD Docket 05/19/2023 Page 3 of 5
Phase I: If your answer to Question 3 is

“Yes,” and your answer to Question 5

is “Yes,” and your answer to Question 6

is “No,” what amount is Diaz owed

from 5/11/18 to 1/4/19? $_____________

Phase I: If your answer to Question 3 is

“Yes,” and your answer to Question 5

is “No,” and your answer to Question 6

is “No,” what amount is Diaz owed

from 6/23/18 to 1/4/19? $_____________

Phase II Questions:

Phase II: If your answer to Question 4

is “No,” answer no more “Phase II”

questions and go to Question 8.

Phase II: If your answer to Question 4 is

“Yes,” and your answer to Question 6

is “No,” what amount Diaz he owed

from 1/18/19 to 11/8/19? $_____________

Phase II: If your answer to Question 4 is

“Yes,” and your answer to Question 6

is “Yes,” what amount is Diaz owed

from 3/9/18 to 11/8/19? $_____________

8. That Ruben Sierra also was an employer of Leonel Diaz:

Answer Yes or No _____________

Case 1:20-cv-22603-JG Document 191-1 Entered on FLSD Docket 05/19/2023 Page 4 of 5
SO SAY WE ALL.

___________________________

Foreperson’s Signature

DATE: ___________________

Case 1:20-cv-22603-JG Document 191-1 Entered on FLSD Docket 05/19/2023 Page 5 of 5