UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

Objection Codes (SDFL Local Rule 16.1) 

A – Authenticity H – Hearsay 

I – Contains inadmissible matter UP – Unduly prejudicial 

R – Relevancy P – Privileged 

 

*Include a notation as to the location of any exhibit not held with the case file or not available because of size. Page 1 of 4

Erik Chavez, et al., 

vs.

Grill Enterprises, LLC, et al.

PRESIDING JUDGE PLAINTIFF’S ATTORNEY(S) DEFENDANTS’ 

ATTORNEY(S) 

Hon. Jonathan Goodman Anthony F. Sanchez Todd W. Shulby 

Brian H. Pollock 

TRIAL DATE(S) COURT REPORTER COURTROOM DEPUTY 

May 8, 2023 

PLF. 

NO. 

DEF. 

NO. 

DATE 

OFFERED MARKED OBJECTION ADMITTED DESCRIPTION OF EXHIBITS*

 – EXHIBITS – 

 D1 

 D2 

 D3 A, I, H, UP, R Chavez ADP Earnings 

Statements (e.g. ECF No. 

78-2, P. 1). 

 D4 A, I, H, UP, R Diaz ADP Earnings 

Statements (e.g. ECF No. 

78-2, P. 1). 

 D5 

 D6 

 D7 

 D8 

 D9 A, I, H, UP, R Chavez Clock Out Reports 

(e.g. ECF No. 70-1). 

DEFENDANTS’ 

UPDATED EXHIBIT LIST 

Case No.: 20-22603-CIV-GOODMAN 

Case 1:20-cv-22603-JG Document 173-1 Entered on FLSD Docket 05/05/2023 Page 1 of 4
Chavez vs. Grill Enterprises, LLC CASE NO. 

20-22603-CIV- GOODMAN 

*Include a notation as to the location of any exhibit not held with the case file or not available because of size. Page 2 of 4

PLF. 

NO. 

DEF. 

NO. 

DATE 

OFFERED MARKED OBJECTION ADMITTED DESCRIPTION OF EXHIBITS*

 D10 A, I, H, UP, R Diaz Clock Out Reports 

(e.g. ECF No. 70-2). 

 D11 A, I, H, UP, R Chavez Tip/ Tip Out 

Records (e.g. ECF No. 65-7, 

P. 3). 

 D12 A, I, H, UP, R Diaz Tip/ Tip Out Records 

(e.g. ECF No. 65-7, P. 3). 

 D13 A, H, I, UP, R Employee Schedule (Covid 

19), produced by Defendants 

during the course of 

discovery. 

 D14 A, H, I, UP, R Sales records and customer 

receipts, produced by 

Defendants during the 

course of discovery. 

 D15 

 D16a I, UP, R Plaintiff Erik Chavez’s 

answers to Defendants’ 

Interrogatories, and all 

documents produced 

therewith. 

 D16b I, UP, R Plaintiff Leonel Diaz’s 

answers to Defendants’ 

Interrogatories, and all 

documents produced 

therewith. 

 D17a I, UP, R Plaintiff Erik Chavez’s 

supplemental answers to 

Defendants’ Interrogatories, 

and all documents produced 

therewith. 

 D17b I, UP, R Plaintiff Leonel Diaz’s 

supplemental answers to 

Defendants’ Interrogatories, 

and all documents produced 

therewith. 

Case 1:20-cv-22603-JG Document 173-1 Entered on FLSD Docket 05/05/2023 Page 2 of 4
Chavez vs. Grill Enterprises, LLC CASE NO. 

20-22603-CIV- GOODMAN 

*Include a notation as to the location of any exhibit not held with the case file or not available because of size. Page 3 of 4

PLF. 

NO. 

DEF. 

NO. 

DATE 

OFFERED MARKED OBJECTION ADMITTED DESCRIPTION OF EXHIBITS*

 D18a I, UP, R Plaintiff Erik Chavez’s 

responses to Defendants’ 

Requests for Production of 

Documents, and all 

documents produced 

therewith. 

 D18b I, UP, R Plaintiff Leonel Diaz’s 

responses to Defendants’ 

Requests for Production of 

Documents, and all 

documents produced 

therewith. 

 D19a I, UP, R Plaintiff Erik Chavez’s 

supplemental responses to 

Defendants’ Request for 

Production of Documents, 

and all documents produced 

therewith. 

 D19b I, UP, R Plaintiff Leonel Diaz’s 

supplemental responses to 

Defendants’ Request for 

Production of Documents, 

and all documents produced 

therewith. 

 D20 

 D21 

 D22 I, R, UP Plaintiff’s Amended 

Complaint (ECF No. 8). 

 D23 I, R, UP Plaintiff’s FLSA Statement 

of Claim (ECF No. 8). 

 D24 UP Documents appended to 

Chavez’s Affidavit (ECF 

No. 65) (but not Affidavit 

itself) 

Case 1:20-cv-22603-JG Document 173-1 Entered on FLSD Docket 05/05/2023 Page 3 of 4
Chavez vs. Grill Enterprises, LLC CASE NO. 

20-22603-CIV- GOODMAN 

*Include a notation as to the location of any exhibit not held with the case file or not available because of size. Page 4 of 4

PLF. 

NO. 

DEF. 

NO. 

DATE 

OFFERED MARKED OBJECTION ADMITTED DESCRIPTION OF EXHIBITS*

 D25 UP Documents appended to 

Diaz’s Affidavit (ECF No. 

66)(But not Affidavit itself). 

 D26 

 D27 I, R, UP DOL WHD Fact Sheet #15 

(ECF No. 78-3). 

 D28 A, I, R, UP WH-58 Signed by Diaz 

 D29 A, I, R, UP W-2’s issued to Chavez 

(2017 to 2020) 

 D30 A, I, R, UP W-2’s issued to Diaz (2017 

to 2019 – or as limited to 

2019 if claims released by 

WH-58 Form he signed) 

 D31 A, I, R, H, UP All documents produced by 

Defendants during the 

course of discovery in this 

case. 

 D32 

 D33 

 D34 

 D35 A, I, R, H, UP All exhibits listed by 

Plaintiffs to which there was 

no objection. 

 D36 A, I, R, H, 

UP, P 

 Any exhibits necessary for 

rebuttal or impeachment. 

 D37 

Defendants reserve the right to amend or supplement this list. 

Case 1:20-cv-22603-JG Document 173-1 Entered on FLSD Docket 05/05/2023 Page 4 of 4