UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Miami Division

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

Erik Chavez, individually, and on 

behalf of others similarly situated,

Plaintiff,

vs.

Grill Enterprises, LLC, a Florida 

limited liability company, d/b/a “Los 

Parrilleros” and “Parrilleros Tavern”, 

and; 

Ruben Sierra, individually,

Defendants.

PROPOSED VERDICT FORM

Verdict form proposed by Plaintiffs (to which Defendants object) 

are italicized. 

Verdict form proposed by Defendants (to which Defendants 

object) are bold-faced. 

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Miami Division

Case No.: 1:20-cv-22603-GOODMAN

[CONSENT]

Erik Chavez, individually, and on behalf 

of others similarly situated,

Plaintiff,

vs.

Grill Enterprises, LLC, a Florida 

limited liability company, d/b/a “Los 

Parrilleros” and “Parrilleros Tavern”, 

and; 

Ruben Sierra, individually,

Defendants.

[PROPOSED] SPECIAL VERDICT FORM

PAYMENT OF MINIMUM HOURLY WAGE

Do you find from a preponderance of the evidence:

1. That Plaintiffs were engaged in commerce, or employed by an 

enterprise engaged in commerce?

Answer Yes or No _____________

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2. That Defendant Grill Enterprises, LLC required or facilitated the 

Plaintiffs’ participation in an invalid “tip pool”? 

Answer Yes or No _____________

3. That Defendant Grill Enterprises, LLC kept any portion of Plaintiffs’ 

tips?

Answer Yes or No _____________

4.1. That one or both Defendants Defendant Grill Enterprises, LLC

failed to fully pay Erik Chavez the minimum hourly wage due on any regularly 

scheduled pay day, as required by law?

Answer Yes or No _____________

Please go on to answer the next question.

2. That Leonel Diaz waived his right to recover any damages 

from Defendants from March 11, 2017, through the workweek ending 

March 9, 2019: 

Answer Yes or No _____________

Please go on to answer the next question.

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5.3. That one or both Defendants Defendant Grill Enterprises, LLC

failed to fully pay Leonel Diaz the minimum hourly wage due on any regularly 

scheduled pay day, as required by law?

Answer Yes or No _____________ 

Please go on to answer the next question.

6.4. If you answered “Yes” to either question 4 1. Or question 5 3, 

above, do you find that one or more of the Defendants Defendant Grill 

Enterprises, LLC acted willfully violated the minimum wage laws?

Answer Yes or No _____________

Please go on to answer the next question.

7.5. If your answer is answered NO to question 3, please proceed to 

Question No. 9; if you answered YES to question 5. 3., above, how much is 

Erik Chavez due on account of unpaid minimum wages should Erik Chavez be 

awarded damages?

Answer Yes or No _____________

If your answer is “Yes”,

In what amount? $_____________

Please go on to answer the next question.

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8.6. If your answer is answered NO to Question No. 3, please proceed 

to Question No. 9; if you answered YES to question 6 Question No. 4, above, 

how much is Leonel Diaz due on account of unpaid minimum wages should 

Leonel Diaz be awarded damages?

Answer Yes or No _____________

If your answer is “Yes”,

In what amount? $_____________

Please go on to answer the next question.

9.7. If you answered “Yes” to Question No. either question 7 5 or 

question 8 6, above, do you find that besides Grill Enterprises, LLC, 

Defendant Ruben Sierra should be individually liable for the corresponding 

damages as an owner or officer with operational control over the restaurant also 

was an employer of Plaintiffs?

Answer Yes or No _____________

SO SAY WE ALL.

___________________________

Foreperson’s Signature

DATE: ___________________

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