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 A, I, H Chavez time and pay 

records, produced during the 

course of discovery. 

 D2 A, I, H Diaz time and pay records, 

produced during the course 

of discovery. 

 D3 A, I, H Chavez ADP Earnings 

Statements (e.g. ECF No. 

78-2, P. 1). 

 D4 A, I, H Diaz ADP Earnings 

Statements (e.g. ECF No. 

78-2, P. 1). 

 D5 A, I, H Chavez Bi-Weekly Shift/ 

Payroll Reports (e.g. ECF 

No. 78-2, P. 2). 

 D6 A, I, H Diaz Bi-Weekly Shift/ 

Payroll Reports (e.g. ECF 

No. 78-2, P. 1). 

DEFENDANTS’ EXHIBIT LIST 

Case No.: 20-22603-CIV-GOODMAN 

Case 1:20-cv-22603-JG Document 144-2 Entered on FLSD Docket 04/24/2023 Page 1 of 4
Chavez vs. Grill Enterprises, LLC CASE NO. 

20-22603-CIV-COOKE/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*

 D7 A, I, H Chavez Bi-Weekly Payroll 

Details Reports (e.g. ECF 

No. 65-6). 

 D8 A, I, H Diaz Bi-Weekly Payroll 

Details Report (e.g. ECF 

No. 65-6). 

 D9 A, I, H Chavez Clock Out Reports 

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

 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 A, I, H, UP, R Documents exchanged with 

the DOL, Wage and Hour 

Division (as redacted). 

 D16 I Plaintiffs’ respective answers 

to Defendants’ 

Interrogatories, and all 

documents produced 

therewith. 

 D17 I Plaintiffs’ respective 

supplemental answers to 

Defendants’ Interrogatories, 

and all documents produced 

therewith. 

Case 1:20-cv-22603-JG Document 144-2 Entered on FLSD Docket 04/24/2023 Page 2 of 4
Chavez vs. Grill Enterprises, LLC CASE NO. 

20-22603-CIV-COOKE/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*

 D18 I Plaintiffs’ respective 

responses to Defendants’ 

Requests for Production of 

Documents, and all 

documents produced 

therewith. 

 D19 I Plaintiffs’ respective 

supplemental responses to 

Defendants’ Request for 

Production of Documents, 

and all documents produced 

therewith. 

 D20 I Plaintiffs’ respective 

responses to Defendants’ 

Second Request for 

Production of Documents, 

and all documents produced 

therewith. 

 D21 I Plaintiffs’ respective 

supplemental responses to 

Defendants’ Second Request 

for Production of 

Documents, and all 

documents produced 

therewith. 

 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 Chavez’s Affidavit (ECF 

No. 65), subject to 

objections. 

 D25 UP Diaz’s Affidavit (ECF No. 

66), subject to objections. 

 D26 I, R, UP Chavez’s Deposition (ECF 

No. 67-1), subject to 

objections. 

Case 1:20-cv-22603-JG Document 144-2 Entered on FLSD Docket 04/24/2023 Page 3 of 4
Chavez vs. Grill Enterprises, LLC CASE NO. 

20-22603-CIV-COOKE/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*

 D27 A, I, R, H DOL WHD Fact Sheet #15 

(ECF No. 78-3). 

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

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

(2017 to 2020) 

 D30 A, I, R, H, 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 A, I, R, H, UP All documents produced by 

Plaintiffs during the course 

of discovery in this case. 

 D33 A, I, R, H, UP All documents referenced by 

Defendants in their 

responses to Plaintiffs’ 

discovery requests in this 

case 

 D34 A, I, R, H, UP All documents referenced by 

Plaintiffs in their responses 

to Defendants’ discovery in 

this case to which there was 

no objection. 

 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 A, I, R, H, UP Any demonstrative exhibits, 

charts, graphs, timelines, 

and blow-ups, etc. 

Defendants reserve the right to amend or supplement this list. 

Case 1:20-cv-22603-JG Document 144-2 Entered on FLSD Docket 04/24/2023 Page 4 of 4