Case Time Log

20-22603

Date DE Professional Services Rendered Staff Ho

06/10/20 In-office consultation with Mr. Erik Chavez to discuss the circumstances of his termination by his now former employer, Los 

Parrilleros Restaurant, and their pay practices and policies (230p-425p); completed EEOC Online Inquiry form; prepared EEOC Charge of Discrimination; prepared representation letter to EEOC to go along with his Charge of Discrimination, which we will mail since appointments are unavailable at this time

AFS 

06/12/20 Brief call to Erik Chavez to ask that he provide us with copies of his W-2 forms and tax returns from 2017 through the 

present; he has them and will bring copies to us on Monday

faz 

06/15/20 Follow up in-office meeting with Erik Chavez to review his tax returns and W-2s forms, as well as answer a few follow up 

questions regarding the tip pool at the restaurant he used to work at (1045a-1100a)

AFS 

06/18/20 Reviewed email from Ms. Nenita Giessmann from the EEOC indicating that the Chavez Charge of Discrimination received 

by the EEOC on 6/15/20 has been transferred to the Miami-Dade County Commission on Human Rights for processing; there were two attachments to the email - 1) acknowledgment of receipt of the Charge of Discrimination, stamped 6/15/20 and 2) memorandum letter dated 6/18/20 from the EEOC stating that the Charge had been transferred to the Miami-Dade County Commission on Human Rights; assigned EEOC Charge # 510-2020-04203

AFS 

06/18/20 Reviewed email from Ms. Tisha S. Rodriguez, from the Miami-Dade County Commission on Human Rights, acknowledging 

the Charge of Discrimination and providing a 7-page Notice of Charge of Discrimination as well as a form of Consent to Conduct Business Electronically for execution and return

AFS 

06/19/20 Signed and returned, via email, Consent to Conduct Business Electronically and the Invitation to Mediation Conference 

forms received yesterday

AFS 

06/23/20 1 Drafted and filed Complaint, attaching the required civil cover sheet and two proposed summonses as the exhibits thereto AFS 06/23/20 2 Reviewed Clerk's Notice of Judge Assignment (Judge Cooke, Magistrate Judge Goodman) AFS 06/23/20 3 Reviewed summonses issued by the clerk AFS 06/26/20 Forwarded complaints with summonses to Caplan process servers along with a cover email faz 06/26/20 4 Drafted and filed Notice of Filing Consent to Join of Erik Chavez, attaching the executed consent to join as the sole exhibit AFS 06/29/20 5 Reviewed the Court's Order of Referral & Order Regarding Court Practices & Procedures AFS 06/29/20 6 Reviewed the Court's Paperless Order Regarding Phone Calls to Chambers, entered 6/27/20 AFS 07/01/20 Prepared the Excel calculations, using the data from the limited pay records provided by Plaintiff, for the damages owing to 

the Plaintiff; this will be attached to the statement of claim at the time of filing

AFS 

07/01/20 Drafted and served demand letter for unpaid wages and statutory damages; served on the corporate Defendant via 

email/US mail in c/o registered agent; served the individual Defendant via US mail; attached a copy of the Excel spreadsheet we prepared earlier today

AFS 

07/02/20 Accepted incoming call from Ms. Azucena Dilley, who represented herself to be the mediator who will mediate this matter; 

Ms. Dilley indicated the Respondents have agreed to mediate this matter and asked for AFS' email address, which I provided to her; Ms. Dilley further requested I provide her with the consent to conduct business electronically and our 

agreement to mediate forms which we previously provided to Ms. Tisha Rodriguez

faz 

07/02/20 Drafted and served email to Ms. Dilley attaching the consent to conduct business electronically and our agreement to 

mediate forms she requested during our call

faz 

07/06/20 Logged in to process server's website and downloaded the return of service, invoice, and job details for the service of the 

complaint on Defendant Grill Enterprises, LLC

AFS 

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Date DE Professional Services Rendered Staff Ho07/08/20 Sent email to mediator Dilley inquiring as to the status of scheduling the mediation in this matter; reviewed response 

indicating the matter is scheduled for mediation on 7/30 @ 10a

faz 

07/17/20 7 Drafted and filed First Amended Complaint AFS 07/17/20 8 Drafted and filed Plaintiff's Statement of Initial Estimate of Wage Claims and Preliminary Calculations, attaching the

spreadsheet for the calculations as the sole exhibit

AFS 

07/17/20 9 Drafted and filed Notice of Compliance re the Court's Order...Regarding Court Practices AFS 07/17/20 Drafted and served email to Registered Agent of Defendants attaching Amended Complaint [7], Statement of Claim [8], 

and Certificate of Compliance [9]

faz 

07/27/20 Drafted and served email to mediator Ms. Azucena Dilley regarding the upcoming mediation scheduled for 7/30 @ 10a and 

requesting any specific dial-in instructions for the telephonic mediation; noted that we expect our client to join us here at 

the office for the telephonic mediation and we would dial-in jointly on the same line, alternatively, we may be reached at the 

main office line if she would be initiating the call; reviewed response, Ms. Dilley will initiate the call

faz 

07/29/20 Reviewed case file and prepared for tomorrow's mediation AFS 07/30/20 Meeting with Plaintiff just prior to the mediation re update status of the case and discuss any changes to his employment 

situation

AFS 

07/30/20 Mediation with Miami-Dade Commission on Human Rights Mediator Azucena Dilley (10a-142p); drafted and served via 

email confidential counter-proposal to mediator Dilley; we agreed to keep our latest offer open until 5, but we have otherwise reached an impasse

AFS 

07/30/20 Drafted and served public records request on the Florida Dept. of Economic Opportunity for the records of Claimant 

Chavez' unemployment file; request signed jointly by AFS and Claimant Chavez; sent via US mail and email

AFS 

08/03/20 Research re trying to find supplemental service addresses for the individual Defendant, Ruben Sierra; located possible 

office address c/o "Desa Agi, LLC" at 1401 Brickell Avenue, Suite 340, Miami, Florida 33131; possible residential address at 5702 SW 148th Avenue, Southwest Ranches, Florida, 33330

AFS 

08/03/20 Drafted and served email to Caplan process servers with supplemental addresses for service attempts faz 08/03/20 10 Drafted and filed Notice of Filing Return of Service, attaching the return of service for corporate Defendant Grill 

Enterprises, LLC as the sole exhibit

AFS 

08/04/20 11 Reviewed Clerk's CM/ECF entry re "Summons (Affidavit) Returned Executed" as to corporate Defendant Grill Enterprises,

LLC

AFS 

08/04/20 12 Reviewed Clerk's Notice to Filer re [11]; corrected by Clerk and no need to re-file AFS 08/04/20 13 Drafted and filed Plaintiff's Verified Motion for Entry of Clerk's Default Against Defendant Grill Enterprises, LLC, attached 

the return of service re Grill Enterprises, LLC and a proposed form of entry of default as the two exhibits

AFS 

08/04/20 14 Reviewed Clerk's Default entered by Clerk of Court against Defendant Grill Enterprises, LLC AFS 08/04/20 15 Reviewed the Court's Order to Show Cause requiring us to serve Defendant at the address service was effected with a 

copy of this order via US Mail

AFS 

08/04/20 16 Drafted and filed Plaintiff's Notice of Compliance with the Court's Order to Show Cause re serving copy of the order on 

Defendant

AFS 

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Date DE Professional Services Rendered Staff Ho08/04/20 Printed out copy of the Order to Show Cause [15] and Plaintiff's Certificate of Compliance [16] and mailed via First-Class 

US Mail; additionally, served the same registered agent via email at the same address we have been sending filings in this case

AFS 

08/07/20 Reviewed automated status update from Caplan Process Servers indicating individual Defendant Ruben Sierra was served 

on 8/5/20; downloaded the return of service for filing with the Court

AFS 

08/07/20 17 Drafted and filed Notice of Filing Return of Service, attaching the affidavit of service as the sole exhibit; Defendants' 

answer to Amended Complaint due by 8/26/20

AFS 

08/12/20 18 Reviewed the Court's Order on Motion for Entry of Default [18] AFS 08/14/20 19 Reviewed Notice of Attorney Appearance filed by attorney Todd W. Shulby, Esq., on behalf of both Defendants; updated 

service list accordingly

AFS 

08/14/20 20 Reviewed Defendants' Certificate of Interested Persons and Corporate Disclosure Statement AFS 

08/14/20 21 Reviewed Defendants' Notice of Pendency of Other Actions; no pending/related cases disclosed; note that this filing is 

consistent with the Middle District of Florida Local Rules and not the SDFL

AFS 

08/18/20 Reviewed email from opposing counsel Shulby stating Defendants were unaware the corporate had previously been 

served and would be filing a motion to set aside the default; sent response noting our objection and adding that the 

individual Defendant, Ruben Sierra, had participated in a mediation already on 7/30/20 on behalf of both himself and the 

corporate Defendant

AFS 

08/18/20 22 Analyzed Defendants' Answer and Affirmative Defenses, filed on behalf of both Defendants AFS 08/19/20 Drafted and served "Service of Court Document" email to opposing counsel attaching the Court's Order of Referral and 

Order Regarding Court Practices and Procedures [5] and Plaintiff's Statement of Claim [8], now that counsel has made an appearance on behalf of both Defendants

faz 

08/19/20 23 Drafted and filed Plaintiff's Notice of Full Compliance re serving the Court's Order of Referral and Order Regarding Court 

Practices and Procedures [5], and Plaintiff's Statement of Claim [8], both of which were served via email earlier today

AFS 

08/19/20 24 Analyzed Defendant's (Grill Enterprises, LLC) Motion to Set Aside Final Default Judgment AFS 09/02/20 25 Reviewed Defendants' Response to Plaintiff's Statement of Claim [16]; this "response" basically says Defendants cannot 

understand Plaintiff's Statement of Claim and therefor cannot respond appropriately

AFS 

09/02/20 26 Reviewed Defendants' Notice of Full Compliance with Order [5] AFS 

09/02/20 27 Drafted and filed Plaintiff's Response in Opposition to Defendant's [Grill Enterprises, LLC] Motion to Set Aside Final Default 

Judgment [24], attaching exhibits related to the mediation we attended on 7/30/20

AFS 

09/02/20 Reviewed email from opposing counsel Shulby offering to either permit us to come inspect documents, have them copied 

and delivered, or scanned and delivered to us; sent response stating whatever method is fastest

AFS 

09/10/20 28 Reviewed Defendant's [Grill Enterprises, LLC] Reply in Support of Defendant's Motion to Vacate Final Default Judgment AFS 10/14/20 Reviewed email from Mercy Obando, HRFEP Specialist, Miami-Dade County Human Resources Department, Human 

Rights & Fair Employment Practices regarding her request for dates of availability for a conference; will check with our client and get back to her

faz 

10/30/20 29 Analyzed the Court's Order Requiring Additional Briefing and Setting Briefing Schedule re Motion to Set Aside Default; 

calendared deadlines accordingly

AFS 

11/04/20 Call to Plaintiff Chavez to discuss possibility of AFS 

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Date DE Professional Services Rendered Staff Ho11/06/20 Drafted Stipulation for Voluntary without Prejudice as to Defendant Ruben Sierra only and sent to opposing counsel along 

with a brief email for his review and comments/position; reviewed response, opposing counsel will check with his client and 

get back to us, but it will not be today

AFS 

11/06/20 32 Drafted and filed Plaintiff's Memorandum re whether inconsistent judgments could potentially be entered if the Court does 

not set aside default against Defendant Grill Enterprises

AFS 

11/06/20 33 Drafted and filed Plaintiff's Memorandum re whether default judgment may be entered against Defendant Grill Enterprises 

regarding the claims made in Amended Complaint

AFS 

11/06/20 34 Drafted and filed Plaintiff's Conditional Motion of Dismissal without Prejudice as to Defendant Ruben Sierra AFS 11/06/20 30 Reviewed Defendants' Brief Regarding Impact of Plaintiff's Amended Complaint AFS 11/06/20 31 Reviewed Defendants' Brief Regarding Inconsistent Judgments AFS 11/10/20 Brief call to Erik Chavez to ask that he provide us with copies of his W-2 forms and tax returns from 2017 through the 

present; he has them and will bring copies to us on Monday

11/10/20 Brief call to Erik Chavez re his availability for a conference, requested by Ms. Obando from Miami-Dade County; drafted

and served response to Ms. Obando's 10/14 email; reviewed reply setting the conference call for 12/4 @ 11a

faz 

11/20/20 35 Analyzed Defendants' Response in Opposition to Plaintiff's Conditional Motion to Dismiss Defendant Ruben Sierra [34] AFS 11/30/20 36 Drafted and filed Plaintiff's Reply to Defendants' Response [35] in Opposition to Plaintiff's Conditional Motion to Dismiss 

Defendant Ruben Sierra [34]

AFS 

12/01/20 37 Reviewed the Court's "Order Granting Defendant Grill Enterprises, LLC's Motion to Set Aside Final Default Judgment" [24] AFS 

12/02/20 Reviewed email from opposing counsel re joint scheduling report; prepared initial draft and served on opposing counsel 

with responsive email

AFS 

12/03/20 Reviewed email from opposing counsel re revisions to the joint scheduling report draft; adopted revisions and sent it back 

for his consent to file; authorized to file the joint scheduling report in its current form

faz 

12/03/20 38 Filed Joint Scheduling Report, Proposed Scheduling Order, and Consent to Magistrate Jurisdiction Form faz 12/04/20 Conference call Plaintiff Chavez (who participated from our office) with Ms. Mercy Obando, HRFEP Specialist, Miami-Dade

County Human Resources Department Human Rights & Fair Employment Practice (11a-1150a)

AFS 

12/09/20 In-office meeting with Leonel Diaz Gonzalez re his wanting to join the current lawsuit against Los Parrilleros (Grill 

Enterprises, LLC) 1040a-1145a; completed retainer paperwork, consent to join, contact sheet, etc.

AFS 

12/09/20 39 Drafted and filed Notice of Consent to Join, attaching the executed Consent to Join of Leonel Diaz as the sole exhibits 

thereto

AFS 

12/21/20 Reviewed email from opposing counsel from yesterday, propounding Defendants' first set of interrogatories and first 

request for production of documents to each Plaintiff; calendared deadline to respond; will forward these to each of the 

Plaintiffs in advance of a discovery meeting with each of them on a TBD date

AFS 

12/21/20 Drafted emails to each of the two Plaintiffs and attached copies of the discovery requests we were served with yesterday faz 12/21/20 Drafted Plaintiffs' first set of discovery requests (roggs/rpd) to Defendants and served AFS 

12/23/20 Calls to Plaintiffs re their availability for deposition; Chavez available whenever provided he has advance notice; Diaz left 

voicemail

faz 

12/28/20 Called Plaintiff Diaz re his availability for deposition; left voicemail asking him to call us re his availability for deposition and 

to confirm receipt of my 12/21 email enclosing discovery requests

faz 

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Date DE Professional Services Rendered Staff Ho01/04/21 Call with Plaintiff Diaz to confirm receipt of my 12/21/20 email attaching discovery requests and re deposition scheduling; 

asked that I forward it to him again; did so; provided dates of availability for deposition

faz 

01/06/21 Drafted and served brief email to opposing counsel providing dates of availability for deposition for the two current Plaintiffs faz 01/11/21 Reviewed email from opposing counsel re tentatively setting depositions for 2/16 and 2/17, via Zoom; sent response faz 

01/15/21 Reviewed email from opposing counsel's office, received yesterday, enclosing respective Notices of Taking Deposition; 

called each of the two current Plaintiffs to communicate the date/time of the deposition and forwarded the notices via email as well; we also scheduled appointments with both Plaintiffs for 1/27/21 @ 11a to prepare discovery responses

faz 

01/27/21 In-office discovery meeting with both Plaintiffs to prepare responses to Defendants' first set of discovery requests (3p550p); finalized respective answers to interrogatories; reviewed the documents brought by the Plaintiffs in response to 

requests for production

AFS 

02/02/21 Reviewed email from opposing counsel re discovery responses; sent response and indicated we will be providing the 

responses today via email

AFS 

02/02/21 Drafted and finalized respective responses to Defendants' first request for production of documents to each Plaintiff; 

attached responsive documents; bates stamps DIAZ0001-0038 and CHAVEZ0001-0099

AFS 

02/03/21 Reviewed email from opposing counsel re parties filed a joint scheduling report on 12/3/20 (DE 38), but no scheduling 

order has been entered; sent response and will discuss with him tomorrow by phone

AFS 

02/03/21 Reviewed Defendants' respective responses and answers to Plaintiffs' first set of discovery requests (interrogatories/rpd); 

will have to confer with opposing counsel re Defendants' responses, particularly since there are no documents produced, 

instead they will be made available during the next 2 weeks at a mutually convenient date/time at Defendants' counsel's office and at Plaintiffs' expense; calendared deadline to object and go through the Court's discovery dispute procedures

AFS 

02/04/21 Incoming call from opposing counsel and then we jointly placed call to chambers (initiated by opposing counsel), in 

accordance with the instructions in DE 6, re scheduling order; instructed that no action needed on the parties' part with respect to the scheduling order; prior to jointly calling chambers, we also discussed our objection to having to drive to 

counsel's office to inspect responsive documents; opposing counsel will seek authorization to produce responsive documents electronically

AFS 

02/11/21 Exchanged brief emails with opposing counsel re scheduling call to discuss respective discovery responses faz 02/12/21 Phone conference with opposing counsel re respective discovery responses/objections (10a-1105a); depositions of the 

Plaintiffs scheduled for 2/16 and 2/17 will be postponed; supplemental discovery responses due 2/26/21

AFS 

02/12/21 Mailed the executed authorization for release of records to Florida Dept. of Economic Opportunity re Plaintiff's 

unemployment compensation records

faz 

02/12/21 Drafted and served FOIA request to the Dept. of Labor for all investigative records re Defendants Grill Enterprises, LLC 

and Ruben Sierra

AFS 

02/12/21 Drafted and served Plaintiff's second request for production of documents and served on opposing counsel via email AFS 

02/22/21 Resubmitted our 2/12/21 U.S. Department of Labor FOIA request, but this time by fax, because we have not received the 

acknowledgment / request tracking # we were expecting; successful fax transmission and confirmation saved

faz 

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Date DE Professional Services Rendered Staff Ho02/24/21 Brief in-office meeting with Plaintiffs to go over the amended/supplemented responses to discovery in accordance with the 

discovery conference held with opposing counsel on 2/12/21

AFS 

02/25/21 Reviewed email from opposing counsel requesting that we push the date to exchange supplemental/amended responses 

to discovery back by one week; responded that we do not oppose as long as any deadlines to objections are waived; 

agreed 

AFS 

03/05/21 Reviewed email from opposing counsel requesting that we again push back the date to exchange supplemental/amended 

responses to discovery; the person best suited to prepare responses will return next week

AFS 

03/05/21 Prepared a draft of joint motion for issuance of scheduling order or, in the alternative, for a scheduling conference; will 

send to opposing counsel to see if it may be filed jointly

AFS 

03/05/21 Sent response to opposing counsel's email earlier today requesting an extension to exchange discovery responses; 

indicated we agree to mutual extension and attached the draft joint motion re scheduling order

AFS 

03/08/21 40 Filed Joint Motion for Issuance of Scheduling Order, or Order Calendaring a Scheduling Conference; opposing counsel 

wrote over the weekend the joint motion it acceptable as-is

faz 

03/08/21 41 Reviewed the Court's paperless order denying Joint Motion for Issuance of Scheduling Order, or Order Calendaring a 

Scheduling Conference [40]

AFS 

03/12/21 Finalized and served Plaintiffs' respective supplemental responses to both interrogatories and requests for production, in 

accordance with the discovery telephone conference with opposing counsel on 2/12

AFS 

03/15/21 42 Reviewed the Court's Paperless Order referring case to mediation AFS 03/15/21 Reviewed Defendants' respective supplemental responses to Plaintiffs' first request for production of documents; and also 

reviewed the Defendants' responses to Plaintiff's second request for production of documents

AFS 

03/15/21 43 Reviewed the Paperless Order Referring Case to Mediation; deadline to complete mediation 10/8/21 AFS 03/16/21 Drafted and served email to opposing counsel proposing two mediators (Karen Evans & Leslie Langbein); current deadline 

to file notice of selection is 3/24/21; deadline to complete mediation currently 10/8/21

faz 

03/17/21 Reviewed email from opposing counsel re deposition availability of the two Plaintiffs faz 03/22/21 Called each of the two Plaintiffs re their availability for virtual/zoom depositions in the coming weeks; forwarded dates to 

opposing counsel

faz 

03/22/21 Reviewed email from opposing counsel attaching the respective Notices of Taking Deposition of each of the two Plaintiffs 

(served on us 3/19/21); forwarded to the Plaintiffs for their records

faz 

03/24/21 44 Drafted and filed Request for Clerk to Appoint Mediator after being unable to agree on mediator AFS 03/24/21 45 Reviewed the Clerk's Notice of Mediator Designation; Ms. Carol Soret Cope of Salmon & Dulberg is appointed as mediator faz 04/05/21 Prepared for tomorrow's deposition of Erik Chavez (and for Wednesday's deposition of Leonel Diaz) AFS 

04/06/21 Deposition of Plaintiff Erik Chavez (10a-410p), via Zoom AFS 04/06/21 Attended deposition of Plaintiff Erik Chavez with AFS to take notes and ensure no technical issues faz 

04/07/21 Deposition of Plaintiff Leonel Diaz (10a-2p), via Zoom AFS 04/07/21 Attended deposition of Plaintiff Leonel Diaz with AFS to take notes and ensure no technical issues faz 04/07/21 Reviewed email from opposing counsel re Plaintiff Erik Chavez's discovery responses following his deposition yesterday AFS 

04/07/21 Called Florida Department of Economic Opportunity re the status of our unemployment compensation records request; left 

voicemail providing our contact information, name of our client , and date of request (2/12/21)

faz 

04/16/21 Discovery conference by phone with opposing counsel (9a-954a) AFS 

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Date DE Professional Services Rendered Staff Ho04/16/21 Placed call to Judge Goodman's chambers to obtain dates of availability for discovery; left brief voicemail with case and 

callback number

faz 

04/16/21 Drafted and served email to Florida Department of Economic Opportunity regarding the status of our records request, 

initially submitted on 7/30/20 and then resubmitted on 2/12/21 using the Department's required form of request, completed 

and signed by the Plaintiff/Claimant and AFS

faz 

04/22/21 Call with Plaintiff Chavez; will be coming in tomorrow with supplemental document production AFS 04/23/21 Prepared Plaintiff's first draft of witness list AFS 04/23/21 In-office meeting with Plaintiff Chavez re supplemental document production and amended interrogatories (245p-3p); 

reviewed his supplemental production and went over the draft of witness list with him

AFS 

04/23/21 Reviewed Defendants' witness list AFS 04/23/21 Served Plaintiff's witness list faz 04/23/21 Reviewed Defendants' amended/supplemental witness list AFS 04/26/21 Drafted and served lengthy email on opposing counsel re outstanding discovery disputes, specifically Plaintiffs' request for 

production items 9, 13, 18, 21, 23, 24

AFS 

04/28/21 Email to opposing counsel re discovery telephone conference; we will talk on 4/30/21, but might be rescheduled AFS 

04/30/21 Reviewed email from opposing counsel; discovery phone conference is postponed and we will have it sometime next week AFS 

05/04/21 Reviewed email from opposing counsel's office attaching a second amended witness list; reviewed list for amendments; 

reviewed email from opposing counsel following email from his office asking if we have any objections to the second amended witness list

AFS 

05/05/21 Drafted and served response to opposing counsel's email from yesterday re second amended witness list and also 

inquired as to what day to continue our discovery conference

AFS 

05/07/21 Reviewed email from opposing counsel re scheduling our continued telephonic discovery conference on Tuesday; sent 

response agreeing to the same

AFS 

05/10/21 Exchanged two emails with opposing counsel re scheduling continued discovery conference; set for tomorrow at 1p AFS 

05/11/21 Conference call with opposing counsel re outstanding discovery issues (1258p-107p); during the call, had FAZ send an 

exemplar of a "Clock Out Report" to opposing counsel via email

AFS 

05/11/21 Placed call to Judge Goodman's chambers to obtain dates of availability for discovery; left brief voicemail with case and 

callback number

faz 

05/12/21 Reviewed brief email from opposing counsel stating he will ask his client about the "Clock Out Report[s]" we sent 

yesterday

AFS 

05/12/21 Placed call to Judge Goodman's chambers to obtain dates of availability for discovery; left brief voicemail with case and 

callback number

faz 

05/12/21 Call to Plaintiff Chavez (320p-335p) AFS 05/12/21 Drafted and served email to Conrad Bassett of the U.S. Dept. of Labor regarding the status of our FOIA request, which was 

estimated to be completed on 3/23/21, but for which we have still not received any documents; reviewed response indicating he hopes to have it completed by the end of the month, but there is a significant backlog and there are several requestors ahead of us

faz 

05/13/21 Placed call to Judge Goodman's chambers to obtain dates of availability for discovery hearing; left brief voicemail with 

case and callback number

faz 

05/13/21 Call from Kim from Judge Goodman's chambers; received dates of availability for discovery hearing faz 

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Date DE Professional Services Rendered Staff Ho05/13/21 Drafted and served email to opposing counsel providing dates of availability for discovery hearing; reviewed email from

opposing counsel providing dates he apparently was provided by Judge Goodman's chambers; placed another call to 

Magistrate Goodman's chambers to ask whether the Court's would prefer the parties have a unified discovery hearing regarding their respective objections; told that would be fine but the parties would be limited to one total hour for all matters and the procedure would be to notice the hearing and have the other party file a cross-notice of hearing for the same time

faz 

05/13/21 Placed call to opposing counsel to inquire whether Defendants are receptive to having a single discovery hearing on all

matters; left message with staff, who indicated she would text opposing counsel to give us a call

faz 

05/18/21 1140a Placed call to opposing counsel, got voicemail; left detailed message re Judge Goodman can accommodate a joint 

discovery hearing lasting no longer than 1-hour for both parties to have their issues heard; reviewed email response from 

opposing counsel re dates the Court is available for a discovery hearing; sent reply stating we are available on those days and asking if he is so that we may notice the hearing; waiting for opposing counsel to confirm a date

faz 

05/18/21 Called Judge Goodman's chambers and spoke with Kim re discovery hearing scheduling; Court would prefer 6/10 for a 

hearing because the calendar that day is more open

AFS 

05/18/21 352p Called and left message for opposing counsel re asking that he confirm he is available for a discovery hearing on 

6/10 so it can be noticed before the date becomes unavailable

AFS 

05/18/21 605p Placed another call to opposing counsel attempting to left another message 05/18/21 Reviewed email from opposing counsel indicating he is not available on 6/10 05/18/21 46 Drafted and filed Plaintiff's Notice of Discovery hearing after parties agreed to hearing on 6/3/21 at 1030a AFS 

05/18/21 Prepared Word versions of "source materials" for discovery hearing; one file containing requests for production and all

responses/supplemental responses thereto, and one file containing the interrogatories and answers thereto

faz 

05/18/21 Prepared and served email to Judge Goodman's chambers attaching Plaintiffs' "source materials" for the 6/3/21 discovery

hearing

AFS 

05/20/21 47 Reviewed Defendants' Cross-Notice of Discovery Hearing for 6/3/21 @ 1030a AFS 05/20/21 Reviewed email from opposing counsel to Judge Goodman enclosing Word versions of Defendants' "source materials" for 

the 6/3 discovery meeting

AFS 

05/24/21 48 Reviewed the Court's Paperless Order regarding Zoom Discovery Hearing; paperless order sets the 6/3/21 noticed [46] 

and cross-noticed by the parties [47] to be heard via Zoom rather than in-person; updated calendar entry to add the Zoom 

details; parties to log in 10 minutes early

faz 

05/24/21 49 Reviewed the Court's second Paperless Order regarding Zoom Discovery Hearing; this paperless order is nearly identical 

to the first one [48] except that it sets the hearing for 6/10/21 at 11:30 a.m. (first one set the hearing for 6/3 at 1130a); updated our calendar accordingly

faz 

05/24/21 50 Reviewed Clerk's Notice of Docket Correction re [48]; due to error, access to [48] is restricted faz 05/31/21 Reviewed email from opposing counsel requesting written consent to permit Defendants to file an amended 

answer/affirmative defenses to admit they have >$500,000 in gross yearly revenues for jurisdictional purposes

AFS 

06/01/21 Sent brief response to opposing counsel's email from yesterday stating Plaintiffs do not consent, and in fact oppose, 

Defendants amending their answer & affirmative defenses

AFS 

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Date DE Professional Services Rendered Staff Ho06/03/21 51 Analyzed "Defendants' Motion to File Amended Complaint Without Written Consent of Plaintiff"; the document title is a typo 

as the motion is for leave to file an Amended Answer , rather than an Amended Complaint; reviewed the attached 

proposed amended answer and compared vis-a-vis the original answer for differences

AFS 

06/03/21 52 Reviewed Defendants' Motion for Leave to File Amended Answer . . . ; this is the same as [51] except that it corrects the 

document title

AFS 

06/03/21 53 Reviewed Defendants' Notice of Striking [51] AFS 06/04/21 Reviewed email from opposing counsel re continued efforts to resolve discovery dispute prior to the discovery hearing 

scheduled for 6/10/21; sent response

AFS 

06/08/21 Reviewed email, received yesterday evening, from opposing counsel attaching supplemental production by Defendants; 

the production consisted of 14 pages relating to the Dept. of Labor's investigation of Defendants several years ago; the production was received in an email without any formal pleading therewith and without bates stamps; reviewed the 

supplemental production; there are a few pay stubs, Dept. of Labor releases, but no narrative report regarding the investigation

AFS 

06/08/21 Brief in-office meeting with Plaintiff Chavez to verify and finalize his amended interrogatory responses and supplemental 

document production

AFS 

06/08/21 Drafted and served email attaching Plaintiff Chavez's amended responses to interrogatories and second supplemental 

responses to document production; produced bates stamps CHAVEZ 0100-0190)

faz 

06/09/21 Prepared for tomorrow's discovery hearing before Judge Goodman; reviewed all discovery requests and responses to 

date, including all supplements; respective parties' source materials; gathered together several PDF exemplars for potential use at the discovery hearing to support arguments why Defendants should be compelled to produce documents

AFS 

06/09/21 Reviewed email from Ms. Kim Rollnick regarding Plaintiff's source materials for hearing tomorrow; sent response attaching 

the same source materials previously delivered on 5/18/21

AFS 

06/10/21 Zoom discovery hearing before Judge Goodman (1130a-1230p); the remainder of this hearing will take place on 6/14/21 @ 

2p

AFS 

06/10/21 54 Minute Entry for Zoom discovery hearing held earlier today AFS 06/10/21 55 Paperless Order setting continued Zoom discovery hearing on 6/14/21 @ 2p AFS 06/10/21 Reviewed email from Ms. Evangeline Rambeau from the Miami-Dade County Commission on Human Rights, enclosing a 

determination letter and a narrative report regarding the charge of discrimination made by Erik Chavez; reviewed both 

documents

AFS 

06/10/21 56 Reviewed the Court's Partial Post-Discovery Hearing Administrative Order memorializing the rulings during this morning's 

Zoom discovery hearing; calendared Defendants' deadline of 6/24/21 to provide responsive documents; discovery hearing will continue on 6/14 @ 2pm

AFS 

06/10/21 57 Drafted and filed Plaintiffs' response in opposition to Defendants' motion for leave to file amended answer [52] AFS 

06/11/21 58 Reviewed Defendants' Corrected Cross-Notice of Continued Discovery Hearing; this corrects [47] and correctly identifies 

the items Defendants would like heard at the continued discovery hearing set for 6/14/21 @ 2p

AFS 

06/14/21 Continuation of Zoom discovery hearing which began on 6/10 and was continued to today (2p-330p); Plaintiffs ordered to 

supplement document production; Defendants ordered to supplement document production and interrogatory responses; the Court also imposed a fine against Defendants and their counsel; order to follow

AFS 

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Date DE Professional Services Rendered Staff Ho06/14/21 59 Minute Entry for Zoom discovery hearing which was continued today from 6/11/21 (2p-330p) AFS 06/15/21 Reviewed email from opposing counsel re notice of third-party subpoenas for documents to a) Sorrel Enterprises, LLC and

b) A. Falero Trucking, Inc.; reviewed the two subpoenas, both of which ask for the same documents; documents to be 

produced by 7/6/21; calendared

AFS 

06/16/21 Incoming call from Kim Rollnick from Judge Goodman's chambers (259p-302p); called to confirm the spelling of Pixmark 

USA Corp and Sorrel Enterprises, LLC; these two entities were part of the issues argued during the discovery hearing on 

6/14/21

AFS 

06/16/21 60 Analyzed Defendants' Reply to Response [57] to their Motion for Leave to File Amended Answer/Defenses [52] AFS 06/17/21 61 Reviewed the Court's Post-Discovery Hearing Administrative Order and compared the documents we currently have vs the 

ones that we are ordered to produce; this is the order related to the 6/14/21 continuation of the discovery hearing; 

calendared deadlines set forth therein;

AFS 

06/17/21 Reviewed email from opposing counsel enclosing Defendants' Notice of Subpoenas and its two attachments; these appear 

to be identical to the ones we received 6/15/21

AFS 

06/17/21 Forwarded the Court's discovery order [61] from this morning with a cover email indicating we will call him shortly faz 

06/17/21 Call (401-424p) with Plaintiff Chavez re the discovery order [61]; Chavez stated that AFS 06/18/21 Reviewed the dozen or so emails from Plaintiff Chavez received last night, each email separately faz 

06/18/21 Reviewed supplemental documents received from Plaintiff Chavez and compiled them into a single supplemental 

production, to be served on 6/21/21

AFS 

06/18/21 In-office meeting (1125a-1250p) with Plaintiff Chavez re clarification of some questions with respect to the supplemental 

production; prepared two Notices of Compliance to be filed on 6/21/21 and 7/1/21, respectively, and each of which was verified by Plaintiff Chavez, certifying compliance with the Court's most recent discovery order [61]

AFS 

06/21/21 Downloaded and saved the following items, served on us after-hours on 6/18: 1) Defendant Ruben Sierra Supplemental 

Answers to Plaintiff's First Set of Interrogatories 2) Defendant Grill Enterprises Supplemental Answers to Plaintiff's First 

Set of Interrogatories 3) Defendants Joint Supplemental Response to Plaintiffs' Second Request for Production of 

Documents; these were the items compelled by the Court's discovery order [61]; total of 308 pages produced, ready for AFS review

faz 

06/21/21 Reviewed Defendants' Second Request for Production of Documents to Leonel Diaz and Defendants' Second Request for 

Production of Documents to Erik Chavez; will forward these to Plaintiffs in advance of discussing these items with them; 

these were served on us Sat 6/19/21; responses due 7/19/21

AFS 

06/21/21 Drafted brief cover email to Plaintiffs attaching Defendants' Second Request for Production of Documents to Plaintiffs faz 06/21/21 Served Plaintiff Chavez's supplemental responses to Defendants' first request for production, in compliance with the 

Court's recent discovery order [61); produced bates stamps CHAVEZ 0191-0220

faz 

06/21/21 62 Filed the Notice of Compliance with the Court's "Post-Discovery Hearing Administrative Order" [61] Pertaining to "Topic 4", 

prepared with Erik Chavez on 6/18/21

faz 

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Date DE Professional Services Rendered Staff Ho06/22/21 Reviewed emails from opposing counsel attaching document production; downloaded and saved the 8 exemplar PDFs 

received from opposing counsel (totaling 478 pages) re tip records; ready for AFS review; the final email was not production, but rather comments regarding request for production item 9

faz 

06/24/21 Reviewed emails from opposing counsel attaching document production; downloaded and saved 42 PDF files totaling 863 

pages; ready for AFS review

faz 

06/25/21 Reviewed email from opposing counsel's office providing supplemental document production; ppp loan for the Defendant; 

saved to e-file; ready for AFS review

faz 

06/25/21 Drafted and served email to opposing counsel indicating I will review all the supplemental documents received over the 

past week starting next week and get back to him; reviewed response

AFS 

06/29/21 Reviewed email from opposing counsel re deposition of Pixmark USA corporate representative AFS 07/01/21 63 Filed Notice of Compliance with the Court's "Post-Discovery Hearing Administrative Order" [61] Pertaining to "Topic 3", 

prepared with Erik Chavez on 6/18/21

faz 

07/07/21 Reviewed email from opposing counsel attaching five non-party subpoenas to the following entities: Miami-Dade 

Commission on Human Rights, (2x) Florida Dept. of Economic Opportunity, Florida Commission on Human Rights, Equal Employment Opportunity Commission; responsive documents due by 7/23/21

AFS 

07/08/21 Drafted Plaintiffs' second set of interrogatories and third request for production of documents to Defendants AFS 07/08/21 Served Plaintiff's second set of interrogatories and third request for documents upon opposing counsel via email faz 

07/12/21 Reviewed email from opposing counsel seeking to take the deposition of the 30(b)(6) witness of Pixmark USA; drafted and

served response and also requested dates of availability for defense witness Ruben Sierra and 30(b)(6) witness; also indicated we would accept the payroll report summaries as a substitute for the daily shift slips reflecting the tips earned 

during each shift

AFS 

07/19/21 Call with Leonel Diaz re responses to Defendants' second request for production of documents AFS 07/19/21 Call to Erik Chavez; left voicemail; incoming call from Erik Chavez re Defendants' second request for production of 

documents, and depositions of Defendants' witnesses (537p-549p)

AFS 

07/19/21 Prepared Notice of Taking Deposition of Ruben Sierra (8/4) and Notice of Taking Deposition of Vanessa Carrillo (8/3); both 

will be done via Zoom as previously agreed

AFS 

07/19/21 Prepared drafts of respective Plaintiff responses to Defendants' Second Request for Production of Documents AFS 07/19/21 Served the respective Notices of Taking Deposition of Sierra and Carrillo on opposing counsel faz 07/19/21 Drafted and served brief email to opposing counsel re deposition scheduling; AFS 07/19/21 Served Plaintiffs Chavez and Diaz respective responses to Defendants' Second Request for Production of Documents faz 07/21/21 Reviewed email from opposing counsel addressed to AFS seeking to discuss Plaintiffs' responses to discovery served 

earlier this week on 7/19/21; responded to this email on behalf of AFS who is out through the rest of this week and 

suggested a conference call on Monday when AFS will be back; scheduled call for noon on 7/26/21

faz 

07/26/21 Sent email to the Florida Dept. of Economic Opportunity requesting copy of Plaintiff Leonel Diaz' unemployment 

compensation records

faz 

07/26/21 Call with opposing counsel Shulby to discuss a few discovery matters (12p-1228p); Ruben Sierra's deposition will be 

moved from 8/4 to 8/5; discussed defense witness Vanessa Carrillo's attendance at her deposition, she may require a 

subpoena but it is Defendants' intention to produce her voluntarily; discussed Plaintiffs' recent responses to Defendants' 

RPD.2

AFS 

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Date DE Professional Services Rendered Staff Ho07/26/21 Prepared and served Amended Notice of Deposition for Ruben Sierra; rescheduled his deposition from 8/4 to 8/5, per 

Defendants request

faz 

07/26/21 Prepared Subpoena for Deposition for Vanessa Carrillo and forwarded to Caplan process servers for service on Ms. 

Carrillo for her deposition next Tuesday since Defendants cannot provide assurances she will appear voluntarily 

AFS 

07/26/21 Drafted and served email to opposing counsel memorializing our conversation earlier today re discovery matters; attached 

copy of the subpoena for deposition of Vanessa Carrillo

AFS 

07/26/21 Reviewed responsive email from opposing counsel responding to my earlier from earlier today memorializing our 

telephone call

AFS 

07/27/21 Reviewed automated status update from Caplan Process Servers indicating defense witness and management employee 

of the Defendants Vanessa Carrillo has been served with the subpoena for deposition currently set for 8/3 @ 10a

AFS 

07/28/21 Downloaded the return of service of the subpoena for deposition served on Vanessa Carrillo yesterday faz 07/29/21 Email from opposing counsel indicating Ms. Carrillo will be attending her deposition on 8/3 voluntarily AFS 07/30/21 Email to Robert Castillo to see if he can cover the depositions of Carrillo and Sierra currently scheduled for 8/3 and 8/5, 

respectively; he can cover both

faz 

07/30/21 Reviewed email from opposing counsel indicating Vanessa Carrillo will attend voluntarily; sent brief response indicating we 

will provide the Zoom connection details on Monday

faz 

07/30/21 Emails with Jose Vega (Legal Translations) to see if he can cover the 8/3 and 8/5 depositions; he can; secured services faz 08/02/21 Drafted and served email to opposing counsel enclosing Zoom details for tomorrow's deposition of defense witness 

Vanessa Carrillo; sent emails to both Jose Vega (interpreter) and Robert Castillo (court reporter) as well containing the Zoom details and the Notice of Taking Deposition

faz 

08/02/21 Prepared for tomorrow's Zoom deposition of Vanessa Carrillo; went through the documents produced by Defendants todate and segregated potential exhibits for tomorrow's deposition as individual PDFs in order to share during the deposition AFS 08/03/21 Zoom deposition of Vanessa Carrillo (10a-530p) AFS 08/05/21 Zoom deposition of Ruben Sierra (10a-240p) AFS 08/05/21 Uploaded the PDF exhibits used in the Zoom depositions of Vanessa Carrillo and Ruben Sierra to our cloud account for 

access by the court reporter

faz 

08/06/21 Reviewed lengthy email from opposing counsel re "Chavez/ Diaz v. Grill Enterprises/ Sierra - DISCOVERY" AFS 

08/10/21 Analyzed Defendants' responses to Plaintiffs' RPD.3 and answers to Plaintiffs' ROGGS.2, both received late last night; 

various responses to documents requests state that responsive documents will be produced within two weeks; the responses may necessitated setting a discovery hearing

AFS 

08/18/21 Calls to both Plaintiffs to schedule appointments for them to come in and review/sign affidavits in support of summary 

judgment; both are coming in on 8/23/21

faz 

08/18/21 Prepared initial drafts of affidavits of Plaintiffs Erik Chavez and Leonel Diaz in support of motion for summary judgment; 

these affidavits will be more or less the outline of a statement of undisputed facts

AFS 

08/19/21 Prepared initial draft of Plaintiffs' Statement of Materials Facts in support of motion for summary judgment; one item will be 

attached as an exhibit

AFS 

08/20/21 Prepared initial draft of Plaintiffs' Motion for Summary Judgment AFS 08/23/21 In-office meeting with Plaintiff Diaz re affidavit in support of motion for summary judgment (1130-1230p); revised affidavits AFS 

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Date DE Professional Services Rendered Staff Ho08/23/21 Made revisions to the Statement of Facts and put in final AFS 08/23/21 In-office meeting with Plaintiff Chavez re affidavit in support of motion for summary judgment (320p-410p); revised 

affidavits

AFS 

08/23/21 Finalized Plaintiffs' Motion for Summary Judgment AFS 08/23/21 Redacted all social security numbers and Florida Dept. of Revenue account number from the ~100 pages of RT-6 tax 

forms produced by Defendants; these will be exhibits to the Plaintiffs' respective affidavits

faz 

08/23/21 65 Filed Affidavit of Plaintiff Erik Chavez in Support of Motion for Summary Judgment; 8 exhibits faz 08/23/21 66 Filed Affidavit of Plaintiff Leonel Diaz in Support of Motion for Summary Judgment; 8 exhibits faz 08/23/21 68 Filed Plaintiffs' Statement of Undisputed Material Facts in Support of Motion for Summary Judgment faz 

08/23/21 69 Filed Plaintiffs' Motion for Summary Judgment faz 

08/24/21 Downloaded & saved Defendants' filings from 8/23: Motion for Summary Judgment [64], Statement of Material Facts [67] 

and its exhibits

faz 

08/24/21 Downloaded Defendants' Notice of Filing re their Statement of Facts [68], which omitted two exhibits faz 08/24/21 70 Reviewed Defendants' Notice of Filing and its exhibits thereto; these are the exhibits which were omitted from Defendants' 

Statement of Material Facts

AFS 

08/25/21 67 Analyzed Defendants' Statement of Undisputed Materials Facts, filed 8/23, and its exhibits thereto (affidavits of three 

defense witnesses, transcripts of both Plaintiffs' depositions)

AFS 

08/25/21 64 Analyzed Defendants' Motion for Summary Judgment, filed 8/23; AFS 09/02/21 Email from opposing counsel re conferral as to a one-week extension to file response to motion for summary judgment; 

sent response indicating no opposition as long as he does not oppose our own one-week extension for the same

AFS 

09/02/21 71 Reviewed Joint Motion for One Week Extension [to respond to respective motions for summary judgment] AFS 

09/02/21 72 Reviewed Defendants' Notice of Filing Proposed Order re [71] AFS 09/02/21 Reviewed email from opposing counsel to the Court enclosing the Word version of the proposed order AFS 09/07/21 Drafted Plaintiffs' Response to Defendants' Statement of Material Facts [67], for filing along with the forthcoming response 

to Defendants' motion for summary judgment

AFS 

09/08/21 76 Drafted and filed Plaintiffs' Response to Defendants' Motion for Summary Judgment [64] AFS 09/08/21 75 Filed Plaintiffs' Response to Defendants' Statement of Material Facts [67], drafted yesterday faz 09/09/21 73 Analyzed Defendants' Response to Plaintiffs' Statement of Material Facts [68], and the three declarations and two pay

record excerpts attached thereto as exhibits, filed just before midnight on 9/7/21

AFS 

09/09/21 74 Analyzed Defendants' Response to Plaintiff's Motion for Partial Summary Judgment [69], filed just before midnight on 

9/7/21

AFS 

09/14/21 77 Drafted and filed Plaintiffs' Reply to Defendants' Response [74] to Plaintiffs' Motion for Partial Summary Judgment [69] AFS 

09/15/21 78 Reviewed Defendants' Reply to Response [75] to Defendants' Motion for Summary Judgment [64], and the three 

attachments thereto

AFS 

09/16/21 Drafted and served email to opposing counsel following up on my email of 8/23 and AFS email of 9/2, both regarding 

attempts to schedule mediation, since we have not received any response regarding our mediation scheduling inquiries; reviewed response; targeting 10/6 for mediation; reserved the date/time via the mediator's online calendaring system

faz 

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Date DE Professional Services Rendered Staff Ho09/16/21 Placed call to mediator's office re ability to conduct the mediation via Zoom rather than in-person; conflicting information on 

the website as to whether this is an option; spoke to Martha who said she saw our request in the notes of our reservation and confirmed they do Zoom mediations, but there is some technical issue particular to the designated mediator; will get back to us 

faz 

09/20/21 Email to Martha with Salmon & Dulberg mediation re whether the mediator can accommodate a Zoom mediation rather 

than in-person only; received confirmation they can do the mediation by Zoom

faz 

09/20/21 Prepared proposed order scheduling mediation and sent to Judge Cooke via email, as required, with copies to all counsel

of record

faz 

09/20/21 Email to opposing counsel re we have received written confirmation the mediation will be conducted via Zoom faz 

09/20/21 Reviewed Notice of Suit Rights letter received in the mail today from the EEOC, dated 9/8/21; calendared +90 days from 

the date of the letter to file suit

AFS 

09/21/21 Email from Conrad Bassett from the Wage & Hour Division of the DOL regarding our FOIA request from earlier this year; 

review is completed and any responsive documents are attached; reviewed cover letter and the 8 pages of responsive documents, which includes the narrative report regarding the investigation of Grill Enterprises, LLC for violations of the FLSA

AFS 

09/22/21 Reviewed email from Plaintiff Chavez (received late last night) re the EEOC letter he received in the mail; sent brief 

response stating we received the same letter and we will discuss when he's here for the 10/6 mediation

faz 

09/22/21 Drafted and served emails to both Plaintiff regarding the mediation in this case, scheduled for 10/6 at 1p, via Zoom; 

instructed both Plaintiffs to arrive here shortly before 1pm and to plan on the mediation taking up the remainder of the day

faz 

09/22/21 Reviewed the email from Salmon & Dulberg mediation (received yesterday) enclosing the Zoom videoconference details 

for the 10/6/21 mediation; also reviewed the attached PDFs (engagement letter and Notice of Mediation Conference)

AFS 

09/28/21 Reviewed email from mediator Carol Cope, received last night, and sent response enclosing various filings in this case so 

that she may familiarize herself with the facts of this case

AFS 

10/04/21 Called both Plaintiffs to confirm their attendance at the 10/6 mediation, to take place remotely from our office; both 

confirmed

faz 

10/06/21 Prepared for and attended mediation (Zoom from 1p-324p); case did not settle; Defendants made no counter-offer AFS 

10/09/21 Reviewed responsive email from mediator Carol Cope, responding to an email from opposing counsel from earlier this 

morning in which he quotes the scheduling order [42] requiring that a mediation report be filed within 5 days of the mediation conference; mediator Cope indicated the report will be filed on Monday (10/11)

AFS 

10/11/21 79 Reviewed Report of Mediator filed by mediator Carol Cope indicating all parties were present and that no agreement was 

reached

AFS 

10/11/21 Email from Salmon & Dulberg ADR enclosing mediation invoice for the 10/6 mediation faz 10/20/21 80 Reviewed the Court's paperless Endorsed Order granting nunc pro tunc the parties' Joint Motion for Extension of Time to 

File Responses to Motions for Summary Judgment [79]

AFS 

11/05/21 Prepared the initial draft of Joint Pretrial Stipulation as well as Plaintiffs' initial witness/exhibit list, for service on opposing 

counsel for his revisions to the JPS and so that he may note any objection codes on exhibits

AFS 

11/08/21 Exchanged three subsequent versions of the Joint Pretrial Stipulation with opposing counsel AFS 

11/08/21 Reviewed Defendants' witness/exhibit lists and noted our objection codes AFS 

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Date DE Professional Services Rendered Staff Ho11/08/21 Drafted the joint "Summaries" of Motions in Limine in the format required by the Court and sent to opposing counsel for his 

responses thereto and Defendants' own motions in limine, if any

AFS 

11/08/21 Reviewed Defendants' motions in limine and drafted our responses summaries thereto; this document is now in final and 

ready for filing

AFS 

11/08/21 81 Filed Joint Pretrial Stipulation, attaching respective witness/exhibit lists, after receiving confirmation from opposing counsel 

the items are in final

faz 

11/08/21 82 Filed "Joint Summary of Parties' Motions In Limine " faz 

11/16/21 Started preparing the initial draft of joint jury instructions; instructions must be filed jointly although the parties need not 

agree on each one

AFS 

11/17/21 Continued preparing the initial draft of joint jury instructions AFS 11/18/21 Finished the initial draft of joint jury instructions, will send to opposing counsel for his review/additions AFS 11/19/21 Drafted and sent to opposing counsel the initial draft of "joint trial witness list with synopses and estimation of time needed 

for direct and cross examination"

AFS 

11/22/21 Reviewed email from opposing counsel attaching Defendants' revisions to the joint witness list with estimates of time 

required for testimony; this list is considered "Final" now and ready for filing tomorrow

AFS 

11/22/21 Call to Plaintiff Chavez (1235p-1256p) to discuss Defendants' witness list AFS 11/22/21 Call to Plaintiff Diaz (1259p-116p) to discuss Defendants' witness list AFS 11/22/21 Drafted and served email to opposing counsel re the status of the joint jury instructions, the initial draft of which we 

provided last Thursday; we have still not received either Defendants' objections to any of the jury instructions or any of Defendants' proposed jury instructions (if any) and they are due tomorrow

AFS 

11/23/21 Reviewed email from opposing counsel which attached the Defendants' objections/proposed jury instructions AFS 11/23/21 Reviewed the Defendants' objections and, alternatively, proposed jury instructions if objections to Plaintiffs' proposed 

instructions are made; made Plaintiffs' objections to the Defendants' proposed jury instructions; cleaned up formatting to comply with the requirements of the Court's scheduling order [42] and will send back to opposing counsel in "final" form 

AFS 

11/23/21 Drafted Plaintiffs' Proposed Voir Dire Questions; will file these along with the joint filings when we file at the end of the day AFS 

11/23/21 Drafted Plaintiffs' Witness List with "identifying information" for the jury, to be filed at the end of the day along with the other 

items due today

AFS 

11/23/21 84 Filed the Joint Proposed Jury Instructions and Verdict Form, previously finalized by the parties faz 11/23/21 85 Filed the Joint List of trial witnesses with joint synopses and estimate of time required for direct and cross exam, previously 

finalized by the parties

faz 

11/23/21 86 Filed Plaintiffs' proposed voir dire questions faz 

11/23/21 87 Filed Plaintiff's Witness List with "identifying information" for the jury faz 11/23/21 83 Reviewed Defendants' Witness List with "identifying information" for the jury, as required by the Court's scheduling order 

[42]

AFS 

11/23/21 88 Reviewed Defendants' proposed voir dire questions AFS 11/24/21 89 Reviewed the Court's Order on Defendants' Motion for Leave to Amend Answer [52]; Defendants' motion is denied AFS 

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Date DE Professional Services Rendered Staff Ho12/01/21 Prepared trial subpoenas for: Vanessa Carrillo, Denysse Carrillo, Yeison Gonzalez, Cyndia Sanchez, and Mariana Pinto; 

sent to opposing counsel with a cover email asking if he will accept service of these since they are all employees of the 

Defendants and all the contact information provided in answers to interrogatories is the restaurant phone number and 

address

AFS 

12/03/21 90 Reviewed the Court's Administrative Order; the calendar call scheduled for 12/8 and two-week trial period scheduled to 

start 12/13 are both continued to as-yet-unknown dates; another scheduling order to follow

AFS 

12/03/21 Called and spoke with both Plaintiffs to inform them the trial will not begin on 12/13/21 and that we would communicate any 

further details once we have them

faz 

12/03/21 Reviewed email response from opposing counsel re my email of 12/1 re trial subpoenas; counsel suggests we touch base 

about this after the Court rules on the respective motions for summary judgment

AFS 

12/09/21 91 Drafted and filed Plaintiffs' Notice of Supplemental Authority to provide the following three authorities: Sure-Tan, Inc. v. 

NLRB, 467 U.S. 883, 893 (1984); Patel v. Quality Inn South, 846 F.2d 700, 704-05 (11th Cir. 1988); Lucas v. Jerusalem 

Cafe, LLC, 721 F.3d 927, 930 (8th Cir. 2013)

AFS 

12/13/21 92 Reviewed Defendants' Notice of Supplemental Authority, filed on Sat 12/11/21, citing the following cases: Patel v. Quality 

Inn South, 846 F.2d 700, 704-05 (11th Cir. 1988); Lamonica v. Safe Hurricane Shutters, Inc., 711 F.3d 1299 (11th Cir. 

2013); Lucas v. Jerusalem Café, LLC, 721 F.3d 927 (8th Cir. 2013)

AFS 

12/17/21 93 Drafted and filed Plaintiffs' Response to "Defendants' Notice of Supplemental Authority" [92] AFS 01/31/22 94 Analyzed the Court's 17-page Order Denying Plaintiffs' Motion for Partial Summary Judgment; note that the order denied 

both respective motions for summary judgment [64 & 69] for the reasons set forth therein, and set a deadline of 2/11/22 to refile motions for summary judgment; deadline calendared

AFS 

02/03/22 Brief calls to both Plaintiffs to confirm they will be in town next week so that we can schedule an appointment to prepare 

new affidavits in support of renewed/re-filed motion for summary judgment in compliance with the Court's Order [94] 

entered this past Monday; both are here and available

faz 

02/04/22 Prepared initial drafts of the respective affidavits of Plaintiffs Chavez and Diaz in support of forthcoming renewed motion 

for summary judgment; will need to speak with each of them in advance of having them come in to review/sign in order to clarify some details regarding the origin of various food items and liquors they served as employees of the Defendants

AFS 

02/07/22 Call with Plaintiff Chavez to clarify some details in advance of his coming in this week to prepare a supplemental affidavit 

to accompany the renewed motion for summary judgment (316p-334p)

AFS 

02/07/22 Called Plaintiff Diaz and left message re call to clarify some details in advance of his coming in this week to prepare a 

supplemental affidavit to accompany the renewed motion for summary judgment

AFS 

02/07/22 Incoming return call from Plaintiff Diaz (551p-556p) to clarify some details in advance of his coming in this week to prepare 

a supplemental affidavit to accompany the renewed motion for summary judgment 

AFS 

02/09/22 In-office meeting with Plaintiff Diaz (943a-1038a) to prepare his supplemental affidavit in support of a renewed Plaintiffs' 

motion for summary judgment, to be filed on Friday 2/11/22; will be including an additional two exhibits to each of the respective affidavits which will be calculations of damages for "Phase 1" and "Phase 2", which were not initially included as 

exhibits the first time

AFS 

02/09/22 In-office meeting with Plaintiff Chavez (415p-440p) to prepare his supplemental affidavit in support of a renewed Plaintiffs' 

motion for summary judgment

AFS 

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Date DE Professional Services Rendered Staff Ho02/09/22 Prepared initial draft of the Plaintiffs' statement of material facts in support of the forthcoming renewed motion for summary 

judgment, using the first statement of material facts as the starting point; most notably, also adjusted the amount sought by the Plaintiff Chavez on account of inadvertently including an additional few months worth of damages for Plaintiff Chavez in 

the initial SFM filing, adjusted the numbers so that the damages only accrued beginning exactly 3 years prior to the filing of the lawsuit

AFS 

02/10/22 Prepared initial draft of the Plaintiffs' renewed motion for summary judgment, using the first filing as a starting 

point/framework

AFS 

02/11/22 97 Finalized and filed Plaintiffs' Statement of Undisputed Facts in Support of (forthcoming) Renewed Motion for Summary 

Judgment

AFS 

02/12/22 98 Filed the previously-finalized Supplemental Affidavit of Erik Chavez in support of Plaintiffs' (forthcoming) Renewed Motion 

for Summary Judgment

AFS 

02/12/22 99 Filed the previously-finalized Supplemental Affidavit of Leonel Diaz in support of Plaintiffs' (forthcoming) Renewed Motion 

for Summary Judgment

AFS 

02/12/22 100 Finalized and filed Plaintiffs' Renewed Motion for Summary Judgment AFS 02/14/22 95 Analyzed Defendants' Renewed Motion for Summary Judgment (filed 2/11/22) and prepared outline of response AFS 02/14/22 96 Analyzed Defendants' Statement of Material Facts (filed 2/11) in support of Defendants' Renewed Motion for Summary 

Judgment [95]

AFS 

02/16/22 Prepared initial draft of response to Defendants' Statement of Material Facts [96] in support of renewed motion for 

summary judgment

AFS 

02/17/22 Prepared initial draft of response to Defendants' Renewed Motion for Summary Judgment [95] AFS 02/24/22 101 Reviewed the Court's paperless Endorsed Order referring the respective motions for summary judgment [95 and 100] to 

Magistrate Goodman for an R&R

AFS 

02/25/22 102 Finalized and filed Plaintiffs' Response to Defendants' Statement of Material Facts in support of Renewed Motion for

Summary Judgment [96]

AFS 

02/25/22 105 Finalized and filed Plaintiffs' Response to Defendants' Renewed Motion for Summary Judgment [95] AFS 02/28/22 103 Analyzed Defendants' Response (filed 2/25/22) to Plaintiff's Statement of Undisputed Facts [97] and the five exhibits 

attached thereto (this is very similar to the initial filing [73])

AFS 

02/28/22 104 Analyzed Defendants' Response (filed 2/25/22) to Plaintiff's Renewed Motion for Summary Judgment [100] AFS 

03/01/22 Reviewed email from opposing counsel re conferral on Defendants' forthcoming motion for leave to file excess pages in 

their reply to their renewed motion for summary judgment; sent response noting our opposition

AFS 

03/02/22 Briefly reviewed Defendants' Motion for Leave to Exceed Page Limits and the accompanying proposed order (this was filed

last night)

AFS 

03/02/22 Reviewed the Court's Paperless Order granting Defendants' Motion for Leave to Exceed Page Limits; Defendants 

forthcoming reply may be 13 pages

AFS 

03/02/22 Prepared the initial draft of Plaintiffs' reply to Defendants' response [104] to Renewed Motion for Summary Judgment [100] AFS 06/16/22 110 Drafted and filed Notice of Ninety Days Expiring re Plaintiffs' Renewed Motion for Summary Judgment [100] AFS 08/16/22 111 Analyzed 52-page Report & Recommendation (entered yesterday) on cross-motions for summary judgment [95, 100] AFS 

08/28/22 Began drafting Plaintiffs' Objections to Report and Recommendation on Parties Cross-Summary Judgment Motions [111] AFS 

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Date DE Professional Services Rendered Staff Ho08/29/22 113 Completed draft of Plaintiffs' Objections to Report and Recommendation on Parties Cross-Summary Judgment Motions 

[111], finalized, and filed

AFS 

08/30/22 112 Analyzed Defendants' Objections to Report and Recommendation on Parties Cross-Summary Judgment Motions [111], 

filed yesterday; any response due 9/12/22

AFS 

09/09/22 Began drafting Plaintiffs' response to Defendants' Objections [112] to port and Recommendation on Parties CrossSummary Judgment Motions [111], completed through Argument II(A) AFS 09/12/22 114 Continued drafting Plaintiffs' response to Defendants' Objections [112] to port and Recommendation on Parties CrossSummary Judgment Motions [111]; finalized and filed AFS 

09/12/22 115 Skimmed through Defendants' Response to Plaintiff's Objections [113] to R&R [111] AFS 09/15/22 116 Reviewed the Court's Order Adopting and Affirming Report and Recommendation [111] AFS 11/01/22 Prepared draft of motion for entry of order scheduling trial, so as to put this case back on the trial calendar since all 

summary judgment motions have been disposed of and all pretrial preparations have been completed; sent to opposing 

counsel for his review and sent cover email requesting his position

AFS 

11/03/22 Reviewed early morning email from opposing counsel indicating he will check with his client as to Defendants' position on 

the motion for entry of order scheduling trial

AFS 

11/03/22 117 Finalized and filed the motion for entry of order scheduling trial AFS 01/27/23 118 Reviewed the Clerk's Notice of Reassignment of Case; this case has been reassigned to Judge Robin L. Rosenberg AFS 01/27/23 Went to Judge Rosenberg's FLSD page to review any specific standing/pretrial orders; reviewed the exemplar of trial order 

in civil cases to familiarize myself with Judge Rosenberg's trial procedures and made notations to file

AFS 

01/30/23 119 Reviewed the Court's Paperless Order Setting a Zoom Status Conference for 2/8/23 @ 1030a; calendared faz 01/30/23 Call to opposing counsel Shulby to discuss the recent paperless order [119] and conferred re scheduling conflict we have 

(evidentiary hearing before Judge Torres that same day but at 10a); opposing counsel also has a conflict that same day 

and time; they will draft a form of joint motion and leave a placeholder for us to include our conflict details

faz 

01/31/23 Reviewed email from opposing counsel enclosing draft form of joint motion to reschedule status conference set for 2/8/23 

due to conflicts by both parties; inserted our conflict in the placeholder provided and sent back to opposing counsel after 

running it by AFS

faz 

01/31/23 120 Reviewed Joint Motion to Reschedule Status Conference AFS 01/31/23 121 Reviewed the Court's Paperless Order granting Joint Motion to Reschedule Status Conference [120]; status conference 

now set for 2/9 @ 11a; adjusted calendar accordingly

AFS 

02/10/23 Call with Plaintiff Diaz to discuss upcoming status conference and confirm his availability or unavailability, generally, for a 

trial in the near to mid-term

AFS 

02/10/23 Incoming call from Plaintiff Chavez, following my text to him, to discuss his general availability for trial; only time in the near 

to mid-term that he's unavailable is June 2023

faz 

02/10/23 Call to Plaintiff Chavez to discuss his availability in greater detail AFS 02/13/23 Prepared for today's status conference before Judge Rosenberg, by generally reviewing the case file to-date, plus a more 

focused review of summary judgment motions/order, trial prep related filings (jury instructions, pretrial stipulation, witness 

lists, etc.)

AFS 

02/13/23 Zoom Status Conference before Judge Rosenberg (11a-1130a) AFS 02/13/23 Prepared draft form of supplemental Magistrate Judge consent form consenting to jurisdiction for purposes of trial and sent 

to opposing counsel for his review/comments

AFS 

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Date DE Professional Services Rendered Staff Ho02/13/23 122 Reviewed the Court's Paperless Order following the Status Conference this morning; deadline to submit Magistrate Judge 

jurisdiction form is noon on 2/15/23; calendared

AFS 

02/15/23 Call to opposing counsel Shulby following up on our draft of supplemental Magistrate Jurisdiction Form we sent two days

ago; indicates he has not yet been able to reach his client, but will get back to us

AFS 

02/15/23 Brief incoming call from opposing counsel; parties agree to jurisdiction by Magistrate Judge AFS 

02/15/23 123 Filed Supplemental Magistrate Jurisdiction Form indicating the parties' consent to jury trial AFS 02/15/23 124 Paperless Minute Entry for proceedings held 2/13/23 AFS 02/15/23 125 Reviewed the Court's Order of Reference re jury trial to Judge Goodman AFS 02/16/23 126 Reviewed Paperless Order setting trial scheduling conference (via Zoom) for 2/22 @ 5p; zoom details to follow; calendared AFS 

02/16/23 127 Reviewed Paperless Order providing Zoom meeting details for the 2/22 scheduling conference; updated calendar 

accordingly and noted that participants must log in 10 minutes prior to the start of the hearing to ensure there are no technical issues

faz 

02/16/23 128 Reviewed Paperless Order denying as moot Plaintiff's motion for issuance of trial order [117] AFS 02/22/23 Reviewed our calendar/case load today and noted our general availability for trial, excluding any period of time when either 

Plaintiff has told us they are unavailable as well as dates we are currently on trial calendar or otherwise unavailable

AFS 

02/22/23 Scheduling Conference before Judge Goodman (Zoom); logged in 10 minutes early, per Judge Goodman's Order [127] AFS 

02/22/23 129 Minute entry for scheduling conference concluded a little bit ago AFS 02/22/23 130 Reviewed the Court's Order Specially Setting Civil Jury Trial . . .; calendared all the deadlines set forth therein and made 

notation to file of any special procedures or practices required by the same

AFS 

02/24/23 131 Reviewed the Court's Paperless Order regarding Final Pretrial Conference; final PTC will take place on 4/26/23 @ 1pm via 

Zoom; calendared

AFS 

02/24/23 132 Reviewed Defendant's Notice Regarding Settlement Conference with Magistrate Judge; Defendants prefer that another 

judge conduct the settlement conference in this case

AFS 

02/27/23 133 Reviewed the Court's Paperless Order Referring Case to Judge Damian for Settlement Conference/Mediation (note that 

this was entered yesterday); parties are directed to contact Judge Damian asap to schedule a date and time for the 

settlement conference, to take place via Zoom

AFS 

02/27/23 134 Reviewed the Court's Paperless Order setting Zoom Final Pretrial Conference for 4/26/23 @ 1pm; Zoom details provided

in this order; updated calendar entry with these Zoom details

AFS 

02/27/23 Email to opposing counsel Shulby inquiring as to his availability for a conference/joint call to Judge Damian re settlement 

conference scheduling, as required by the Court's recent paperless order [133]

faz 

02/28/23 Reviewed email from opposing counsel Shulby re scheduling call to Judge Damian for purposes of scheduling settlement 

conference

faz 

02/28/23 Placed call to Judge Damian's chambers asking for dates of availability for the Court for a settlement conference; Judge 

Damian is generally available the last two weeks of March; instructed to circulate dates and send an email to chambers once we've agreed on a date or dates

faz 

02/28/23 Reply email to opposing counsel Shulby re settlement conference scheduling and my call moments ago to Judge Damian's 

chambers

faz 

03/03/23 Email from opposing counsel Shulby providing dates of availability for settlement conference AFS 

03/03/23 Email to Judge Damian's chambers providing dates of availability for the parties for a settlement conference; cc to 

opposing counsel

AFS 

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Date DE Professional Services Rendered Staff Ho03/03/23 135 Reviewed the Court's Order Scheduling Settlement Conference and calendared all deadlines faz 03/03/23 Placed calls to and spoke with both Plaintiffs to provide the date/time of the settlement conference faz 03/10/23 Reviewed and exchanged a handful of emails with opposing counsel re Defendant does not believe settlement conference 

will be productive and wants to know if we will join in a notice requesting it be canceled; we will not be joining in such a request

AFS 

03/14/23 Email from Judge Damian's chambers providing zoom details for 3/21 settlement conference; will forward to Chavez who 

will be attending remotely

faz 

03/15/23 Drafted and served email to Plaintiff Chavez providing the Zoom instructions we received from the Court yesterday for the 

3/21 settlement conference

faz 

03/15/23 Email to Jose Vega with Legal Translations asking if he can cover a (zoom) settlement conference on 3/21/23 beginning at 

10a; he will get the quote together and get back to me

faz 

03/15/23 Incoming call from Plaintiff Chavez; he will be coming into the office to attend the settlement conference, via zoom; he 

delayed his travel plans so that he could be physically present here in the office rather than attend the settlement 

conference remotely by himself

faz 

03/16/23 Drafted and served Plaintiffs' confidential settlement statement to Judge Damian, in advance of the 3/21/23 settlement 

conference

AFS 

03/21/23 In-office meeting (930a-10a) with Plaintiffs prior to the start of the settlement conference, per Plaintiffs request; purpose of 

the meeting was to bring them up to speed on where we are with the case since there was a significant period of time that has passed since this case was recently reset on the trial calendar

AFS 

03/21/23 Attended Zoom Settlement Conference before Judge Damian (10a-305p); no agreement; discussed with Plaintiffs their 

settlement demands and acceptable negotiating range for any settlement

AFS 

03/21/23 136 Paperless minute entry for settlement conference today faz 03/23/23 Prepared draft of a Plaintiffs' motion in limine re 4 areas where Plaintiffs seek to limit the Defendants' introduction of 

evidence at trial

AFS 

03/23/23 Email to opposing counsel enclosing draft of Plaintiffs' motion in limine; reviewed response saying he will run it by his client 

and get back to us; this same email also included a summary of areas/topics Defendants will move to exclude; sent brief 

reply

AFS 

03/23/23 138 Finalized and filed Plaintiffs' Motion in Limine AFS 03/24/23 Incoming call from Plaintiff Diaz re settlement discussions AFS 03/27/23 137 Analyzed Defendants' Motion in Limine (filed 3/23/23) AFS 03/27/23 Drafted and served, via email, Plaintiffs' Offer of Judgment per Rule 68 AFS 04/03/23 139 Reviewed Defendants' Response to Plaintiffs' Motion in Limine [138]; note that no replies are permitted, per scheduling 

order [130]

AFS 

04/03/23 140 Drafted and filed Plaintiffs' Response to Defendants' Motion in Limine [137]; no reply permitted per [130] AFS 04/10/23 Outgoing calls to Plaintiffs Chavez (1214p-1217p) and Diaz (1217p-1224p) returning their calls from over the weekend; 

both called for updates re case status and settlement discussions

AFS 

04/10/23 Prepared draft of joint pretrial stipulation for service on opposing counsel in advance of the 4/24/23 deadline to file the 

same

AFS 

04/10/23 141 Reviewed Defendants' Notice of Appearance as Co-Counsel for Defendants (attorney Brian H. Pollock); updated service 

list accordingly

faz 

04/13/23 Incoming call from attorney Brian Pollock (145p-206p) AFS 

04/13/23 Reviewed email from opposing counsel pollock re joint pretrial stipulation draft, and reviewed the attached revised 

stipulation

AFS 

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Date DE Professional Services Rendered Staff Ho04/13/23 Made revisions to joint pretrial stipulation and sent back to opposing counsel Pollock AFS 04/13/23 Forwarded to opposing counsel Pollock a copy of the most recent settlement communications so he knows where the 

parties were, included a brief cover email detailing that we served Defendants with a pre-suit demand letter which was 

ignored

AFS 

04/13/23 Reviewed email from opposing counsel Pollock re disputed facts in the draft of joint pretrial stipulation; sent response AFS 04/13/23 Email from opposing counsel Pollock stating that his client denies ever having receive the pre-suit demand letter and 

asking that co-counsel Shulby be copied on these emails; sent very brief response

AFS 

04/14/23 142 Reviewed the Court's Order granting, in part, Defendants' motion in limine [137] (entered 4/13/23) AFS 04/14/23 143 Reviewed the Court's Order denying Plaintiffs' motion in limine [138] (entered 4/13/23) AFS 04/18/23 Email from opposing counsel Pollock following up on latest draft of pretrial stipulation; sent response saying we should 

have a Zoom call tomorrow to discuss

AFS 

04/19/23 Email to opposing counsel Pollock re availability for a Zoom this afternoon; reviewed response indicating he is available at 

5p; scheduled Zoom and provided details 

faz 

04/19/23 (5p-550p) Zoom meeting with opposing counsel Pollock to continue preparing/review the joint pretrial stipulation; we will 

continue this Friday @ 10a; sent most current draft of pretrial stipulation to opposing counsel

AFS 

04/20/23 Reviewed email from opposing counsel Pollock enclosing revised draft of pretrial stipulation in advance of tomorrow's 

Zoom @ 10a; Defendant's exhibit list to follow tomorrow

AFS 

04/21/23 Reviewed the most recent draft of pretrial stipulation (the one provided yesterday afternoon by opposing counsel); this draft 

will serve as the starting point for tomorrow's Zoom

AFS 

04/21/23 10a-1212p. Zoom with opposing counsel Pollock to finish drafting joint pretrial stipulation AFS 04/21/23 Email from opposing counsel Pollock enclosing Defendants' exhibit list; marked up exhibit list with Plaintiff's objections AFS 

04/21/23 Prepared Plaintiffs' exhibit list AFS 

04/21/23 Email to opposing counsel Pollock returning Defendants' exhibit list (marked up by us) and providing Plaintiffs' exhibit list 

for his objections

AFS 

04/24/23 411pm Email from opposing counsel Pollock enclosing a revised joint pretrial stipulation, Plaintiffs' witness list marked with 

Defendants' objections, Defendants' exhibit list, and a duplicate copy of the joint pretrial stipulation; note that the body ofthe email indicates that the fourth attachment is a "joint witness list" rather than a second copy of the pretrial stipulation

AFS 

04/24/23 Sent brief response email advising that the witness list is missing AFS 04/24/23 Started going through the most recent version of the joint pretrial stipulation and Defendants' exhibit list and making

revisions thereto

AFS 

04/24/23 Email from opposing counsel Pollock enclosing a new set of joint pretrial stipulation, respective exhibit list, and joint 

witness list; started reviewing and revising and marking Plaintiffs' objections to certain exhibits

AFS 

04/24/23 Call to opposing counsel Pollock advising that the "joint witness list" was a Judge Cooke specific requirement which is not 

called for under the current trial order [130] and asking that he provide Defendants witnesses on a standalone document; 

discussed minor changes to the Plaintiff's summary of the case portion of the JPS; once we finalize these items and receive Defendants' witness list, we have authority to file the pretrial stipulation and its attachments

AFS 

04/24/23 Email from opposing counsel Pollock enclosing Defendants' witness list; briefly reviewed AFS 04/24/23 144 Finalized and filed joint pretrial stipulation, attaching respective witness and exhibit lists AFS 

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Date DE Professional Services Rendered Staff Ho04/24/23 Prepared trial subpoenas for Denysse Carrillo, Mariana Pinto, Vanessa Carrillo, and Yeison (a/k/a "Nelson) Gonzalez and

forwarded to Caplan for service

AFS 

04/25/23 Email from Caplan advising they have received the job request and will get the subpoenas served AFS 04/26/23 Prepared for Pretrial Conference today @ 1p AFS 04/26/23 1p-314p. Pretrial conference before Judge Goodman, via Zoom AFS 04/26/23 Incoming call from opposing counsel Pollock (432p-442p) re coordinating the work re the items required to be filed over the 

next couple weeks as a result of the pretrial conference

AFS 

04/26/23 145 Reviewed the prospective juror questionnaire filed by the Court during the pretrial conference earlier today AFS 04/26/23 Prepared initial draft of summary of claims/defenses for reading during voir dire, as required by the Court's order; sent to 

opposing counsels

AFS 

04/26/23 146 Reviewed the minute entry re the pretrial conference earlier today AFS 04/26/23 Logged into the process server portal and downloaded the returns of service for trial witnesses Vanessa Carrillo, Denysse 

Carrillo, Yeison Gonzalez, and Mariana Pinto; saved to file

faz 

04/26/23 Reviewed a string of 10 separate emails sent over a span of 3 minutes from opposing counsel Shulby enclosing assorted 

samples of documents that are contained with boxes in the possession of the Defendants

AFS 

04/26/23 Prepared an initial draft of "joint summary of claims and defenses in the case" to be read to the jury in voir dire, as

discussed earlier today during the pretrial conference; sent via email to opposing counsels

AFS 

04/26/23 Reviewed response email from opposing counsel Pollock re pretrial stipulation and remaining questions of fact; sent 

response

AFS 

04/26/23 147 Reviewed the Court's Post-Pretrial Conference Administrative Order, which sets out deadlines to file certain items (jury 

instructions, memos, etc.); calendared

AFS 

04/27/23 Began drafting Plaintiffs' omnibus memorandum of law regarding each of the "legal issues" listed in the pretrial stipulation 

as required by the Court's order

AFS 

04/27/23 Reviewed email from opposing counsel Shulby enclosing latest revisions to the joint neutral summary (from yesterday) to

be read during voir dire; made revisions and sent back

AFS 

04/27/23 Reviewed email from opposing counsel Pollock re proposed verdict form AFS 04/27/23 Reviewed email from opposing counsel Pollock re proposed verdict form 

04/27/23 Reviewed email from opposing counsel Pollock attaching latest revision of proposed jury instructions and reviewed the 

attached Word document; there are many issues with this draft (not the font required by Judge Goodman, it has removed certain instructions previously proposed by the Plaintiff but with no redline/track changes indication of the same, etc.)

AFS 

04/27/23 Email from opposing counsel Pollock re conferral regarding ECF 147 and the outstanding "issues" AFS 04/27/23 Drafted and served response to opposing counsel Pollock re conferral on outstanding legal issues AFS 04/27/23 Response from opposing counsel Pollock re outstanding legal issues; sent very brief reply indicating if he does not 

understand Plaintiff's position, to return my call so we can discuss

AFS 

04/27/23 Sent very brief response to opposing counsel Pollock responding to his earlier email re proposed verdict forms AFS 

04/27/23 Sent email to opposing counsel Pollock noting that his recent proposed jury instructions deleted previous instructions 

proposed by the Plaintiff, without tracking the changes, and replacing them with new proposed instructions in the "agreed" 

format, so all traces of Plaintiff's proposed instructions are now lost from the document 

AFS 

04/27/23 Reviewed latest revisions to the joint summary of claims/defenses, provided by opposing counsel Shulby AFS 

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Date DE Professional Services Rendered Staff Ho04/27/23 Reviewed email from opposing counsel Pollock stating that he "followed the procedure customarily used to modify 

proposed jury instructions"; sent response stating that is not the case since rather than making any changes in track changes mode to Plaintiff's proposed instructions, they were removed (without track changes), requiring Plaintiffs to identify the missing instructions and recreate them

AFS 

04/28/23 Reviewed two emails from opposing counsel Shulby re joint summary of case to be read in voir dire AFS 04/28/23 Reviewed email from opposing counsel Pollock; Defendants will be filing a motion for clarification re jury instructions AFS 04/28/23 Short email to opposing counsels re joint summary of case to be read in voir dire AFS 04/28/23 148 Reviewed Defendants' Motion for Clarification re Jury Instructions & Verdict Forms AFS 04/28/23 Email from opposing counsel Shulby re joint summary; says he tracked his changes and doesn't know why they aren't 

visible

AFS 

04/28/23 149 Drafted and filed Plaintiffs' Response to Defendants' Motion for Clarification, attaching the draft of jury instructions sent by 

Defendants earlier as the sole exhibit

AFS 

04/28/23 Made revisions to the joint summary received last night from opposing counsel Shulby, accepted all changes, and tracked

our own changes

AFS 

04/28/23 150 Reviewed the Court's Order denying Defendants' Motion for Clarification re Jury Instructions & Verdict Forms [148] AFS 04/28/23 Email to opposing counsel Shulby enclosing most recent draft of joint summary; all of Defendants' proposed changes were

accepted and we reinserted the language that was somehow lost in our various exchanges

AFS 

04/28/23 Reviewed lengthy email from opposing counsel re jury instructions and verdict form; sent short response AFS 

04/28/23 Reviewed email from opposing counsel Pollock, who says he has conferred with co-counsel Shulby re joint summary and 

has attached what they believe is a final version; reviewed the attachment

AFS 

04/28/23 Very brief email to opposing counsel Pollock indicating recent draft of joint summary is acceptable for filing with 

Defendants' proposed changes once all the redlined changes are accepted

AFS 

04/28/23 151 Joint Neutral Summary of Claims/Defenses filed by Defendants (the same one we indicated was acceptable to file) AFS 04/28/23 152 Reviewed the Court's paperless order re Joint Neutral Summary [151]; Court asks for clarification with respect to whether 

text that was stricken through is intended to be removed or not

AFS 

04/28/23 153 Reviewed Defendants' Notice of Striking [151] AFS 04/28/23 154 Reviewed the refiled Joint Neutral Summary of Claims/Defenses (filed by Defendants) AFS 04/28/23 Reviewed email from opposing counsel Pollock re "Boxes of Documents" Defendants have; apparently there are a total of 

12 boxes instead of the 6 previously represented

AFS 

04/28/23 155 Reviewed the Court's Paperless Order supplementing its prior Order [147] AFS 04/28/23 Brief email from opposing counsel Shulby re jury instructions and verdict form AFS 04/28/23 Prepared the most recent version of proposed jury instructions and verdict form; for the jury instructions, took the version I 

received yesterday at about 3:37 p.m. and accepted all the changes, where they are agreed , we submit them as agree, where we don’t agree, we identified them as a Defendants’ version and boldfaced the text, If we submit a competing proposed jury instructions, we italicized it to make clear that it’s a Plaintiffs’ version. These changes were made with trackchanges enabled. 

AFS 

04/28/23 Drafted and served email to opposing counsels enclosing most recent draft of joint proposed verdict form and proposed 

jury instructions

AFS 

04/28/23 Brief email to opposing counsel Pollock re "Boxes of Documents"; asked that he advise when Defendants' exhibits are 

marked and ready for review

AFS 

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Date DE Professional Services Rendered Staff Ho04/28/23 Email from opposing counsel Pollock re jury instructions; latest proposed jury instructions and verdict form are attached; 

will review these in the morning

AFS 

04/28/23 Email from opposing counsel Pollock re "Boxes of Documents"; sent response AFS 04/29/23 Exchanged several brief emails with opposing counsel Pollock re "Boxes of Documents" AFS 04/29/23 Continued drafting Plaintiffs' omnibus memorandum of law regarding each of the "legal issues" listed in the pretrial 

stipulation as required by the Court's order; completed through issue "S"

AFS 

04/29/23 Reviewed the latest proposed jury instructions and verdict from received last night from Defendants and made revisions AFS 

04/29/23 Email to opposing counsels enclosing latest revised draft of jury instructions AFS 04/29/23 Email to opposing counsel enclosing Plaintiffs' proposed verdict form and suggesting we jointly submit separate versions, 

since we are so far apart; reviewed response; reformulated the verdict forms and sent in reply email

AFS 

04/30/23 Email from opposing counsel enclosing latest proposed verdict form; reviewed, revised, and sent back AFS 04/30/23 Completed draft of Plaintiffs' omnibus memo of law re the remaining legal issues to be determined by the Court AFS 04/30/23 Email from opposing counsel Pollock enclosing latest jury instructions and verdict form; AFS 05/01/23 Email from Pollock re "Boxes of Documents" conferral; also included comments re trial exhibits AFS 05/01/23 Reviewed latest draft of jury instructions; accepted all changes, but corrected a lot of the formatting to conform with the 

Court's requirements and corrected minor spelling errors, but no substantive changes to any of the instructions; this should be the final version or close to once these formatting changes are accepted

AFS 

05/01/23 Email to opposing counsels enclosing jury instructions AFS 05/01/23 Email from opposing counsel Pollock enclosing latest jury instructions; Defendants made one substantive change that was

admittedly not tracked, but described in the email; should be final if changes accepted

AFS 

05/01/23 Inserted a new plaintiffs' objection to jury instruction on page 35, cleaned up additional formatting; sent back to opposing 

counsel

AFS 

05/01/23 Email from opposing counsel advising jury instructions are fine to submit; AFS 

05/01/23 Called Arrow Express messengers to schedule pickup for final jury instructions to be delivered to Judge Goodman; printed 

and placed Word version on flash drive to be included in paper delivery

faz 

05/01/23 156 Drafted and filed Notice of Filing Proposed Jury Instructions and Verdict Form AFS 05/01/23 Prepared cover letter to Judge Goodman to go along with the paper copies of jury instructions and flash drive; cc to 

opposing counsel via email only

AFS 

05/01/23 157 Reviewed the Court's Paperless Order re proposed verdict form [156-2]; parties to resubmit as separate/individual filings 

by 5/4/23 along with paper courtesy copy and flash drive

AFS 

05/01/23 Email from opposing counsel Pollock re "Boxes of Documents" conferral / trial exhibits AFS 05/02/23 Email to opposing counsel Pollock responding to his email yesterday evening re "Boxes of Documents" conferral / trial 

exhibits

AFS 

05/02/23 158 Reviewed the Court's Paperless Order re interpreters for the upcoming civil trial; we'll reach out to Legal Translations later 

this week as the trial date approaches

AFS 

05/02/23 Reviewed the three separate automated status updates from Caplan Process Servers re trial witnesses Denysse Carrillo, 

Mariana Pinto, Yeison Gonzalez; served

AFS 

05/02/23 159 Analyzed Defendants' Memo on the Admissibility of DOL Form WH-58, and its three exhibits thereto AFS 

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Date DE Professional Services Rendered Staff Ho05/03/23 Prepared draft of Plaintiffs' motion to permit electronic equipment into the courthouse during trial and served on opposing 

counsel for conferral, as required by the Court's Order [147]; no objection

AFS 

05/03/23 Reviewed email from opposing counsel Pollock re default issue; read the case cited by Defendants; Barbuto v. Miami 

Herald Media Co., 2022 WL 2237164

AFS 

05/03/23 Email from opposing counsel Pollock; no objection to motion to permit electronic devices into courthouse AFS 05/03/23 Email from opposing counsel Pollock re witnesses subpoenaed by Plaintiffs for trial and order we intend to call witnesses AFS 05/03/23 160 Finalized and filed Plaintiff's Motion to Bring Electronic Equipment into Courthouse, attaching the text of a proposed order 

as the sole exhibit

AFS 

05/03/23 Drafted and served email to Judge Goodman (cc counsel of record and staff) enclosing ECF No. 160-1 in Word format faz 05/03/23 161 Reviewed Court's Order granting Plaintiff's Motion to Bring Electronic Equipment into Courthouse [160]; printed two copies 

and placed in trial papers to take on Monday

faz 

05/03/23 162 Reviewed Defendants' Motion to Bring Electronic Equipment into Courthouse and its proposed order AFS 05/03/23 Lengthy email from opposing counsel Pollock re "Exhibit Exchange and Availability" AFS 05/03/23 163 Reviewed Court's Order granting Defendants' Motion to Bring Electronic Equipment into Courthouse [161] faz 05/03/23 Organized and segregated Plaintiffs' trial exhibits into separate PDF files (one per exhibit to match the exhibit list) and 

applied exhibit labels and bates stamps across all of them for ease of reference/identification; uploaded them to our cloud 

account and enabled remote access

faz 

05/03/23 Email to opposing counsels providing access link and password for Plaintiffs' trial exhibits faz 05/03/23 Brief email from opposing counsel Pollock; Plaintiffs exhibits email received and is will review and get back to us faz 

05/03/23 Email from opposing counsel Pollock re "Trial Exhibit Initial Review and Thoughts"; after cursory review, likely Defendants 

will stipulate to certain exhibits; requested we provided our most recent exhibit list so they can provide the updated 

objections to the same

AFS 

05/03/23 Began drafting Plaintiffs' Response to Defendants' memo re admissibility of DOL Form WH-58 [159]; completed through p. 

8 (through Argument I")

AFS 

05/04/23 164 Prepared and filed Notice of Filing Plaintiffs' Proposed Verdict Forms, attaching the proposed verdict form as the sole 

exhibit

AFS 

05/04/23 Drafted cover letter to Judge Goodman to accompany the proposed verdict form to be delivered to chambers AFS 05/04/23 Email from opposing counsel Pollock requesting the most current version of Plaintiffs' trial exhibit list so they can mark their 

revised objections

AFS 

05/04/23 Email from opposing counsel Pollock re "Chavez v. Grill - Pics of Boxes and Contents For You" AFS 05/04/23 Brief email to opposing counsel Pollock responding to his emails of earlier today AFS 05/04/23 165 Reviewed Defendants' Notice of Compliance re filing of Defendants' proposed verdict form, which is attached as the sole 

exhibit

AFS 

05/04/23 Email from opposing counsel Pollock re : Chavez v. Grill - Defs' Exhibits for Trial; this enclosed a DropBox link to download 

the exhibits

AFS 

05/04/23 Downloaded Defendants' trial exhibits from the DropBox link provided; saved to file faz 

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Date DE Professional Services Rendered Staff Ho05/04/23 Went through Defendants' trial exhibits and compared vs their exhibit list; some of these exhibits do not match the 

description at all (e.g., 'all docs produced by defendants' exhibit corresponds to 9 PDF files which are all a random selection of credit card receipts and nothing more; 'W2s issued to Chavez' corresponds with W2s issued to Chavez and to 

composite PDFs of W2s for all employees of the restaurant for the years 2018-2020); some of the exhibits detailed in the 

trial exhibit list are not produced

AFS 

05/04/23 Email from opposing counsel Pollock attaching a cover letter to Judge Goodman re Defendants' verdict form AFS 05/04/23 Email to opposing counsel Pollock enclosing Plaintiffs' most recent trial exhibit list, so that Defendants may mark with their 

revised/updated objections

faz 

05/04/23 Email to opposing counsels enclosing copy of the cover letter sent to Judge Goodman earlier today with the proposed 

verdict form

faz 

05/04/23 Email to opposing counsel Pollock requesting Defendants' most recent exhibit list so that we may provide revised 

objections thereto

faz 

05/04/23 166 Revised, finalized, and filed Plaintiffs' omnibus memo of law re the 28 "issues of law which remain for determination by the 

Court"

AFS 

05/04/23 167 Completed Plaintiffs' Response to Defendants' memo re admissibility of DOL Form WH-58 [159]; finalized and filed AFS 05/04/23 Email to Legal Translations requesting interpreter for upcoming trial faz 05/04/23 169 Reviewed the Court's Paperless Order regarding DOL Form WH-58; form will be allowed to be introduced into evidence AFS 05/05/23 168 Reviewed Defendants' memo of law re the 28 outstanding legal issues which remain for determination by the Court (filed 

yesterday afternoon)

AFS 

05/05/23 170 Reviewed the Court's Paperless Order requiring Plaintiffs filed copies of the demand letter previously served on 

Defendants by no later than 3pm today

AFS 

05/05/23 Email from opposing counsel Pollock enclosing Defendants' most recent exhibit list, which we need to provided updated 

objections to; saved to file

faz 

05/05/23 Email from opposing counsel Pollock re witness testimony order AFS 05/05/23 Revised Defendants' exhibit list to include Plaintiffs' revised objections AFS 05/05/23 171 Drafted and filed Plaintiffs' response to the Court's Paperless Order [170] requiring filing of demand letter; attached 4 items 

as exhibits

AFS 

05/05/23 172 Reviewed Defendants' filing of Plaintiff's exhibit list with their updated objections AFS 05/05/23 Email to opposing counsel attaching Defendants' exhibit list with Plaintiffs' updated objections; subsequent email sent right 

after requests Defendants upload the new exhibits which had been marked in yellow so that we may have those

AFS 

05/05/23 173 Filed Defendants' exhibit list containing the revised Plaintiffs' objections faz 

05/05/23 174 Reviewed Defendants' Motion to Bring Electronic Equipment into Courthouse and its proposed order AFS 05/05/23 Email from opposing counsel's office to Judge Goodman containing the Word version of the proposed order filed as 174-1 AFS 

05/05/23 175 Reviewed the Court's Paperless Order Granting Defendants' Motion to Bring Electronic Equipment into Courthouse AFS 05/05/23 176 Analyzed the Court's "Order Dismissing Without Prejudice Plaintiff Leonel Diaz's Florida Minimum Wage Act Claim and 

Requiring Revised Proposed Verdict Forms" and reviewed the handful of cases cited therein

AFS 

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Date DE Professional Services Rendered Staff Ho05/05/23 Email from opposing counsel Pollock conferring re Plaintiffs will agree to Defendants' request for 

clarification/reconsideration as to whether Plaintiff Chavez complied with the FMWA by including liquidated damages in the 

pre-suit letter

AFS 

05/05/23 177 Analyzed the Court's "Order on Remaining Legal Issues Listed in the Parties' Joint Pretrial Stipulation" AFS 05/05/23 Drafted and served "Pre-Suit Demand for Unpaid Wages and Statutory Damages" on behalf of Leonel Diaz; served by US 

mail to Sierra at the restaurant and to Registered Agent at their address; also served registered agent a copy by email

AFS 

05/05/23 Prepared a revised "Exhibit P-142" (summary of damages calculation) in light of the Court's recent order AFS 05/05/23 Email to opposing counsel enclosing updated Plaintiff's exhibit package (noting that the only change is to this newly 

revised exhibit P-142)

faz 

05/05/23 Prepared revised verdict forms in light of the Court's recent order requiring the same AFS 05/05/23 178 Drafted and filed Notice of Filing Revised Proposed Verdict Forms; attaching two proposed verdict forms as exhibits AFS 05/05/23 Email to Judge Goodman enclosing the Word version of Plaintiffs' revised proposed verdict forms faz 05/05/23 Email to opposing counsel Pollock responding to his email earlier today re Defendants' forthcoming request for 

clarification/reconsideration as to dismissing Plaintiff Chavez's FMWA claim

AFS 

05/05/23 Email from opposing counsel Shulby asking if, other than Exhibit P-142, the others remain unchanged; sent brief response 

indicating that is the case

faz 

05/06/23 179 Analyzed [Defendants] (incorrectly labeled as "Plaintiff's") Motion to Reconsider Order Dismissing without Prejudice

Plaintiff Leonel Diaz's Florida Minimum Wage Act Claim and Requiring Revised Proposed Verdict Forms, and Order on 

Remaining Legal Issues Listed in the Parties' Joint Pretrial Stipulation, and the cites cited thereby by Defendants in support 

AFS 

05/06/23 180 Reviewed the Court's Paperless Order requiring expedited response by Plaintiffs no later than tomorrow at noon to 

Defendants' recent Motion to Reconsider . . .[179]

AFS 

05/06/23 Email to AFS enclosing G.I.C. Corp., Inc. v. U.S., 121 F.3d 1447 (11th Cir. 1997) re pretrial stipulations are binding faz 

05/06/23 Prepared initial draft of Plaintiffs' response to Defendants' recent Motion to Reconsider . . .[179]; this filing will serve as our 

response and our own motion for relief/reconsideration from trial orders

AFS 

05/07/23 Email to opposing counsel Pollock re conferring on the relief sought by Plaintiffs' dual-purpose response/motion filing, due 

by noon today; exchanged an additional three emails

AFS 

05/07/23 181 Finalized and filed Plaintiffs' Response to Defendants' Motion to Reconsider . . .[179]; this filing is also a Plaintiffs' Motion 

for Reconsideration of the recent trial orders

AFS 

05/07/23 182 Reviewed the Court's Paperless Order requiring supplemental notice by Tues 5/9 @ 9am re: "parties will each file a notice 

of authorities (not a memorandum of law) on the issue of whether a tip pool is invalidated by participation in it by an 

undocumented co-worker. The Court is looking for on-point authority, not cases addressing, in general, the economic realities test (for determining whether a plaintiff is an employee or an independent contractor) or whether an employer is 

legally required to pay undocumented employees"

AFS 

05/07/23 183 Reviewed the Court's Paperless Order Canceling May 8, 2023 Jury Trial; to be rescheduled; more detailed order to follow; 

advised Plaintiffs; Chavez intends to travel back to Oklahoma as soon as possible in light of this cancellation

AFS 

05/07/23 In-office meeting with Plaintiffs to prepare for trial and answer any questions they may have AFS 05/07/23 184 Reviewed the Court's Order Re: Trial Postponement AFS 

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Date DE Professional Services Rendered Staff Ho05/08/23 185 Reviewed the Court's "Order Re: Trial Rescheduling, Briefing, and Questions"; calendared Zoom hearing scheduled 

therein; will need to prepare a motion to continue/reschedule this Zoom hearing as it is set for a day I will be out of town

AFS 

05/08/23 Call to opposing counsel Pollock re availability for a rescheduled hearing AFS 05/08/23 186 Drafted and field Plaintiffs' Motion to Reschedule Zoom Hearing; provided alternative dates therein AFS 05/08/23 187 Reviewed the Court's Paperless Order Granting Motion to Reschedule Zoom Hearing [186] AFS 05/08/23 188 Reviewed the Court's Paperless Order re rescheduled hearing; 5/11/23 @ 3p; calendared; via Zoom AFS 05/10/23 Prepared responses to the items the Court indicated in its Order re Trial Rescheduling, Briefing and Questions [185] the 

parties should be ready to discuss at the Zoom hearing

AFS 

05/11/23 Call to Leo Diaz to discuss his dates of availability for trial going forward AFS 05/11/23 Call to Erik Chavez to discuss his dates of availability for trial going forward and requesting that he itemize all costs he has 

incurred in connection with his flying down to Miami from Oklahoma this past weekend for the trial

AFS 

05/11/23 Saved copies of receipts sent to us by Erik Chavez re expenses related to attending trial scheduled for 5/8/23 faz 

05/11/23 Zoom schedule conferencing before Judge Goodman (3p-447p) AFS 05/11/23 189 Minute entry for Zoom hearing held this afternoon before Judge Goodman faz 05/12/23 190 Reviewed the Court's Post-Hearing Administrative Order; calendared the deadlines set forth therein AFS 05/17/23 Email to Chavez and Diaz enclosing copy of the recent order rescheduling the trial to 9/11/23; sent both in its original 

English and in Spanish

faz 

05/19/23 191 Reviewed Defendants' Notice of Filing Revised Proposed Verdict Forms AFS 05/19/23 Reviewed email from opposing counsel to the Court enclosing Word versions of the verdict forms filed earlier today AFS 05/24/23 192 Reviewed Defendants' "Response In Opposition To Plaintiffs’ Motion For Relief From Trial Orders Introducing New Issues 

And Evidence For Special Set Trial Contrary To Pretrial Stipulations Without Finding Of “Manifest Injustice”, And Response To “Plaintiff’s [Sic] Motion To Reconsider Order Dismissing . . . , And Order On Remaining Legal Issues Listed In The 

Parties’ Joint Pretrial Stipulation” (filed yesterday); deadline to reply is 5/30/23

AFS 

05/24/23 Downloaded and saved the approx. 30 cases cited in Defendants' response [192] faz 05/29/23 Began drafting Plaintiffs' Reply to Defendants' "Response In Opposition To Plaintiffs’ Motion For Relief From Trial 

Orders . . ." [192]

AFS 

05/30/23 193 Completed drafting Plaintiffs' Reply to Defendants' "Response In Opposition To Plaintiffs’ Motion For Relief From Trial 

Orders . . ." [192]; filed

AFS 

05/31/23 Legal research regarding the 11 issues of law the Court has required the parties to brief AFS 06/01/23 Began drafting the "11 Issues" memo of law required by the Court's Orders [185, 190]; completed draft of "Issue 1" AFS 06/02/23 Drafted "issue 2" and "Issue 3" memos of law AFS 06/03/23 Drafted "Issues" 4 and 5 memos of law AFS 06/05/23 Drafted memo of law re "Issue 6" AFS 06/06/23 Completed draft of memos of law re issues 7 and 8 AFS 06/07/23 Completed memos of law regarding issues 9 and 10 AFS 06/09/23 Completed memo or law pertaining to issue 12 (the Court directed the parties to skip over #11 and jump to #12 (See ECF 

190))

AFS 

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Date DE Professional Services Rendered Staff Ho06/12/23 Reviewed and edited the 11 separate draft memos of law pertaining to the "11 issues" the Court required the parties to 

brief; finalized for filing

AFS 

06/12/23 194 Drafted a cover "Notice of Compliance and of Filing Memoranda of Law"; filed and attached the 11 memoranda of law (plus 

an additional blank one as the "Issue 11" placeholder in accordance with the Court's Order [190]) 

AFS 

06/13/23 195 Analyzed Defendants' Memorandum of Law Regarding the Order Re: Trial Rescheduling, Briefing and Questions (filed last 

night)

AFS 

06/13/23 196 Reviewed NEF re Clerk's Recategorizing of Notice of Compliance and of Filing Memoranda of Law [194] AFS 

06/13/23 196 Reviewed Clerk's Notice to Filer re [194]; no need to refile AFS 06/13/23 197 Paperless NEF re Clerk's Notice to Filer regarding [194]; not necessary to refile document AFS 08/02/23 1047a-1049a Incoming call from opposing counsel Brian Pollock re touching base with respect to current settlement 

discussions while we are in a lull in activity on this case; AFS stepped out for a moment but I will pass message along and Brian will call back in 5-10 mins

faz 

08/02/23 1126am incoming call from Brian Pollock re settlement negotiations status AFS 08/02/23 313p-328p, incoming call from Brian Pollock re continued settlement discussions and offer AFS 08/03/23 Email from opposing counsel Pollock re settlement discussions and memorializing Defendants' current offer AFS 

08/04/23 Email to opposing counsel Pollock re counter-offer AFS 08/04/23 Email from opposing counsel Pollock re confirming settlement amount; he will work on the initial draft of settlement 

agreement

AFS 

08/04/23 198 Reviewed the Notice of Settlement, filed by Defendants AFS 08/04/23 199 Reviewed the Court's Notice of Court Practice Upon Notice of Settlement; calendared the deadline set forth therein faz 

08/08/23 Reviewed email from opposing counsel Pollock enclosing initial draft of settlement agreement AFS 08/10/23 Email from opposing counsel Pollock re settlement agreement draft status; sent brief response saying I'll provide it 

tomorrow

AFS 

08/11/23 Reviewed and revised the initial 9-page draft of settlement agreement AFS 08/11/23 Email to opposing counsels enclosing revised draft of settlement agreement AFS 08/12/23 Email from opposing counsel Shulby enclosing latest version of settlement agreement, which was also provided in "clean"

(final) format

AFS 

08/14/23 Made very minor revision to the settlement agreement and emailed to opposing counsel in Word and PDF AFS 08/14/23 Email to both Plaintiffs enclosing the settlement agreement for their review/comments faz 08/14/23 Calls to both Plaintiffs advising copies of the agreement have been emailed to them faz 

08/16/23 In-office meeting with Plaintiff Diaz to sign the settlement agreement and complete the required tax forms AFS 

08/17/23 Prepared settlement agreement for electronic execution by Plaintiff Chavez; uploaded to SignWell signature service; sent 

separate email directly to Plaintiff Chavez to advise that the settlement agreement for electronic execution will come from "Anthony F. Sanchez P.A. via SignWell"

faz 

08/17/23 Email from SignWell signature service notifying the agreement has been executed; saved to file faz 08/18/23 Email from opposing counsel Shulby advising he expects to received signed agreement from his clients by Monday (8/21) AFS 08/18/23 Exchanged four emails with opposing counsel Pollock/Shulby providing the Plaintiffs' counterparts and respective 

completed tax forms

faz 

08/21/23 Prepared form of joint notice to file upon notifying the agreement has been executed by Defendants AFS 

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Date DE Professional Services Rendered Staff Ho08/21/23 Email to opposing counsels reminding the deadline to provide notice to the Court is today, and attaching a form of joint 

notice

AFS 

08/21/23 504p, brief call to opposing counsel Pollock re status of agreement; he is in the same position as we are, waiting to receive 

an executed Defendants' counterpart, but reaffirmed that we do have an agreement

AFS 

08/21/23 Reviewed emails from opposing counsel Shulby advising he has been in Court all day and has not had an opportunity to 

work on this case today, and then a subsequent email from his office providing a signature page from the Defendants; saved to file

AFS 

08/21/23 200 Filed the Joint Notice of Executed Settlement Agreement, in compliance with the Court's previous Order [199], after 

receiving the go-ahead from AFS

faz 

08/22/23 201 Reviewed the Court's paperless order scheduling fairness hearing for 8/25/23 via Zoom @ 1045a; Zoom details to follow 

separately; calendared; order also established deadline to provide certain materials by tomorrow at 5p; calendared

faz 

08/22/23 202 Reviewed the Court's paperless order providing the Zoom details for the upcoming hearing on 8/25/23; updated calendar 

event to include these details

faz 

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