UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

CASE NO.: 1:20-cv-22603-MGC

ERIK CHAVEZ, individually, and

on behalf of others similarly situated, 

Plaintiff,

vs.

GRILL ENTERPRISES, LLC, a 

Florida Limited Liability Company, d/b/a 

Los Parrilleros and Parrilleros Tavern, and 

RUBEN SIERRA, individually,

Defendants.

_________________________________/

DEFENDANT GRILL ENTERPRISES, LLC’S SUPPLEMENTAL ANSWERS

TO PLAINTIFF’S FIRST SET OF INTERROGATORIES

Defendant, GRILL ENTERPRISES, LLC, by and through the undersigned counsel, and 

pursuant to Rule 33, Federal Rules of Civil Procedure, serves this, its supplemental response to 

Plaintiff’s First Interrogatories.

Respectfully submitted,

TODD W. SHULBY, P.A.

Todd W. Shulby, Esq.

1792 Bell Tower Lane 

Weston, Florida 33326

Telephone: (954) 530-2236

Facsimile: (954) 530-6628

E-mail: tshulby@shulbylaw.com

Counsel for Defendants

By: /s/Todd W. Shulby, Esq.

Florida Bar No.: 068365

Case 1:20-cv-22603-JG Document 167-2 Entered on FLSD Docket 05/04/2023 Page 1 of 4
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DEFENDANT GRILL ENTERPRISES, LLC’S SUPPLEMENTAL 

RESPONSES TO INTERROGATORIES

5. Please provide, with regard to all restaurants and taverns operated by Defendants 

or its subsidiaries, a complete list of employees or former employees (to include name, job title, 

address, telephone number, social security number and e-mail address) – or other person who 

rendered services to, or for the benefit of, the Defendants and its clients – who were or are paid a 

base wage which is or was less than the then applicable minimum wage.

SUPPLEMENTAL RESPONSE:

See attached list.

13. Identify by full name, last known address, and telephone number, each and every

individual believed or known to you to have knowledge or to have witnessed the events set forth 

in the pleadings, including all those persons whom you may call as witnesses at trial during your 

defense or rebuttal case.

SUPPLEMENTAL RESPONSE:

Ruben Sierra

10775 NW 41st Street

Doral, FL 33178

Telephone: (305) 597-0019

Knowledge/ Information: The witness is the owner of Grill Enterprises, LLC. It is 

anticipated that the witness will be able to testify as to: (1) Plaintiffs’ employment; (2) 

Plaintiffs’ employer; (3) Plaintiffs’ hours worked; (4) how Plaintiffs and others recorded 

the hours they worked; (5) Plaintiffs’ compensation; (6) Plaintiffs’ tips received; (7) 

Plaintiffs’ handling and recording of the tips received; (8) the tips paid out to others by 

Plaintiffs; (9) the persons who worked for Defendant who received tips and tip-outs; (10) 

Defendant’s payroll practices and procedures, tip-out practices and procedures and payroll 

taxes/ withholdings; (11) changes to Defendant’s tip-out practices and procedures (in or 

about January 2019); (12) Defendant’s payroll including documentation of wages, hours, 

tips and the tip credit, withholdings and taxes; (13) notification to tipped employees of the 

tip credit and Defendants’ tip-out practices and procedures; (14) documentation notifying 

tipped employees of the tip credit and Defendants’ tip-out procedures including payroll 

documents and posters; (15) Plaintiff Chavez’s voluntary resignation and the 

circumstances leading thereto; (16) Plaintiff Chavez’s claim that he was terminated due to 

alleged complaints/ statutorily protected activity; (17) the events set forth in the pleadings; 

(18) the allegations, admissions and/or denials contained in the pleadings; (19) the defenses 

raised in the pleadings. 

Nelson Gonzalez

10775 NW 41st Street

Case 1:20-cv-22603-JG Document 167-2 Entered on FLSD Docket 05/04/2023 Page 2 of 4
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Knowledge/ Information: It is anticipated that the witness would have information about 

hours, days and weeks worked by Plaintiff, the wages, compensation and/or remuneration 

paid to Plaintiff and/or Plaintiff’s business, Plaintiff’s damages and efforts to mitigate 

damages.

Florida Department of Economic Opportunity

107 East Madison Street

Caldwell Building

Tallahassee, Florida 32399

Telephone: (850) 245-7105

Knowledge/ Information: It is anticipated that the witness would have information about 

hours, days and weeks worked by Plaintiff, the wages, compensation and/or remuneration 

paid to Plaintiff and/or Plaintiff’s business (including unemployment compensation), 

Plaintiff’s damages and efforts to mitigate damages. It is further anticipated that the witness 

may have information about the end of Plaintiff’s employment with Defendant and 

Plaintiff’s voluntary resignation from employment.

U.S. Department of Labor

Wage and Hour Division

510 Shotgun Rd., Ste. 140

Sunrise, FL 33326

Telephone: (954) 356-6896

Knowledge/ Information: It is anticipated that the witness would have information about a 

prior DOL investigation/ audit of Defendant and its basis, findings, and resolution, 

including with respect to Leonel Diaz.

Internal Revenue Service

1111 Constitution Avenue, NW

Washington, DC 20224

Telephone: (202) 622-5000

Knowledge/ Information: It is anticipated that the witness would have information about 

the wages, compensation and/or remuneration paid to Plaintiff and/or Plaintiff’s business, 

Plaintiff’s damages and efforts to mitigate damages.

14. With respect to those individuals identified in response to Interrogatory No. 13 

above, describe in detail the nature and substance of the knowledge or information he or she 

possesses.

SUPPLEMENTAL RESPONSE:

Please see complete response to Interrogatory 13 above which includes the nature and 

substance of the knowledge or information the witnesses possess.

Case 1:20-cv-22603-JG Document 167-2 Entered on FLSD Docket 05/04/2023 Page 3 of 4
DECLARATION OF DEFENDANT 

I have read the foregoing answers to interrogatories and do declare under penalty of perjury 

that they are true and correct to the best of my knowledge and belief. 

REUBEN SIERRA, for 

GRILL ENTERPRISES, LLC, a 

Florida Limited Liability Company, 

d/b/a Los Parrilleros and Parrilleros Tavern 

Date: -------------

Case 1:20-cv-22603-JG Document 167-2 Entered on FLSD Docket 05/04/2023 Page 4 of 4