UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

CASE NO. 1:22-CV-23074-BLOOM/OTAZO-REYES 

OCTAVIO COLLADO, 

for himself and all others 

similarly situated, 

Plaintiff, 

v. 

450 NORTH RIVER DRIVE, LLC, 

D/B/A KIKI ON THE RIVER, 

RJ RIVER, LLC, and ROMAN JONES, 

Defendants. 

_______________________________________/

JOINT MOTION FOR ENTRY OF STIPULATED CONFIDENTIALITY 

AGREEMENT AND PROTECTIVE ORDER 

Defendants, 450 North River Drive, LLC, d/b/a Kiki on the River (“Kiki”), RJ River, LLC, 

(RJ), and Roman Jones (“Jones”) (collectively “Defendants”), and Plaintiff, Octavio Collado 

(“Collado”) (collectively the “Parties”), by and through their undersigned attorneys, jointly move 

pursuant to Fed. R. Civ. P. 26(c), S.D. Local Rule 26.1, and this Court’s Order (ECF No. 121) for 

entry of the attached proposed Stipulated Confidentiality Agreement and Protective Order 

(“Protective Order”) regarding confidentiality of discovery material. In support of this Joint 

Motion, the Parties state the following: 

1. Plaintiff filed a claim for himself and others seeking for unpaid wages under federal 

and Florida law. The Parties anticipate exchanging extensive discovery and seek to exchange 

information, including information and materials that are confidential, privileged, and/or contain 

personal identifying information. 

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2. In particular, the Parties seek to avoid the wrongful disclosure of confidential or 

privileged sensitive financial information, personnel information and business records that may be 

contained in Defendant’s files and/or Plaintiff’s records. The parties anticipate that during the 

course of this litigation, the parties may be required to exchange information relating to payroll 

records and other personal identifiable information. 

3. The standard governing the right of access as it applies to particular documents 

requires the court to balance the competing interests of confidentiality and the right of public 

access on a case-by-case basis. Chicago Tribune Co. v. Bridgestone/Firestone, Inc., 263 F.3d 

1304, 1312 (11th Cir. 2001). In the case of sensitive documents such as payroll records and other 

records with personal identifiable information, the Parties’ interest in preserving confidential and 

sensitive information clearly outweighs the public’s right to access the information. 

4. Further, this Court has directed the Parties to submit a confidentiality order to 

protect the confidential and sensitive nature of records and information to be exchanged. ECF No. 

121 at ¶ 1. 

5. The entry of the Protective Order proposed by the Parties will permit the exchange 

of the information covered by the Protective Order by the Parties for the purpose of preparing their 

claims and defenses in this litigation without risk of that information becoming generally known, 

to the detriment of the Parties, and the procedure for designating documents and resolving those 

designations. A copy of the proposed Protective Order is attached as Exhibit “A.” 

6. The Parties agree that the attached proposed Protective Order will protect the 

confidentiality of privileged and sensitive information and believe that its entry will promote “the 

just, speedy, and inexpensive determination” of this action. Fed. R. Civ. P. 1. 

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WHEREFORE, the parties respectfully request that the Court enter the Protective Order 

attached as Exhibit A. 

CERTIFICATE OF GOOD FAITH 

The Parties hereby certify that this Motion is being filed jointly; thus, there is no objection 

to the relief sought herein. 

Dated: June 22, 2023 

Respectfully submitted, 

s/ Brian Pollock 

Brian Pollock, Esq. 

Florida Bar No. 174742 

Email: brian@fairlawattorney.com 

FAIRLAW FIRM 

135 San Lorenzo Ave. 

Coral Gables, Florida 33146 

Telephone: (305) 230-4884 

Counsel for Plaintiff 

s/ Reynaldo Velazquez 

Reynaldo Velazquez, Esq. 

Florida Bar No.: 069779 

Email: rey.velazquez@jacksonlewis.com 

Roman Sarangoulis, Esq. 

Florida Bar No. 1011944 

Email: roman.sarangoulis@jacksonlewis.com

JACKSON LEWIS P.C. 

One Biscayne Tower 

2 South Biscayne Boulevard, Suite 3500 

Miami, Florida 33131 

Telephone: 305-577-7600 

Counsel for Defendants, 450 North River Drive, 

LLC, Kiki on the River, and Roman Jones 

s/ Allan Reiss 

Allan Reiss, Esq. 

Florida Bar No. 858500 

Email: asr@Levinelawfirm.com 

LEVINE & PARTNERS, P.A. 

3350 Mary Street 

Miami, Florida 33133 

Telephone: (305) 372-1352 

Counsel for RJ River, LLC

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