135 San Lorenzo Avenue, Suite 770, Coral Gables, FL 33156

TEL 305.230.4884 FAX 305.230.4844

www.fairlawattorney.com

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

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

OCTAVIO COLLADO,

Plaintiff,

vs.

450 NORTH RIVER DRIVE, LLC,

D/B/A KIKI ON THE RIVER, 

RJ RIVER, LLC AND 

ROMAN JONES,

Defendants.

______________________________/

PLAINTIFF’S NOTICE OF DISCOVERY HEARING

Plaintiff, Octavio Collado, notices the Court and all parties of the discovery hearing 

scheduled before Magistrate Judge Alicia M. Otazo-Reyes at 11:30 a.m. on April 5, 2023, by 

Zoom (instructions to be provided by the Court) on the following issue(s):

A. Initial Disclosure Documents.

1. Defendants served their Initial Disclosures on November 28, 2022, and disclosed

documents on November 28, 2022, and December 20, 2022.

2. Defendants redacted the names of everyone but Mr. Collado and the six Opt-In 

Plaintiffs who joined these proceedings by December 20, 2022.

3. Defendants disclosed the payroll records for years 2019, 2020, 2021, and 2022 but 

did not disclose documents for years 2017 and 2018, which also are at issue in this lawsuit based 

on Counts II and III.

Case 1:22-cv-23074-BB Document 103 Entered on FLSD Docket 03/16/2023 Page 1 of 3
135 San Lorenzo Avenue, Suite 770, Coral Gables, FL 33156

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4. Defendants did not provide the payroll records containing the names of all persons 

who received tips to enable Plaintiff to perform an accounting of those records for the five (5) 

relevant years in this lawsuit.

5. At issue is whether Defendants should be required to provide payroll records that 

include the names of all persons who received tips during the time relevant to this lawsuit 

(September 23, 2017, to the present).

B. Responses and Objections to Interrogatories to Defendants, 450 North River 

Drive, LLC and Roman Jones.

6. Mr. Collado served Interrogatories on Defendants 450 North River Drive, LLC,

and Roman Jones.

7. Defendants 450 North River Drive, LLC, and Roman Jones responded separately 

to the Interrogatories on February 8, 2023.

8. The parties conducted several conferrals relating to the contents of the Answers and 

Objections to the Interrogatories.

9. The parties were unable to resolve their disputes relating to the following:

a. INTs to Roman Jones Nos.: 1, 2, 6, 7, 10, 11, 12, 13, and 14. Defendants 

agreed to revisit the issues regarding INT Nos. 12 and provide their updated 

position by March 24, 2023.

b. INTs to 450 North River Drive, LLC, Nos.: 1, 2, 3, 5, 6, 7, 8, 12, 14, 17, 

19. Defendants agreed to revisit the issues regarding INT Nos. 5, 8, 12, and 

19 and their updated position by March 24, 2023.

10. If the parties resolve any of the issues surrounding the INTs identified above that 

Defendants agreed to revisit before the discovery hearing, Mr. Collado will advise the Court.

Case 1:22-cv-23074-BB Document 103 Entered on FLSD Docket 03/16/2023 Page 2 of 3
135 San Lorenzo Avenue, Suite 770, Coral Gables, FL 33156

TEL 305.230.4884 FAX 305.230.4844

www.fairlawattorney.com

Respectfully submitted this 16th day of March 2023,

s/Brian H. Pollock, Esq.

Brian H. Pollock, Esq.

Fla. Bar No. 174742

brian@fairlawattorney.com

FAIRLAW FIRM

135 San Lorenzo Avenue

Suite 770

Coral Gables, FL 33146

Tel: 305.230.4884

Counsel for Plaintiff

Case 1:22-cv-23074-BB Document 103 Entered on FLSD Docket 03/16/2023 Page 3 of 3