UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

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

OCTAVIO COLLADO,

Plaintiff,

COLLECTIVE ACTION

vs. 

450 NORTH RIVER DRIVE, LLC,

D/B/A KIKI ON THE RIVER,

RJ RIVER, LLC AND ROMAN JONES,

Defendants.

_____________________________________ / 

REMINDER NOTICE

This is a Court-Authorized Reminder Notice and is not a solicitation from a lawyer.

The Court has made no finding about the merits of the case at this time. 

IF YOU ARE OR IF YOU WERE WORKING AS A FRONT-OF-THE-HOUSE TIPPED 

EMPLOYEE AT KIKI ON THE RIVER BETWEEN JUNE 7, 2020, AND THE PRESENT, 

AND BELIEVE YOU RECEIVED SOME BUT NOT ALL THE TIPS YOU EARNED, 

THEN THIS COLLECTIVE ACTION LAWSUIT MAY AFFECT YOUR RIGHTS. 

Plaintiff, Octavio Collado, sued Defendants, 450 North River Drive, LLC d/b/a Kiki on the River, 

RJ River, LLC, and Roman Jones (collectively “Kiki on the River”), in federal court in Miami, 

Florida, alleging that he and the other similarly situated front-of-the-house tipped employees (such 

as captains, servers, bottle servers, bussers, food runners, bartenders, barbacks, hosts, hostesses, 

and dockmasters) were not paid all the tips they earned in violation of the Fair Labor Standards 

Act. The case name is Octavio Collado v. 450 North River Drive, LLC, RJ River, LLC, and Roman 

Jones. The Case is pending in the Southern District of Florida with Case Number 1:22-CV-23074-

BLOOM/OTAZO-REYES. 

The Defendants deny Mr. Collado’s claims and contend that they acted lawfully and did not 

improperly retain or distribute any tips. 

The Court has not decided whether Mr. Collado or the Defendants are correct. There is no money 

available now and no guarantees there will be any money available to you. You have a choice 

about whether you want to join this lawsuit and assert your legal rights in this case.

Case 1:22-cv-23074-BB Document 168-3 Entered on FLSD Docket 07/21/2023 Page 1 of 3
YOUR LEGAL RIGHTS AND OPTIONS IN THIS LAWSUIT

RETURN YOUR CONSENT 

FORM BEFORE 

September 22, 2023 

Be a part of this lawsuit.

By timely returning the Consent Form, you become 

a party plaintiff to this lawsuit against Kiki on the 

River, whether the outcome is favorable or 

unfavorable. By joining, you gain the possibility of 

receiving the tips you claim are owed to you if they 

are recovered after a trial or settlement, but you 

give up your right to separately sue Kiki on the 

River for any claims made in this lawsuit. 

DO NOTHING

You will not be a part of this lawsuit.

If you do decide not to timely return the Consent 

Form or otherwise fail to do so, you will not 

participate in this lawsuit and if money is 

recovered, you will not share in it. But you will 

keep any rights to sue Defendants for any claims 

alleged in this lawsuit. 

NOTICE OF RIGHT TO JOIN LAWSUIT

If you choose to join this lawsuit, you may select your own separate counsel to represent you or 

you can choose to be represented by the FairLaw Firm, which represents Octavio Collado and the 

other people who already joined the lawsuit. 

It is a violation of federal law for the Defendants to fire, discipline, or in any manner discriminate 

or retaliate against you for taking part in this case. If you believe that you have been penalized, 

discriminated against, or disciplined in any way due to your receiving this notification, considering 

whether to join this lawsuit, or joining this lawsuit, you may contact any lawyer of your choosing.

ATTORNEY FEES

Mr. Collado entered into a contingency fee agreement with the FairLaw Firm, which means that if 

he does not win, Plaintiff’s counsel will not charge him for any attorneys’ fees or costs. A copy of 

the contingency fee agreement executed by the named Plaintiff may be obtained upon request from 

the FairLaw Firm. If there is a monetary recovery or settlement, the Court will approve the amount 

of the attorney fees and costs the FairLaw Firm receives.

To join the lawsuit, you must complete the “Consent to Join Pursuant to 29 U.S.C. § 216(b)” form 

and send it to FairLaw Firm by mail, fax, or email on or before September 22, 2023. 

Case 1:22-cv-23074-BB Document 168-3 Entered on FLSD Docket 07/21/2023 Page 2 of 3
Representative Plaintiff’s Counsel:

Brian H. Pollock, Esq. 

FairLaw Firm

135 San Lorenzo Avenue 

Suite 770 

Coral Gables, FL 33156 

Tel: (305) 230-4884 

Fax: (305) 230-4844 

brian@fairlawattorney.com

www.fairlawattorney.com

Case 1:22-cv-23074-BB Document 168-3 Entered on FLSD Docket 07/21/2023 Page 3 of 3