EXHIBIT “B” 

EXHIBIT “B”

Case 1:22-cv-23074-BB Document 163-2 Entered on FLSD Docket 07/17/2023 Page 1 of 5
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

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

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, 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 is Octavio Collado vs. 

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 yet decided whether Mr. Collado or the 

Defendants are correct. There is no money available now and no guarantee that any money will be

available to you. However, you have a choice about asserting your legal rights in this case.

YOUR LEGAL RIGHTS AND OPTIONS IN THIS LAWSUIT

RETURN YOUR CONSENT 

FORM BEFORE 

____, --, 2023

Be a part of this lawsuit.

By timely returning the Consent Form, you 

become a party to this lawsuit, favorable or 

unfavorable. You gain the possibility of

receiving your share of any money that may be 

recovered from a trial or settlement, but you 

give up your right to separately sue Defendants 

for any tips claimed in this lawsuit.

DO NOTHING

You will not be a part of this lawsuit.

If you do not timely return the Consent Form, 

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 bring a sue

Defendants for any alleged failure to abide by 

the applicable federal law. 

Case 1:22-cv-23074-BB Document 163-2 Entered on FLSD Docket 07/17/2023 Page 2 of 5
NOTICE OF RIGHT TO JOIN LAWSUIT

(Page 2)

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 filed their Consent Forms and 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.

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

you do not win, FairLaw Firm will not charge you for any attorneys’ fees or costs. A copy of the 

contingency fee agreement executed by Mr. Collado may be obtained upon request from FairLaw 

Firm. If there is a monetary recovery, FairLaw Firm will be paid by either a percentage of any 

settlement or monetary judgment obtained in favor of everyone who joined the Collective Action 

or by asking the Defendants to pay FairLaw Firm for the attorneys’ fees and costs expended. The 

Court may be asked to determine and/or approve the attorneys’ fees awarded to the FairLaw Firm. 

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, email, or text on or before____ ___, 2023:

Representative Plaintiff’s Counsel:

Brian H. Pollock, Esq. 

FairLaw Firm 

135 San Lorenzo Avenue 

Suite 770 

Coral Gables, FL 33156

Tel: (305) 230-4884 

Text: (786) 386-0885

Fax: (305) 230-4844 

brian@fairlawattorney.com

www.fairlawattorney.com

4877-4238-3985, v. 1

Case 1:22-cv-23074-BB Document 163-2 Entered on FLSD Docket 07/17/2023 Page 3 of 5
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

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

IF YOU ARE OR IF YOU WERE WORKING AS A FRONT-OF-THEHOUSE 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 in federal court in Miami, Florida, alleging that he and the other 

front-of-the-house tipped employees were not paid all the tips they earned in violation of the Fair 

Labor Standards Act. The case is Octavio Collado vs. 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.

This Notice is a reminder that to join this lawsuit, you must complete the 

“Consent to Join Pursuant to 29 U.S.C. §216(b)” form and mail, fax, email, or 

text it to the FairLaw Firm on or before ______________ ____, 2023 to 

participate.

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 yet decided whether Mr. Collado or 

Defendants are correct. There is no money available now and no guarantee that any money will be 

available to you. However, you have a choice about asserting your legal rights in this case. If there 

is no recovery or judgment in Plaintiff’s favor, you will not be responsible for any attorneys’ fees.

If you did not receive the initial Court-Authorized Notice or the “Consent to Join Pursuant to 29 

U.S.C. §216(b),” then please contact the Representative Plaintiff’s Counsel:

Brian H. Pollock, Esq.

FairLaw Firm

135 San Lorenzo Avenue

Suite 770

Coral Gables, FL 33156

Tel: (305) 230-4884

Text: (786) 386-0885

Fax: (305) 230-4844

brian@fairlawattorney.com

www.fairlawattorney.com

4895-3826-6993, v. 1

Case 1:22-cv-23074-BB Document 163-2 Entered on FLSD Docket 07/17/2023 Page 4 of 5
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.

____________________________________/

 

CONSENT TO JOIN PURSUANT TO 29 U.S.C. §216(b) 

 

1. My name is _____________________________________.

2. I consent, agree, and opt to become a Plaintiff in this lawsuit brought under the FLSA, 29 

U.S.C. §201, et seq., against my current/former employer, 450 North River Drive, LLC, d/b/a Kiki on the 

River, and alleged employers RJ River, LLC, and Roman Jones, (collectively “Defendants”).

3. I wish to assert a claim for alleged unpaid/underpaid tips (overtips) against Defendants so I 

can recover all tips improperly retained or distributed, and either liquidated damages if awarded by the Court

or interest, plus the attorneys’ fees and costs available to me.

4. I agree to be bound by any adjudication of this action by the Court, whether it is favorable 

or unfavorable. I further agree to be bound by any collective action settlement herein that is recommended 

by FairLaw Firm, approved by the Class Representative, and approved by the Court as fair and reasonable.

5. I designate the FairLaw Firm to represent me in this case.

This form may be utilized and/or re-filed in an individual action for me, as necessary.

Dated ______________, 202__. Signed:_________________________

Printed Name:____________________

Your Address, Email, and Telephone Are Needed, But Will Not Filed With The Court 

 

Address: _____________________________________ Tel No.:___________________________

____________________________________ Email: ____________________________

MAIL, EMAIL, TEXT, OR FAX YOUR COMPLETED FORM TO:

FairLaw Firm 

135 San Lorenzo Avenue, Suite 770, Coral Gables, FL 33156 / brian@fairlawattorney.com 

TEL 305.230.4884 TEXT 786.386.0885 FAX 305.230.4844 

 

Case 1:22-cv-23074-BB Document 163-2 Entered on FLSD Docket 07/17/2023 Page 5 of 5