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. 

_______________________________________/

COLLECTIVE ACTION

SECOND JOINT MOTION TO RESCHEDULE MEDIATION 

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 this Court to permit the Parties to reschedule the currently set mediation. In support 

thereof, the Parties state the following: 

1. The claims in this matter concern employment-related disputes pertaining to 

alleged unlawful distribution and/or retention of tips. 

2. The following procedural history and case issues have resulted in the Parties 

agreeing to reschedule the mediation from October 5, 2023, to February 8, 2024: 

a. On July 19, 2023, Plaintiff filed a Motion for Class Certification Pursuant to 

Rule 23(b)(3) for Counts II and III. [ECF No. 164]. Defendants filed a 

Response in Opposition to this Motion, and it remains before the Court. The 

Courts’ ruling on this Motion is critical to any potential settlement because it 

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

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would likely significantly impact the number of persons affected and, 

consequently, alleged damages. 

b. Further, Magistrate Judge Otazo-Reyes recently entered an Order on 

discovery issues, (ECF No. 203), which Plaintiff has appealed (ECF No. 213). 

Defendants need responses to the written discovery to have a productive 

mediation. 

c. Finally, the Parties are in the process of setting depositions. The additional 

time will facilitate taking of depositions, which Defendants believe are 

necessary for a productive mediation. 

3. As a result of the foregoing procedural history and case issues, the Parties request 

the Court’s permission to reschedule the mediation until February 8, 2024, allowing it occur after 

the issues in the case are more fully developed. 

4. The Parties respectfully submit that the relief sought herein is necessary to have 

meaningful discussions about potential settlement during their mediation. 

5. This motion is not intended to delay this litigation as the Parties remain actively 

engaged in discovery and working together to narrow and limit issues as much as possible. 

WHEREFORE, Defendants, 450 North River Drive, LLC, d/b/a Kiki on the River, RJ 

River, LLC, and Roman Jones, and Plaintiff, Octavio Collado, respectfully request the Court 

permit the Parties to reschedule the currently set mediation date from July 26, 2023, to October 

5, 2023. 

CERTIFICATE OF GOOD FAITH 

The Parties hereby certify that they conferred regarding the issues and relief requested in 

this Motion and decided to file the Motion jointly because of the necessity of the relief sought. 

Dated: September 29, 2023 

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

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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 

CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the foregoing document is being served on 

September 29, 2023, on all counsel of record on the Service List below via transmission of 

Notices of Electronic Filing generated by CM/ECF. 

 s/ Roman Sarangoulis 

 Roman Sarangoulis, Esq. 

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

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SERVICE LIST 

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 

Attorneys for Plaintiff 

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 450 North River Drive, LLC, d/b/a 

Kiki on the River, and Roman Jones

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 

Attorneys for RJ River, LLC

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