UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

CASE NO. 1:22-CV-23074-BLOOM/Torres 

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. 

_______________________________________/ 

DEFENDANTS’ REPLY IN SUPPORT OF THEIR MOTION FOR 

SANCTIONS PURSUANT TO 28 U.S.C. § 1927 AND THE COURT’S 

INHERENT POWER AGAINST BRIAN POLLOCK, ESQ., AND 

FAIRLAW FIRM WITH SUPPORTING MEMORANDUM OF LAW 

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PRELIMINARY STATEMENT 

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

(“RJ”), and Roman Jones (“Mr. Jones”) (collectively “Defendants”), hereby file this Reply in 

Support of Their Motion for Sanctions against Brian Pollock, Esq., (“Mr. Pollock”) and FairLaw 

Firm (“the Firm”) (collectively “Counsel”), and state as follows. 

Defendants’ Motion for Sanction was filed timely. The Eleventh Circuit has confirmed that 

district courts may sanction attorneys under Section 1927 and the Court’s inherent power even 

after the attorney withdraws from the case. Accordingly, this Court has the authority to sanction 

Counsel. 

Additionally, sanctions are warranted because Counsel vexatiously multiplied these 

proceeding by asserting a claim for violations of the Florida Minimum Wage Act (“FMWA”) 

without any basis in fact or law. Counsel falsely claims in his Response to the Motion for Sanctions 

(“the Response”) that he was pursuing the FMWA claim based on a “novel legal theory.” [ECF 

No. 250 at pp. 3, 20]. That is inaccurate as Counsel actually claimed a minimum wage violation 

in the Third Amended Complaint under the FMWA on the basis of a well-known and frequently 

alleged tip credit violation theory. [ECF No. 122 at pp. 17-29]. 

Specifically, Counsel made false allegations in the Third Amended Complaint when he 

claimed that Plaintiff was paid a “‘tip credit’ wage” and that Kiki “paid Plaintiff . . . a direct hourly 

wage below the direct minimum hourly wage required by the FMWA” in a bad faith attempt to 

get around the Court order dismissing the Second Amended Complaint. [ECF No. 122 at pp. 18-

20, 23-24]. Counsel made these false claims while knowing the allegations could not be supported 

by the facts of this case, and after the Court instructed him that he had to plead Plaintiff was paid 

below the Florida minimum wage to establish an FMWA claim. 

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Significantly, Counsel admits in the Response that Plaintiff’s “hourly wages and service 

charges exceeded the FMWA amount” and claims it “was never disputed” [ECF No. 250 at p. 2]. 

However, the allegations in Count II of the Third Amended Complaint demonstrate that Counsel 

did dispute what he now admits as the truth. If it was never in dispute that Plaintiff’s hourly wages 

and service charges exceeded the Florida minimum wage, then why did Counsel allege in the Third 

Amended Complaint that Plaintiff was paid a “‘tip credit’ wage” and that Kiki “paid Plaintiff . . . 

a direct hourly wage below the direct minimum hourly wage required by the FMWA? [ECF No. 

122 at pp. 18-20, 23-24] (emphasis added). Also, why does Counsel state in his FMWA pre-suit 

letter seeking payment of $18,928,000.00 that the FMWA claim is for “unpaid minimum wages

(including tips)”? [ECF No. 243 at Exhibit A] (emphasis added). The answer to those questions 

is clear - to multiply the proceeding in bad faith by relying on allegations that Counsel now admits 

are false. 

Incredibly, Counsel suggests that because Defendants knew his allegation in the Third 

Amended Complaint were false, the false allegations constitute “no harm, no foul.” Counsel’s 

theory, however, disregards that it took over one year of litigation, Plaintiff’s concessions in the 

interrogatories and deposition, the termination of Counsel by Plaintiff, and the motion for sanctions 

for Counsel to admit the truth - that Plaintiff was paid minimum wage during his employment with 

Kiki. 

Counsel makes additional misrepresentations to this Court in the Response. First, Plaintiff 

implies in the Response that the Court “denied [Defendants’] prior request to sanction [Counsel] 

under Rule 11[,]” which is false. [ECF No. 250 at p. 3]. Defendants never filed a Motion for 

Sanctions pursuant to Rule 11 against Counsel. Second, Counsel claims Defendants admitted to 

liability through their interrogatory answers, which is also untrue. Defendants never admitted that 

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tips were improperly distributed or retained by any individuals that were not entitled to tips. In 

reality, the interrogatory answers in question state that “Kiki distributed all tips that were processed 

by the restaurant from credit card transactions to tipped employees” and that “[a]ny variance that 

may exist[]” pertains to “the distribution of those tips to tipped employees.” 

Finally, Defendants withdraw their argument that Counsel should be sanctioned based on 

his failure to ascertain, prior to and after filing the Third Amended Complaint, that Plaintiff 

received all his cash and credit card tips, and that Plaintiff did not know the difference between 

service charges and tips as reflected in Plaintiff’s sworn deposition testimony. When Defendants 

filed their Motion for Sanction, they relied on the sworn record evidence it ascertained from 

Plaintiff’s sworn interrogatory answers and deposition testimony. At that time, the record evidence 

Defendants ascertained established that Plaintiff, testifying on behalf of the entire collective, stated 

he was not aware until his deposition that an employer could lawfully do whatever it wanted with 

a service charge. That record evidence also confirmed that Plaintiff was always paid above the 

Florida minimum wage and received all tips to which he was entitled. However, Counsel has now 

disclosed his confidential and privileged attorney-client conversations with Plaintiff and asserted 

that he discussed the differences between service charges and tips with Plaintiff and Plaintiff 

conveyed to him that he was owed “tips.” As a result of Counsel’s summaries of the privileged 

conversations he disclosed, Defendants withdraw their request for sanctions based on Plaintiff's 

sworn testimony regarding service charges and receiving all his tips. 

RELEVANT FACTUAL AND PROCEDURAL HISTORY 

1. Counsel alleged in the First Amended Complaint that Plaintiff was paid “an hourly 

rate of pay, supplemented by a non-discretionary service charge and by gratuities left at the 

discretion of Defendants’ patrons.” [ECF No. 40 at ¶ 30]. However, Counsel did not allege that 

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Plaintiff was paid a total hourly wage that was less that the applicable Florida minimum wage. 

Accordingly, Defendants filed their Motions to Dismiss the First Amended Complaint, arguing in 

part, that Plaintiff failed to allege he earned less than the Florida minimum wage and/or paid a tip 

credit wage. [ECF Nos. 55 at p. 9; 56]. 

2. Counsel did not oppose Defendants’ Motions to Dismiss and elected to file a 

Second Amended Complaint. Counsel tried to circumvent the requirements of the FMWA by 

claiming in the Second Amended Complaint that Plaintiff was paid “a direct hourly rate of pay 

that was less than the applicable Florida or federal minimum wage, supplemented by a portion of 

a non-discretionary service charge Defendants received, and further supplemented by [a] portion 

of the gratuities left at the discretion of Defendants’ patrons.” [ECF No. 59 at ¶ 28]. 

3. Defendants moved to Dismiss the Second Amended Complaint arguing, in part, 

that Plaintiff still did not allege he was paid a total hourly rate that was less than the Florida 

minimum wage when considering the service charge payments and/or paid on a tip credit basis to 

permit him to pursue an FMWA claim. [ECF Nos. 63 at p. 9; 69 at p. 6-8]. 

4. The Court granted Defendants’ Motion to Dismiss the Second Amended 

Complaint, in part, and dismissed Plaintiff’s FMWA claim without prejudice. Notably, the 

Honorable Judge Beth Bloom stated that the FMWA claim could only be maintained if Plaintiff 

was paid less than the applicable Florida minimum wage or was paid a tip credit wage. [See Trans. 

Of Motion Hearing Before the Honorable Beth Bloom United States District Court Judge dated 

March 29, 2023, attached hereto as Exhibit “A”]. Specifically, the Court stated the following: 

Court: Well, the FMWA requires that employers shall pay employees wages no less than 

the minimum wage for all hours worked. So what allegation would support the 

cause of action? 

And then 448.110 States that: “For tipped employees meeting eligibility 

requirements for the tip credit under the FLSA, employers may credit towards 

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satisfaction of the minimum wage tips up to the amount of the allowable FLSA tip 

credit.” 

So once again, where would the Court find the allegation that Mr. Collado was paid 

less than the minimum wage to sustain a cause of action with regard to Count 2? 

. . . 

 

Court: Then perhaps we should look at the law. You cited the Biller case. And it appears 

to the Court – and I think that Defendants’ argument has merit in its reply – that, in 

that case, it’s only when the employer is taking a tip credit to reach the minimum 

wage. And it’s unclear whether Mr. Collado was paid on a tip credit basis because 

there is a failure to allege that the direct hourly rate paid, plus the percentage of the 

amount he received [from the service charge], was below the minimum wage. 

So tell me how the law supports the claim as alleged. And I think, quite frankly, it 

requires that Mr. Collado allege that he is being paid less than the minimum 

wage. And I am failing to see how you can actually get around that requirement. 

[Id. at 15:1-11; 17:4-17] (emphasis added). 

5. On April 7, 2023, Counsel filed the Third Amended Complaint. [ECF No. 122]. 

Counsel failed to allege in the Third Amended Complaint what he knew to be true - and what he 

previously alleged, that Plaintiff was paid a direct wage that was supplemented by a portion of the 

service charge. Instead, Counsel alleged under the FMWA claim that Plaintiff was paid a “‘tip 

credit’ wage” and that Kiki “paid Plaintiff . . . a direct hourly wage below the direct minimum 

hourly wage required by the FMWA.” [ECF No. 122 at pp. 18-20, 23-24]. 

6. Contrary to Counsel’s claims, the omission that Plaintiff was also paid a service 

charge was a material exclusion. It was a material omission because it allowed Counsel to instead 

falsely allege that Plaintiff was paid a “‘tip credit’ wage” and “below the direct minimum hourly 

wage required by the FMWA” to get around Judge Bloom’s prior order. Specifically, Counsel lied 

in the Third Amended Complaint to get around Judge Bloom’s basis for the dismissal pertaining 

to the FMWA claim in the Second Amended Complaint. 

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MEMORANDUM OF LAW 

I. Defendants’ Motion for Sanctions is Timely 

A district court has the authority and power to sanction an attorney even after the attorney 

withdraws from the case. See Peer v. Lewis, 606 F.3d 1306, 1316-17 (11th Cir. 2010); see also, 

Jallali v. USA Funds, 578 Fed. Appx. 965, 965-66 (11th Cir. 2014). As Counsel recognizes in the 

Response, the Eleventh Circuit explained in Peer that sanctions pursuant to the Court’s inherent 

power could be awarded after the attorney withdrew from the case, and it remanded the issue to 

the district court for further review. 606 F.3d 1306, at 1316-17. Similarly, the Eleventh Circuit has 

confirmed that under Section 1927, a district court may sanction an attorney regardless of whether 

the attorney in the case withdrew before the sanctions were awarded. See Jallali v. USA Funds, 

578 Fed. Appx. at 965-66 (stating Section 1927 “plainly applies to ‘any attorney . . . admitted to 

conduct cases and is not limited to the current attorney of record at the time a sanction is made.’”). 

Moreover, Counsel incorrectly suggests that Defendants could have filed a Rule 11 motion 

for sanctions or motion for summary judgment prior to receiving Plaintiff’s sworn interrogatory 

answers on December 8, 2023, and taking his deposition on December 12, 2023. Prior to then, the 

allegations in the Third Amended Complaint, and Plaintiff’s Statement of Claim and declaration, 

which were prepared by Counsel, disputed Kiki’s “time, pay, tip, and payroll records.” Those 

factual disputes would defeat a Rule 11 motion and motion for summary judgment. As a result, 

Defendants had to establish that the allegations contained in the Third Amended Complaint, and 

Plaintiff’s Statement of Claim and declaration, were false prior to moving for sanctions or 

summary judgment. In fact, Defendants served Counsel with a Rule 11 motion on December 20, 

2023, only eight days after the deposition, which was not filed because he withdrew from the case. 

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II. Counsel Multiplied Proceedings by His Bad Faith Pursuit of the FMWA Claim 

in the Third Amended Complaint based on Knowingly False Allegations 

Counsel did not purse the FMWA claim in the Third Amended Complaint based on a 

“novel legal theory.” He pursued the FMWA claim in the Third Amended Complaint based on a 

frequently alleged minimum wage violation premised on knowingly false allegations that Plaintiff 

was paid a “‘tip credit’ wage” and that Kiki “paid Plaintiff . . . a direct hourly wage below the 

direct minimum hourly wage required by the FMWA.” Significantly, Counsel now admits that 

Plaintiff was always paid above the Florida minimum wage. [See ECF No. 250 at p. 2]. 

As discussed above, Counsel alleged in the First and Second Amended Complaint that 

Plaintiff was paid (1) a direct hourly wage, (2) a portion of the mandatory service charge that Kiki 

applied to every patron’s bill, and (3) discretionary tips left by customers. [ECF No. 40 at ¶ 30; 

ECF No. 59 at ¶ 28]. Similarly, Counsel submitted a signed and sworn declaration from Plaintiff 

confirming that Plaintiff was paid a directly hourly wage that was supplemented by the mandatory 

service charge. [ECF No. 44-1]. 

Defendants’ filed Motions to Dismiss the First and Second Amended Complaint arguing, 

in relevant part, that they did not establish a claim under the FMWA because they failed to allege 

that Plaintiff was (1) paid a total hourly wage, including the service charge, that was less than the 

Florida minimum wage and/or (2) that he was paid a tip credit wage and was not given all the tips 

he earned to meet the Florida minimum wage. [ECF Nos. 55 and 63]. Judge Bloom held a hearing 

on Defendants’ Motion to Dismiss the Second Amended Complaint on March 29, 2023. At the 

hearing, the Court explained to Counsel that under the applicable law as reflected in Biller v. Café 

Luna of Naples, Inc., No.2:14cv659, 2017 U.S. Dist. LEXIS 234991, at *11-12 (M.D. Fla. Feb. 7, 

2017), tips are only factored into an employee’s wages when the employer takes a tip credit, and 

the Second Amended Complaint failed to allege that (1) Defendants took a tip credit or (2) Plaintiff 

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was paid less than minimum wage. [See Hearing Trans., Ex. A. at 15:1-11; 17:4-17]. 

To circumvent the Court’s basis for dismissal of the FMWA claim in the Second Amended 

Complaint, Counsel amended the Third Amended Complaint in bad faith by omitting all references 

to the service charge payments and claiming for the first time in a pleading that Plaintiff was paid 

only a “‘tip credit’ wage” and below the Florida minimum wage. Counsel’s decision to exclude 

the service charge payments and knowingly include false allegations in his signed pleading was a 

calculated and intentional act to mislead the Court and overcome the basis for the dismissal of the 

FMWA claim in the Second Amended Complaint. 1 Therefore, sanctions are proper under Section 

1927 and/or this Court’s inherent power.2 

III. Counsel’s Other Misrepresentations Contained in the Response 

Counsel claimed in the Response that this Court should deny Defendants’ Motion for 

Sanctions on the false premise that “it denied their prior request to sanction [Counsel] under Rule 

11.” [ECF No. 250 at p. 3]. Defendants did not file a Rule 11 Motion for Sanctions against Counsel. 

Moreover, Counsel also falsely claimed that Defendants “admitted to liability” through their 

interrogatory answers. [ECF No. 25 at ¶ 30, p.18]. In Interrogatory No. 4, Plaintiff asked 

1

 Counsel’s implication that Defendants are not entitled to sanctions against him because of the 

technical misstep of filing a motion to strike before the Motion to Dismiss the Third Amended 

Complaint is a red herring and absurd. A technical misstep does not change the fact that Counsel 

previously made false allegations in the Third Amended Complaint and cannot excuse his bad faith 

behavior. Further, the case cited by Counsel to “support’ his claim is distinguishable. In Caiazza 

v. Marceno, the defendant did not move for summary judgment on an issue and allowed it to 

proceed to trial. Here, discovery was still ongoing, and Defendants intended to move for summary 

judgment, but Counsel withdrew from the case and the matter is now dismissed. [ECF No. 252]. 

2

 Counsel claims incorrectly that sanctions for filing the Third Amended Complaint are not 

available under Section 1927. [ECF No. 250 at p. 20]. Courts have held that sanctions may be 

awarded under Section 1927 when the plaintiff files amended complaints to multiply litigation. 

See Squitier v. Nocco, No. 8:19-cv-0906, 2022 U.S. Dist. LEXIS 71183, *15-18 (M.D. Fla. April 

18, 2022). Here, Counsel filed the Third Amended Complaint to vexatiously multiply the litigation 

by falsely maintaining a non-existent FMWA claim. 

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Defendants to “Describe all facts that support any defense that Plaintiff’s claims for 

unpaid/underpaid tips and/or overtips are barred, overstated, and/or unrecoverable.” Kiki answered 

as follows: 

Kiki distributed all tips that were processed by the restaurant from credit card 

transactions to its tipped employees in accordance with all applicable laws and 

its tip payment policies. Any variance that may exists between the tips the 

restaurant processed from credit card transactions and the distribution of those tips 

to tipped employees, have related explanations and where an explanation is not 

apparent, the variance was inadvertent and would have been corrected had it come 

to the restaurant’s attention. Kiki is unaware of a single instance when any of the 

Plaintiffs complained that they did not receive all their tips. Kiki never handles cash 

tips. Cash tips are accepted by the Captains and distributed as they see fit without 

oversight or interference by Kiki. 

In Interrogatory No. 19, Plaintiff asked Defendants to “state whether Kiki failed to 

distribute tips/overtips it received, and if so, state all the reasons why Kiki failed to do so, the 

amount it believed it failed to distribute each week, the weeks at issue, the amount of money that 

should have been distributed, and to whom.” Kiki responded as follows: 

Subject to the above objections and limited to a three (3) year period, Defendant 

did not intentionally fail to distribute any tips it processed. Any variance that may 

exists between the tips the restaurant processed from credit card transactions and 

the distribution of those tips to tipped employees, have related explanations and 

where an explanation is not apparent, the variance was inadvertent and would have 

been corrected had it come to the restaurant’s attention. Kiki is unaware of a single 

instance when any of the Plaintiffs complained that they did not receive their tips. 

It is clear from Kiki’s answers to Interrogatories 4 and 19, that Defendants did not admit they 

unlawfully distributed tips. Thus, Counsel’s claim that Defendants “admitted to liability” is false. 

IV. Defendants Withdraw Their Request for Sanctions Based on Counsel’s 

Failure to Ascertain that Plaintiff Received all His Tips and that Plaintiff did 

not Know the Difference Between Service Charges and Tips 

When Defendants filed their Motion for Sanctions, the sworn record evidence Defendants 

ascertained established that Plaintiff received all his tips and that Counsel failed to explain to 

Plaintiff the difference between service charges and tips. Therefore, the Motion for Sanctions 

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pertaining to this issue was properly filed. Counsel has now disclosed in the Response, his 

attorney-client privileged communications with Plaintiff; during which Counsel claims that he 

discussed the differences between service charges and tips with Plaintiff and that Plaintiff told him 

he was owed “tips.” [ECF No. 250 at ¶¶ 6, 59]. Defendants did not know about those privileged 

communications when the motion for sanctions was filed. Also, Defendants were not privy to 

them, so they cannot be disputed. Thus, this basis for sanctions is withdrawn. 

Counsel’s suggestion that Defendants should have known Plaintiff understood the legal 

distinction between service charges and tips has no merit. While Counsel identifies a declaration 

Plaintiff signed, that and the other declarations merely state that Defendants included an automatic 

service charge to patrons’ bills and that patrons were permitted to leave a discretionary tip above 

the service charge. [ECF No. 44-1 at ¶¶ 7-8, 44-2 at ¶¶ 7-8]. Critically, the declarations do not

confirm that Plaintiff or any Opt-in Plaintiffs were told about and understood the differences 

between service charges and tips. Moreover, Defendants were entitled to depose Plaintiff on the 

veracity of the allegations in the Third Amended Complaint and his declaration. For all Defendants 

knew, Plaintiff was given documents that were never explained or read, and he just signed them. 

WHEREFORE, Defendants respectfully request that this Honorable Court grant 

Defendants’ Motion for Sanctions pursuant to Section 1927 and/or its inherent powers as it relates 

to the frivolous FMWA claim contained in the Third Amended Complaint that was filed in bad 

faith, and award Defendants’ their reasonable attorneys’ fees and costs incurred in having to defend 

against that claim3 and award any other and further relief as the Court deems just and proper. 

3

 Pursuant to Local Rule 7.3, Defendants will confer with Plaintiff’s Counsel regarding the amount 

of attorneys’ fees and costs to be awarded upon the granting of Defendants’ Motion for Sanctions 

under Section 1927 and/or the Court’s inherent power. If an agreement cannot be reached, 

Defendants will file a motion to determine the amount of attorneys’ fees and costs to be awarded. 

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Dated: February 16, 2024 

Respectfully submitted, 

JACKSON LEWIS P.C. Levine & Partners, P.A. 

One Biscayne Tower, Suite 3500 3350 Mary Street 

Two South Biscayne Boulevard Miami, Florida 33133 

Miami, Florida 33131 Telephone: (305) 372-1352 

Telephone: (305) 577-7600 

/s/ Reynaldo Velazquez /s/ Allan Reiss 

Reynaldo Velazquez, Esq. Allan Reiss, Esq 

Florida Bar No.: 069779 Florida Bar No. 858500 

Email: rey.velazquez@jacksonlewis.com Email: asr@levinelawfirm.com

Roman Sarangoulis, Esq. 

Florida Bar No. 1011944 Counsel for RJ River, LLC 

Email: roman.sarangoulis@jacksonlewis.com

Counsel for 450 North River Drive, LLC, 

d/b/a Kiki on the River and Roman Jones 

CERTIFICATE OF SERVICE 

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

February 16, 2024, 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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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 

Facsimile: 305-373-4466 

Counsel for 450 North River Drive, LLC, 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 

Facsimile: (305) 372-1352 

Attorneys for RJ River, LLC 

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