EXHIBIT “A” 

EXHIBIT “A”

Case 1:22-cv-23074-BB Document 163-1 Entered on FLSD Docket 07/17/2023 Page 1 of 6
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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.

_____________________________________ /

COURT NOTICE

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.

KIKI ON THE RIVER AND THE OTHER DEFENDANTS IN THIS CASE 

ASSERT THAT THEY DISTRIBUTED TIPS APPROPRIATELY AND ACTED 

LAWFULLY.

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-thehouse 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 

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/OTAZOREYES.

Case 1:22-cv-23074-BB Document 163-1 Entered on FLSD Docket 07/17/2023 Page 2 of 6
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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 against Kiki on the River 

and assert 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 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. 

If you join this lawsuit against Kiki on the 

River, you may be required to answer written 

questions under oath, be deposed, and/or 

testify at trial.

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, who 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 you receiving this notification, considering 

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

Case 1:22-cv-23074-BB Document 163-1 Entered on FLSD Docket 07/17/2023 Page 3 of 6
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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 

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 _______ ___, 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

Fax: (305) 230-4844 

brian@fairlawattorney.com

www.fairlawattorney.com

4885-4526-5521, v. 1

Case 1:22-cv-23074-BB Document 163-1 Entered on FLSD Docket 07/17/2023 Page 4 of 6
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.

_____________________________________ /

COURT 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.

KIKI ON THE RIVER AND THE OTHER DEFENDANTS IN THIS CASE ASSERT THAT 

THEY DISTRIBUTED TIPS APPROPRIATELY AND ACTED LAWFULLY.

This notice is a reminder that to join this lawsuit against Kiki on the River and the 

other Defendants, you must complete the “Consent to Join Pursuant to 29 U.S.C. § 

216(b)” form and mail, fax, or email it to the FairLaw Firm 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

Fax: (305) 230-4844

brian@fairlawattorney.com

www.fairlawattorney.com

Case 1:22-cv-23074-BB Document 163-1 Entered on FLSD Docket 07/17/2023 Page 5 of 6
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 against Kiki on the River 

and the other Defendants for the tips I allege I’m owed.

4. I agree to participate in the discovery process and timely answer written discovery 

requests and make myself available for deposition at a time and place that is convenient for all 

parties and to appear as a witness at trial if called.

5. 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.

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

Dated ______________, 2023. Signed:_________________________

Printed Name:____________________

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

Address: _________________________________ Tel No.:___________________________

_________________________________ Email: ____________________________

MAIL, EMAIL, 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 FAX 305.230.4844

4859-6871-7681, v. 1

Case 1:22-cv-23074-BB Document 163-1 Entered on FLSD Docket 07/17/2023 Page 6 of 6