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. 

_______________________________________/

DEFENDANTS 450 NORTH RIVER DRIVE, LLC, 

D/B/A KIKI ON THE RIVER, AND ROMAN JONES’ UNOPPOSED MOTION 

FOR LEAVE FOR THEIR INSURANCE ADJUSTER TO APPEAR 

TELEPHONICALLY AT THE SETTLEMENT CONFERENCE 

Defendants, 450 North River Drive, LLC, d/b/a Kiki on the River and Roman Jones 

(collectively “Defendants”), by and through their undersigned counsel, hereby file their unopposed 

motion for leave for their insurance adjuster to appear telephonically at the settlement conference. 

Defendants state the following in support thereof: 

GROUNDS 

1. On February 13, 2023, the Court entered its Order Scheduling Settlement 

Conference. [E.C.F. No. 81]. The Order specifically states that the Settlement Conference “will be 

conducted in person[,]” and required that a “party representative will full and final authority to 

make and accept offers of settlement attend.” Id. (emphasis added). 

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

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2. Defendants respectfully request that the Court allow their insurance adjuster to 

appear telephonically at the Settlement Conference as the undersigned counsel, Reynaldo 

Velazquez, inadvertently failed to communicate with the insurance adjuster about the settlement 

conference and she is unable to attend in person because she is located New York, NY. 

3. Undersigned counsel acted immediately upon realizing his oversight today. 

Undersigned counsel apologizes to opposing counsel, plaintiffs, the Court, and Magistrate Judge 

Otazo-Reyes. Twenty-seven years of practicing law and this has never happened to undersigned 

counsel. Nevertheless, that is not an excuse and undersigned counsel reiterates his apology to all 

involved. 

4. Defendants’ counsel, Reynaldo Velazquez, Esq., and Roman Sarangoulis, Esq., 

will be attending the Settlement Conference in person along with their clients. 

5. The undersigned certifies that he has conferred with Plaintiff’s counsel, Brian H. 

Pollack, Esq., on February 28, 2023, regarding the relief sought through this Motion. Mr. Pollack 

represented that Plaintiff does not oppose the telephonic appearance of Defendants’ insurance 

adjuster at the Settlement Conference. 

6. The undersigned certifies that this Motion is not made to delay these proceedings 

and that it is in the interest of justice to grant the requested relief. 

CERTIFICATE OF CONFERRAL PURSUANT TO LOCAL RULE 3.01(g) 

Pursuant to Local Rule 3.01(g) counsel for Defendants, Defendants, 450 North River 

Drive, LLC, d/b/a Kiki on the River and Roman Jones, have conferred with counsel for Plaintiff, 

Brian H. Pollock, Esq., regarding this Motion, and he does not object to the relief requested herein. 

WHEREFORE, Defendants respectfully requests that the Court issue an Order granting 

leave for their insurance adjuster to appear telephonically at the settlement conference. 

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

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Dated: February 28, 2023 

Respectfully submitted, 

JACKSON LEWIS P.C. 

One Biscayne Tower, Suite 3500 

Two South Biscayne Boulevard 

Miami, Florida 33131 

Telephone: (305) 577-7600 

/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 

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 28, 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. 

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

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

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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

Telephone: 305-577-7600 

Facsimile: 305-373-4466 

Counsel for 450 North River Drive, LLC, Kiki on 

the River and Roman Jones

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