EXHIBIT B 

Case 1:22-cv-23074-BB Document 243-2 Entered on FLSD Docket 01/12/2024 Page 1 of 56
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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO. 22-CV-23074-BB 

OCTAVIO COLLADO, et al., 

 Miami, Florida 

 Plaintiff(s), 

 November 27, 2023 

 vs. 

450 NORTH RIVER DRIVE, LLC, 

et al., 

 

 Defendant(s). Pages 1 - 46 

----------------------------------------------------------- 

DISCOVERY HEARING 

TRANSCRIBED FROM DIGITAL AUDIO RECORDING 

BEFORE THE HONORABLE ALICIA M. OTAZO-REYES 

UNITED STATES MAGISTRATE JUDGE 

APPEARANCES: 

FOR THE PLAINTIFF(S): BRIAN H. POLLOCK, ESQ. 

 FAIRLAW FIRM 

 135 San Lorenzo Avenue 

 Coral Gables, FL 33146 

 305-230-4884 

 brian@fairlawattorney.com 

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Case 1:22-cv-23074-BB Document 243-2 Entered on FLSD Docket 01/12/2024 Page 2 of 56
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APPEARANCES (CONT'D) 

FOR THE DEFENDANT(S): REYNALDO VELAZQUEZ, ESQ. 

450 N River Drive JACKSON LEWIS, P.C. 

 2 South Biscayne Boulevard 

 Miami, FL 33131 

 305-577-7600 

 rey.velazquez@jacksonlewis.com 

 

FOR THE DEFENDANT(S): ALLAN S. REISS, ESQ. 

RJ River, LLC LEVINE & PARTNERS 

 3350 Mary Street 

 Miami, FL 33133 

 305-372-1350 

 asr@levinelawfirm.com 

 

 

TRANSCRIBED BY: Joanne Mancari, RPR, CRR, CSR 

 Court Reporter 

 jemancari@gmail.com 

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Case 1:22-cv-23074-BB Document 243-2 Entered on FLSD Docket 01/12/2024 Page 3 of 56
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Thereupon, 

the following proceedings were held: 

THE DEPUTY CLERK: Octavio Collado v. 450 North River

Drive, LLC, et al., case No. 22 23074, Civil, Bloom.

Counsel, please state your appearances for the record.

MR. POLLOCK: Good morning. Brian Pollock for the

plaintiff and The Collective.

MR. VELAZQUEZ: Good morning, your Honor. Reynaldo

Velazquez on behalf of 450 North River Drive, doing business as

Kiki on the River, and Roman Jones.

MR. REISS: Good morning, your Honor. Allan Reiss,

Levine & Partners, for defendant RJ River, LLC.

I apologize to the court. I forgot my jacket this

morning.

THE COURT: All right. Well, you do have a beautiful

background.

MR. REISS: I was trying to make up for the absence of

a jacket, Judge. Thank you for noticing.

THE COURT: All right. So I have the Notice of

Discovery Hearing.

The first question is how many plaintiffs in The

Collective may defendants depose.

I don't know if you-all have had discussions. Are you

fighting over a number? Can you give me a little bit of

background on that.

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MR. VELAZQUEZ: Yes, your Honor. So right now the

issue relates to the amount of opt-in plaintiffs to be deposed.

The defense has proposed two per position, which equals 13

depositions, and, of course, the main plaintiff, for a total of

14 depositions.

THE COURT: OK. What is the plaintiffs' position?

MR. POLLOCK: Your Honor, I think under the rules they

provide for ten depositions. So we'd like to stick with the

ten. If we are going to go beyond that, I'd like a limit on

the hours that each deponent would be subject to deposition. I

think that is kind of how these are done. The plaintiff is

deposed, pursuant to the rules, for seven hours, and then if

there are going to be opt-ins that are deposed, there is a

shorter period of time, so that way you can get multiple done

in a day.

THE COURT: OK. You said two per position. What are

the positions?

Mr. Velazquez.

MR. VELAZQUEZ: My apology, your Honor. I thought you

were asking the plaintiff.

It's captains, waiters, bartenders, bussers, barbacks,

the dock master, and I believe it is the wine host or host

classification. So it is a total of seven classifications,

your Honor, but the reason there's 13 depositions is because

the dock master only has one person in the position. So that

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is why there's 13.

THE COURT: OK.

MR. VELAZQUEZ: For the record, your Honor, we have

scheduled the 13 opt-in depositions not for entire-day

depositions. They were scheduled for, spread out over four

days, if I remember correctly, three per day, for approximately

two hours. So that issue is not an issue from the defense

perspective, as reflected in the notice of depositions that we

served, as it relates to the opt-in plaintiffs, the 13.

THE COURT: OK. All right. So it seems like a

reasonable plan, two per position. Sort of like a belt and

suspenders kind of thing. You want two people per, and in one

position you only have one person. So I think it is a

reasonable accommodation.

You are saying two hours maximum per person?

MR. VELAZQUEZ: I am going to reach for my phone, your

Honor, just so I can check my calendar to make sure that is the

way -- I don't know if we scheduled it for two or

two-and-a-half hours, but let me just check real quick so I can

give you a precise time on that.

(Pause) 

MR. VELAZQUEZ: Yes. So it looks like they have been

scheduled between, I guess depending on the significance,

anywhere, from what I can tell here, anywhere between two hours

to three-and-a-half hours is what we have scheduled the

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depositions for, depending on the particular opt-in plaintiff

that we are deposing.

THE COURT: OK. So who merits three-and-a-half hours?

The dock master? I'm trying to figure out your justification

for going above two hours for anyone.

MR. VELAZQUEZ: I'm looking at the notice. One

second, your Honor. Let me see.

Unfortunately, the notices that I'm looking at do not

have them divided by classification.

THE COURT: Well, can you tell -- maybe Mr. Pollock

can assist -- for the people who -- I think two hours across

the board is reasonable. So I'm trying to figure out on the

three-and-a-half what the justification is. So maybe

Mr. Pollock can assist and tell us the positions of those

individuals.

MR. POLLOCK: I'd have to find the notices, Judge, to

be honest.

THE COURT: OK. That's fine. Take your time.

(Pause)

MR. VELAZQUEZ: I apologize, your Honor. The duration

of the opt-in plaintiffs' depo was not an issue that was raised

in our prior conferrals. So I don't have that noted in my

outline.

THE COURT: OK.

MR. VELAZQUEZ: If the court is amenable to this,

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we're willing to kind of like meet in the middle, maybe

two-and-a-half hours, and the ones that we thought would take a

little longer, bring it within two-and-a-half hours, and keep

everybody at two and a half across the board.

THE COURT: OK. That sounds reasonable.

Mr. Pollock, can you live with that?

MR. POLLOCK: Absolutely, Judge.

THE COURT: All right. All right. So then do it that

way.

MR. VELAZQUEZ: Thank you, your Honor.

THE COURT: All right. So then that is item 1.

Then when you say representative deposition testimony

binding on all members, obviously the main plaintiff is a

representative. Are you saying that these people you are going

to be deposing you are going to deem to be representatives

also, Mr. Velazquez?

MR. VELAZQUEZ: Yes, your Honor. If you recall, in

our prior hearing you actually ruled on this issue as it

related to the interrogatories.

THE COURT: Right.

MR. VELAZQUEZ: You ruled that the plaintiffs, opt-in

plaintiffs that were answering in a representative capacity

would bind the whole.

We're asking for that same ruling here for purposes of

the deposition, because if not, your Honor, it puts the defense

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in a position where we're subject to being sandbagged.

Somebody else can be called, they can testify differently, and

we would not have had an opportunity to depose them, your

Honor.

THE COURT: Now, are the people you're deposing the

ones who answered written interrogatories and requests for

production as representatives or are they a different crowd?

MR. VELAZQUEZ: So that is one of the issues that is

before the court and we were unable to reach an agreement on

that. Although I would like to confer with my cocounsel, I

don't believe we're necessarily averse to a situation where the

individuals that are answering or that are being deposed would

also be the individuals that answer the interrogatories from a

class perspective. If that is the question the court --

THE COURT: That would seem to make sense.

MR. VELAZQUEZ: That makes sense to me, your Honor,

and we don't have a problem with that.

Allan, are you OK with that?

MR. REISS: Yes, sir. That's fine.

THE COURT: How were the people who answered the

written discovery selected? Was it selected by Mr. Pollock?

MR. VELAZQUEZ: Your Honor, we proposed initially four

depositions per classification; two witnesses selected by

Mr. Pollock and two witnesses selected by the defense.

Mr. Pollock did not confer on that issue. As the

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discovery deadline is rapidly approaching, we went ahead and

selected our two people, and that is how the two were selected

for each classification that we're deposing.

THE COURT: All right. But what is the relationship

between those people and the ones who answered written

discovery on a representative basis, or are you saying they

haven't done it yet?

MR. VELAZQUEZ: They have not done that, your Honor.

THE COURT: OK.

MR. VELAZQUEZ: We have not received any discovery

from the plaintiffs.

THE COURT: OK. OK. All right. All right. So

basically it seems to me that whoever -- it has to be the same

people who are representatives for both purposes. It wouldn't

make sense to have different representatives.

So as it stands, these 13 people would be the

representatives for deposition, so they would need to be the

ones who answer representative written discovery.

Does that make sense to you, Mr. Pollock?

MR. POLLOCK: To an extent, your Honor. We don't have

a problem with the people who respond to the interrogatories

being the people that are deposed, but I think the issue comes

up, what does it mean to be representative or to bind the

class, which I think is what the question is. Does the

testimony bind all members of the class.

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Here we have certain interrogatories that are binding,

not wholesale interrogatories. So what my concern relates to

is that we've got questions that go across the board and not

just for the limited issues that the court indicated were going

to be representative. I think it was like 2, 3 and 4.

THE COURT: Right.

MR. POLLOCK: So on certain topics I don't have a

problem because that makes sense because it is consistent, but

on a wholesale basis I don't believe that that would be

appropriate.

THE COURT: All right. So basically you want to

follow the same pattern as for the written discovery where I

said interrogatories 2, 3 and 4 -- I don't have in front of me

what those were about, but you're saying limit the portion of

the depositions that pertain to those interrogatories as

representative and anything else non-representative?

MR. POLLOCK: Correct.

THE COURT: I mean, that would be kind of a waste of

time. They are going to ask them name, rank, and serial

number. That is obviously individual.

So let me hear from Mr. Velazquez. How do

interrogatories 2, 3 and 4 relate to the scope of the

depositions you're contemplating?

MR. VELAZQUEZ: So, your Honor, the depositions

obviously are going to go broader an inquiry than the

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representative discovery that the court has ordered as it

relates to 2, 3 and 4. Our position is that --

THE COURT: Can you tell me what 2, 3 and 4 are

because I don't have it in front of me.

MR. VELAZQUEZ: Most certainly, your Honor.

So interrogatory No. 2 states as follows: "Identify

by name and position each and every person constituting a

traditionally non-tipped employee, as described in paragraph 55

of the third amended complaint, that you allege received tips

and/or overtips and state how you know they received the tips

and/or overtips as well as the facts supporting your belief

that the persons identified received tips and/or overtips."

That is question No. 2.

MR. POLLOCK: That is question 3.

MR. VELAZQUEZ: No, that is question No. 2.

MR. POLLOCK: Not on the page that I've got.

MR. VELAZQUEZ: You might be looking at the old ones.

The ones that I'm looking at are the revised one where we sent

you five substantive and one for the ID at the beginning.

If you recall, we initially searched 25 and when you

complained about the amount, we reduced it down to five

substantive and the No. 1, asking for the name of the person

answering. No. 2 on those is the one that I just read.

MR. POLLOCK: OK.

MR. VELAZQUEZ: Would you like me to read No. 3 and

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No. 4, your Honor?

THE COURT: Are you in agreement as to what you just

read to me, that that's one of the interrogatories, I guess.

MR. POLLOCK: That is one of them, Judge. I'm just

trying to find the recent ones.

THE COURT: Find your bearings.

MR. POLLOCK: That's fine.

THE COURT: OK.

MR. POLLOCK: That's fine.

THE COURT: All right. Then the next one.

MR. VELAZQUEZ: Then No. 3, your Honor, states as

follows: "Please state each and every fact which you contend

supports your claim that defendants unlawfully retained tips

and/or overtips, e.g., identifying the workweek in which such

alleged unlawful tip retention occurred, who unlawfully

retained the tips and/or overtips, and the amount of tips

and/or overtips that were allegedly retained each such

workweek, etc., and identify each and every document you

believe supports that claim."

THE COURT: OK. And 4?

MR. POLLOCK: I'm still looking for the revised set.

Rey, do you know when they were sent over?

MR. VELAZQUEZ: I'm reaching for my phone for the same

reason, your Honor.

(Pause)

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MR. VELAZQUEZ: July 10th.

It looks like it was on or around that date, Brian.

That is when I sent you the email advising you that we were

reducing it from 25 to five. So I'm assuming it was on that

date or sometime shortly after that.

MR. POLLOCK: I'm trying to find it.

MR. VELAZQUEZ: Let me see if I can pull it up on my

end and I'll forward it to you.

(Pause)

MR. VELAZQUEZ: I'll forward it to you now. I just

found it.

MR. POLLOCK: OK.

MR. VELAZQUEZ: Give me one second.

Coming your way.

Would you like me to copy you on this communication?

THE COURT: No, that is OK, because you read them to

me.

MR. VELAZQUEZ: OK.

MR. REISS: Rey, that is your July 8 email, right?

MR. VELAZQUEZ: This is dated July 10th.

MR. POLLOCK: It is July 10th.

MR. REISS: OK.

MR. VELAZQUEZ: It actually has the attachments.

I'm copying you as well, Allan.

MR. REISS: I see it. That was while I was in trial,

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one of my trials. Yes.

MR. VELAZQUEZ: Your Honor, while Mr. Pollock looks at

the email, I just want to make sure, as it relates to the

two-and-a-half hour, that only relates to the opt-in

plaintiffs.

MR. POLLOCK: Yes.

MR. VELAZQUEZ: The named plaintiffs can have the full

seven hours.

THE COURT: Yes. Of course.

MR. VELAZQUEZ: Thank you.

Also, your Honor, back to the two depositions per

position, there were three issues there. Well, you know what,

I'm jumping ahead. We will get to those. My apologies.

I consolidated 5 and 6 with No. 1 in my outline. That

is why I'm jumping ahead. So I will just await until we get

there.

THE COURT: All right. So you've told me identify the

people. Then you said the facts supporting the claim that they

kept it in, tips, and then what else?

MR. VELAZQUEZ: Then interrogatory No. 4 states as

follows, your Honor: "Please state each and every fact which

you contend supports your claim that defendants unlawfully

failed to distribute tips and/or overtips, e.g, identifying the

workweek in which such alleged failure to distribute tips

and/or overtips occurred, who unlawfully distributed the tips

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and/or overtips during that week, who unlawfully received the

tips and/or overtips during that week, and the amount of tips

and/or overtips that were allegedly unlawfully distributed each

such workweek, and identify each and every document you believe

supports that claim."

THE COURT: All right. So No. 2 is who. Then No. 3

is facts supporting keeping the tips. No. 4 is facts

supporting distribution of the tips.

Now what else do you want to go into at the

depositions?

MR. VELAZQUEZ: Your Honor, the natural course of a

deposition involves questions that grow from answers that are

proposed and that are asked. Those are the three main areas as

a result of the consolidation of the interrogatories from 25 to

five.

THE COURT: Right.

MR. VELAZQUEZ: It is very difficult for me right now,

given that I haven't started to prepare for those depositions

yet, to say where these questions are going to lead and where

the other questions that we would be asking as it relates to

the merits or lack thereof of this claim.

If we allow the representative discovery but then

afford the plaintiffs the opportunity to have other individuals

come and testify and say something that is different than what

has been already stated in deposition, again, it makes the

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defense and it puts the defense in a position where we are

litigating with one hand behind our back.

You can't use the representative discovery as a sword

and shield. You can't say you're limited to do that but now

what these opt-in plaintiffs say outside of these three areas

doesn't bind everybody else, because then it allows plaintiff

to go into the courtroom and use it as a sword and have the

luxury of knowing what was asked at deposition to prepare,

unbeknownst to the defense, a strategy as it relates to

countering that.

THE COURT: Well, I mean, the whole idea behind my

ruling back in September was to streamline and make things

efficient, and it made sense.

These three interrogatories are not peculiar. 21 in

particular. They pertain to the whole theory of the lawsuit,

and you are deposing people in the representative capacity, so

presumably you're looking for things that are common to the

entire lawsuit in those depositions.

I don't know why you-all can't seem to get that idea

as the one that is being implemented, and I'm not sure --

obviously, what you are saying kind of goes to the other

question of who is going to testify at trial and so on, but we

haven't gotten there yet.

Where we are at is, it seems to me that if you have

written discovery that you are going to use at the deposition

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to kind of like either enlarge or get more detail or things

like that, you don't need to go outside of that territory

because these are the matters that you deemed were of a

representative nature.

So I think that it makes sense to limit the

depositions, the scope of the depositions, to the

representative interrogatory subject matters. We will talk

about who can testify in a minute, but let's stick to the scope

of the depositions for the moment. This is what makes sense to

me, but you tell me.

MR. VELAZQUEZ: So, your Honor, if you recall, the

plaintiffs are also bringing a minimum wage claim.

THE COURT: Yes. I remember that one.

MR. VELAZQUEZ: Yes. It still brings humor to me too,

your Honor.

So those are questions that we are going to be asking

these individuals about also as it relates to --

THE COURT: Well, wouldn't those questions be more

pertinent from the named plaintiff? Those cover everybody.

I mean, I think the reason that you are sort of like

looking for these representatives is because the answers may be

different for captains or waiters or barbacks or bartenders;

otherwise, you would just ask everything of the named

plaintiff.

MR. VELAZQUEZ: Right. I see the struggle that the

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court is having, and I understand. I don't think the defense

fails to realize is that there might be some questions that we

are asking these opt-in plaintiffs that would necessarily be

something that only they could speak to as it relates to either

direct issues pertaining to that particular opt-in plaintiff or

the case in general.

THE COURT: Well, if you are deposing them in a

representative capacity, then they are speaking for all

captains and for all waiters and for all of those people. You

are not deposing them as to your own peculiar situation.

MR. VELAZQUEZ: I think we agree, your Honor, yes.

What the defense is looking for is for what these people say

that have been selected to testify in a deposition. What they

say represents what all the captains would say, represent what

all the barbacks would say, what all the servers would say.

I apologize. Maybe I wasn't connecting the dots as to

what you are telling me, but if that is what the court is

inclined, is saying it is inclined to rule, we agree, yes.

What they testify to in their deposition as it relates their

positions as captains, bussers, servers, whatever the case may

be, should bind the class to that testimony. I apologize, but

we agree with you.

THE COURT: Well, that was my rationale. I guess I

was not very artful in explaining it.

MR. VELAZQUEZ: Or I just failed to understand an

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artful explanation, which is very possible.

THE COURT: So let me hear from Mr. Pollock. How do

you envision this whole thing developing?

MR. POLLOCK: Well, your Honor, what Mr. Jones knows

may be different than what Mr. Smith knows or Mrs. Smith.

THE COURT: Well --

MR. POLLOCK: The normal course when you have a --

because we have a collective action which has been certified --

THE COURT: Right.

MR. POLLOCK: -- and we have got a putative class

action under Florida law, either under the Florida minimum wage

act or a breach of contract. The court has not yet ruled on

certifying those.

THE COURT: Right.

MR. POLLOCK: As it relates to the representative

testimony, what one person knows or conversations someone had

may or may not be representative of the conversations that

others have had. So that is the dilemma.

Because if Mr. Jones testifies that he never had any

conversations with one of the managers about tips, that doesn't

mean that none of the other captains who Mr. Jones represents

were in the same position in that they didn't have any

conversations with the manager about tips. So there are people

who may have had conversations or information. So to bind that

doesn't seem correct.

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I think the issue in this case, when we step back and

remember what the case is about, is about the distribution of

tips that was done pursuant to some amorphous formula, which we

haven't been provided. So the other issues come down to

whether Roman Jones as an individual defendant and the

liability of any of the defendants if a violation of the law

can be proven.

So individuals can have different conversations. They

can have different levels of knowledge. But as it relates to

the violation, I don't see how we get to this representative,

because when we look at the interrogatories, they talk about

facts that support each claim and an accounting of the claim

based on documents which we don't have. I mean, we can kind of

work through those, but I don't see how we get this

representative testimony binding people on issues because that

is going to depend on what the questions are, and then we are

making a pretrial ruling at this point that goes beyond

discovery. I don't see how we do that as it relates to a

deposition.

THE COURT: Well --

MR. VELAZQUEZ: Your Honor, if I may. Two times

Mr. Pollock mentioned documents that he does not have. That is

just an inaccurate representation of the facts, your Honor.

We have produced tens of thousands of documents in

this case. We have produced payroll records as it relates to

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each opt-in plaintiff. The only thing, to my understanding,

that is pending right now is one week out of four weeks that

Mr. Pollock requested information about as it relates to

close-out receipts, that we are in the process of finalizing.

Other than that, I don't know of a record that

Mr. Pollock has requested as it relates to the issues here

pertaining to tips, hours worked, minimum wage, that has not

been produced.

When I say tens of thousands, your Honor, I am talking

north of 50,000 documents. So the records are there for him to

review with his clients and prepare them for deposition.

As it relates to the assertion that what one person

may know the other person may not know, well, it is his

prerogative and his responsibility to find that out and to

afford us an opportunity to depose those individuals. He can't

say, oh, no, we have to have representative discovery and then

absorb all of that information and say, great, here's my trial

strategy; now I am going to bring all of these people that the

defense didn't have an opportunity to depose to say what they

know.

THE COURT: All right.

MR. POLLOCK: I think that gets us into the bigger

issue of representative testimony at trial. So if we are going

to utilize representative testimony at trial and not have each

individual person come in and testify as it relates to damages,

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then that is a different issue.

THE COURT: Well, let me just take a step back. So

far my ruling was limited to the written interrogatories, and

my recollection is that there was a complaint from plaintiffs

saying you can't make everybody answer, and we came up with

this scheme that would streamline and pare things down.

Now this whole representative deposition thing, that

is something that you-all came up on your own, but it doesn't

sound to me like this was thought through.

When you have a corporate representative, the

corporate representative binds the entity, and it is that

simple.

Here, I think the defense is sort of, and rightfully

so, looking to get a picture of what the plaintiffs' claims are

against the defendants because they can't go into trial without

knowing that. That's the whole purpose of discovery.

So we have that on the one hand. Then we have

plaintiff saying, well, these people are not true

representatives because I'm not going to educate them, I'm not

going to take the two captains and say, here's what every

captain did or found out so you can answer.

So it sounds to me like this whole representative

deposition thing is not really thought through, and maybe the

answer to this is to take the named plaintiff, educate him as

to every issue, make his testimony binding as to all

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plaintiffs, and then that way, number one, Mr. Pollock knows

what his duty list is -- educate the plaintiff on everything --

and maybe the way to do this practically is to treat the

plaintiff's deposition, the named plaintiff's deposition as a

corporate representative, and Mr. Velazquez can tell

Mr. Pollock, these are all the questions I want to ask of your

named plaintiff, and he can answer them.

This business of captain A heard this comment but

captain B didn't, so are you going to bind all captains to what

captain A says or to what captain B says, that doesn't make

sense to me.

I thought that there was some kind of agreement that

the interrogatory answers were really representative of the

whole story, but it is sounding to me like Mr. Pollock is not

really buying into that approach.

MR. POLLOCK: I think that that is fair because on a

corporate representative level, they provide binding testimony

on behalf of a corporation to the best -- based on their

knowledge.

THE COURT: There is a duty to prepare, right.

MR. POLLOCK: Correct. If multiple people are

responsive, then multiple people respond. But they may not

know of every conversation that happened within the corporate

fictitious entity, and so the corporation is not bound when

someone says I don't know.

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I mean, I guess this is the law school exam, but we're

trying to address this because at trial then we get into these

hearsay issues because Mr. Smith told me that he had a

conversation with. So there's that, as I'm kind of playing it

out.

THE COURT: Mr. Pollock, you know that defendants have

the right to know ahead of time what the trial witnesses are

going to say. So that ball cannot be hidden.

MR. POLLOCK: Agreed.

THE COURT: So that is how we need to come up with

some practical way of showing the ball.

MR. POLLOCK: No, I understand that. I think if they

want -- I think the other way to do it is have them take the

representative testimony but not let it be binding on the

others, and if there is someone whom we would like to present

at trial other than who has been deposed, we give them notice

and they have the opportunity to depose that person in advance

of trial.

THE COURT: That is sort of keeping the ball under

wraps and showing it later.

MR. VELAZQUEZ: Your Honor, this is a conversation

that we have had at prior hearings. This is the case that

Mr. Pollock has chosen to bring.

THE COURT: Yes.

MR. VELAZQUEZ: He needs to be prepared to prosecute

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his case accordingly.

If he doesn't have the personnel to prepare the two

captains for representative testimony, the two servers, the two

bussers, and on one and onward, the defense should not be

prejudiced because of that.

The work needs to be done. You can't bring this type

of a case and then say, gee, you know, that's too much work,

which it sounds like what is being said without actually saying

it.

THE COURT: Well, maybe it is that or maybe it is I

don't want to be bound before trial and I want to have a chance

if I find some juicy tidbit to bring it. It's sounds to me,

Mr. Pollock.

I don't think -- I mean, I am not going to endorse

this captain/waiters (inaudible) tailored approach. I believe

that -- again, you are masters of how you litigate. I'm not

litigating on your behalf.

I think your best approach is to get together.

Mr. Velazquez tells Mr. Pollock everything he wants to ask of

the named plaintiff. The named plaintiff deposition can exceed

the seven hours. We can maybe do it over two days. And

everything that Mr. Velazquez needs to know to prepare for

trial this named plaintiff will answer to, and that will bind

all the plaintiffs so there won't be any last-minute things.

Now the example that Mr. Pollock came up with, which

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is, well, like in a corporation rep depo, the corporate rep

says I don't know, if it is a legitimate thing or item, then

shame on the corporate representative's attorney who didn't

prepare them, and you can't just come up with that answer later

on. It has to be a fair playing field no matter how you look

at it.

So I will just say, with regard to item No. 1 and No.

2, and No. 3, I am not endorsing the sub-representative people.

If you can come up with a way of having the named plaintiff be

prepared for and deposed over two sessions, seven hours each, I

believe that is the way to go. That I am prepared to endorse,

with the duty of Mr. Pollock's side to prepare that named

plaintiff for all the topics, legitimate topics, of course, on

a list to be provided by Mr. Velazquez. I think that is how

you will get there in the fairest way.

MR. POLLOCK: OK. Thank you, your Honor.

MR. VELAZQUEZ: Well, your Honor, as it relates to

item No. 3, does that mean that then only the plaintiff

testifies at trial?

THE COURT: Well, that can be a motion in limine. You

can bring a motion in limine to Judge Bloom and say, if you go

that route, only the named plaintiff can testify at trial, and

then he can say, oh, but I have this other guy who wants to say

this. Then you say, but wait a minute, you didn't tell me

about that during discovery.

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So you can fight about that if he does have that

issue. I guess it would depend on whether he has something he

wants to bring to trial that he didn't tell you about before,

and under our rules that doesn't work.

I can't tell Judge Bloom who she can allow to testify

at trial or not. That's a motion in limine-type issue.

MR. VELAZQUEZ: That would deal with item No. 3, the

witnesses at trial being limited to the individuals that we

depose, and I hear you, what you are saying as that relates to

being a motion in limine.

THE COURT: Yes.

MR. VELAZQUEZ: As it relates to item No. 2 --

THE COURT: One and 2 I would say I am not going your

sub-representative's route and I am endorsing going with the

named plaintiff being the one who binds everybody, having two

sessions, seven hours each, and you giving Mr. Pollock a

heads-up on what matters you are going to cover so he can

prepare him so that he can bind everybody.

MR. VELAZQUEZ: Your Honor, in what you are proposing

here, we can still depose the opt-in plaintiffs that we are

moving forward with deposing at two-and-a-half hour intervals.

THE COURT: No, sir. I'm saying I'm abandoning that

plan because it doesn't seem to be workable. It seems a waste

of time. What do you care what so-and-so said if so-and-so

doesn't bind the rest of The Collective.

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MR. REISS: They're the one answering the discovery,

right? If I may, Judge.

THE COURT: Yes.

MR. REISS: You entered an order back in September.

We still don't have written discovery from the plaintiff.

THE COURT: Right.

MR. REISS: So I guess what I'm sort of coming up

against is we have a trial -- discovery cutoff discovery order.

THE COURT: I mean, is that one of your issues? I

heard something about the discovery was sent in July and there

is still no response. Is that an issue that you're asking me

to address?

MR. REISS: I think 5 and 6, they don't hit on the

exact date, but they do sit on the number of people that are

going to be responding to this stuff.

The issue is, Judge, that you entered an order, there

was an appeal, it was denied. I guess my only suggestion, if I

may speak on what we have been discussing today.

THE COURT: Yes.

MR. REISS: Judge, we have Mr. Collado set on the

12th. So, brass tacks, if Mr. Velazquez can get out a list or

the defendants jointly can get out a list of subject matters as

in any representative depo by the end of the week, I'd like to

know that we can move forward on the 12th given the February

cutoff. I would like to get the written discovery from

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Mr. Pollock that's been outstanding since July.

THE COURT: I mean, I'm wondering, Mr. Pollock, why

hasn't the written discovery that was the subject of my order

back in September been produced?

MR. POLLOCK: Your Honor, we received an order from

Judge Bloom denying the appeal just a couple of days ago.

THE COURT: So you were just sitting on it.

MR. POLLOCK: I mean, we have been working on it for

Mr. Collado, but as far as the remainder, we were waiting for

an order from Judge Bloom, which we just received. I can look

at the date of when that came in, but I want to say that it was

within the past couple of days.

So as with any order, once the appeal is final, the

order becomes final. So I can take a look, but I want to say

that the paperless order came in on Monday of last week. So

it's been like three working days since that order came in.

THE COURT: All right. But you said you were working

on it on the off-chance that Judge Bloom might think that I was

correct.

MR. POLLOCK: I was working on it with respect to

Mr. Collado, but we were waiting for the rest because I didn't

want to go ahead and unnecessarily expend time or effort on

other people, plus we don't have an agreement as to who those

other representative people are going to be, which was the

beginning of this hearing.

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So without a formula for determining who was going to

be representative, I couldn't go ahead and do that. That's the

other subject of this hearing, which is how we go ahead and who

the people are that are going to respond to it.

MR. VELAZQUEZ: Your Honor --

THE COURT: And you are facing a discovery deadline of

February when practically nothing has been done yet?

MR. VELAZQUEZ: Your Honor, if I may. Starting on

October 11th, we sent our first request to confer about

depositions and the requests for production. October 13th, we

followed up. October --

THE COURT: I'm sorry. It sounds like Mr. Pollock was

just sitting waiting to see if Judge Bloom would give him a

pass.

MR. VELAZQUEZ: That's correct, your Honor. In

numerous of the responses, even though the appeal as it relates

to your ruling had nothing to do with the issues that we were

trying to address, we've gotten no cooperation.

What Mr. Reiss is saying is a major problem for us.

THE COURT: I will agree.

MR. VELAZQUEZ: It is one of the themes that I was

going to address later in the outline, which is --

THE COURT: I'm no magician. I can rule, but I cannot

create time, and it sounds to me like you're bumping against

some very serious deadlines. I thought --

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MR. REISS: Judge, if I may, that is where I sort of

had a suggestion.

THE COURT: Yes.

MR. REISS: Judge, I mean, if Mr. Velazquez gets out a

list of subject matters by the end of the week --

THE COURT: Yes.

MR. REISS: -- we proceed with Mr. Collado. We get

the written discovery responses.

THE COURT: Yes.

MR. REISS: And Mr. Collado, we proceed with his depo

on the 12th, I think that gets us on track.

The other issue is, Judge, the people who are actually

answering this discovery, I don't think we -- respectfully, we

would request the opportunity to depose them whether they are

representative or not about the subject matter of the discovery

which you already ordered. It seems reasonable that we can ask

the people signing the documents why they said what they said.

THE COURT: All right.

MR. POLLOCK: I have been requesting, your Honor, the

depositions back since September. We can go ahead and do that

as well. I haven't received a date.

MR. VELAZQUEZ: Your Honor, that is inaccurate. I

sent an email providing in excess of 30 dates for depositions,

and those dates were for his depositions as well as my

depositions.

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THE COURT: All right. Well, here's what I'm going to

do because what I need to rule on is on the items that are on

the notice.

As to items 1 and 2, I will say that defendants may

depose the named plaintiff for two sessions of seven hours

each, and defendants are to provide a list of topics. I think

you were suggesting -- Mr. Reiss, what was the date you were

suggesting for the list of topics?

MR. REISS: I'm volunteering Mr. Velazquez to get it

out by the end of the week --

THE COURT: End of the week.

MR. REISS: I don't know if he can do that, though,

since we have Mr. Collado's depo.

THE COURT: Sunday, Monday.

MR. REISS: Yes. I know. I hate to speak for my

cocounsel.

MR. VELAZQUEZ: That is not a problem.

THE COURT: Right.

MR. VELAZQUEZ: We can get that out by the end of the

week.

THE COURT: By close of business Friday.

MR. VELAZQUEZ: Yes, your Honor.

THE COURT: You only have them set for one day, right?

MR. REISS: Right now, Judge, yes.

THE COURT: So you will need to find -- you will take

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him for one day, seven, and I will put in the order you will

have the spillover day on a date that you mutually agree. OK.

So he is for two days.

Then I am going to say that you can -- presumably it

will be one -- who will be answering these collective

interrogatories that my prior order required? Is it just one

person, two people? Is it still the named plaintiff? Who is

going to answer that?

MR. VELAZQUEZ: We were proposing, your Honor, the

named plaintiff and two per position.

THE COURT: All right. Let me hear from Mr. Pollock.

Two, 3 and 4, how many people will be answering that? In

addition to the named plaintiff, correct?

MR. VELAZQUEZ: Correct.

MR. POLLOCK: In addition to the named plaintiff --

THE COURT: And if the named plaintiff answers it, why

do we need other people to answer it also?

MR. POLLOCK: I kind of tend to agree with you.

THE COURT: I remember we went from everybody answers

it to narrowing it down, and I think it went one person may

answer on a representative basis. So that sounds like a

collaborative job.

So I don't know, honestly, that you need to have two

people answer each one of these. That would mean six

interrogatory answers. What do you gain by that?

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MR. VELAZQUEZ: So the plaintiffs that would be

answering the ones that we just discussed today, which I

believe was 2, 3 and 4 --

THE COURT: Yes.

MR. VELAZQUEZ: -- the court is suggesting it is one

plaintiff and their interrogatory answers bind the class.

THE COURT: Either that or the named plaintiff answers

2, 3 and 4 and binds the whole class with it. I don't know why

you need somebody else.

Like I said, we are sort of like -- we were looking at

it from big to small now and now we are at small already. So

why do we need to get big again?

MR. POLLOCK: That was kind of what we proposed

initially, was to have the named plaintiff respond because it

is going to be the same information, presumably, for the

others, so why parrot it.

THE COURT: Right, but then the named plaintiff is

going to bind everybody. That seems Mr. Velazquez's issue.

MR. POLLOCK: Correct.

MR. VELAZQUEZ: Allan, as it relates to 2, 3 and 4,

which is representative discovery --

THE COURT: Yes.

MR. VELAZQUEZ: -- I'm OK with the named plaintiff.

THE COURT: OK.

MR. VELAZQUEZ: If his testimony is binding on the

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class, which is what we are contemplating, are you --

THE COURT: That was the ruling from my order. The

answers to 2, 3 and 4 bind the class.

MR. VELAZQUEZ: Do you have any concern with that that

you want to address, Allan?

MR. REISS: Judge, my only concern is, as the court

pointed out, and Mr. Pollock's comment is that if Mr. Collado

says I don't know about something --

THE COURT: Yes.

MR. REISS: -- he can then foist upon us some other

witness, and I understand the corporate rep role.

THE COURT: Yes.

MR. REISS: I think since we are getting out a list of

subject matters by the end of the week, it would be fair if

Mr. Pollock gets out a list by the end of the week of who else

he is going to be calling to testify from this finite group of

people.

THE COURT: No. I'm sorry. I am not going into trial

witness lists. That is not in my bailiwick.

If you come across during the deposition a

situation -- see, it is going to be in two parts, right. You

are going to get the first shot. If there is stuff that he

says I don't know the answer to, then you can run to Judge

Torres, because I won't be here anymore, and he can help you

with that.

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MR. REISS: Thank you, Judge.

THE COURT: All right.

MR. REISS: Thank you, Judge.

THE COURT: I think that is your best approach.

I think you are entitled to an answer to every topic

as long as it is reasonable, which I'm assuming will be

relevant within the scope of discovery. You don't need to ask

him stuff that is not relevant to the case.

All right. So then we have taken care of that. We

have taken care then -- I will modify -- so from my order,

docket entry 203, I will make that the named plaintiff will

answer 2, 3 and 4 and bind the class. The individuals will

still answer 1, 5 and 6 because that presumably pertains to

each of them.

So that takes care of 1 and 2 in your notice.

Three, I defer to a motion in limine. 

Now we still need to deal with the issue of the

requests for production, where in my prior order I said you

should meet and confer and treat those the same way as the

interrogatories.

How do you need my help there?

MR. VELAZQUEZ: Well, your Honor, Mr. Pollock refused

to confer pending the order of the judge, of Judge Bloom's

ruling on his appeal. As I believe the court is aware, his

appeal had nothing to do with that aspect of your order. He

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was not disputing in any way your requirement that we confer.

THE COURT: There is nothing to appeal when I tell you

to meet and confer.

MR. VELAZQUEZ: Exactly, your Honor, but he insisted

on not doing so. So our position is, your Honor, quite

frankly, that these tactics of not responding to discovery and,

quite frankly --

THE COURT: OK. You don't need to go over that over

and over again.

Mr. Pollock, you now have to answer the

interrogatories and you now have to meet and confer, apply the

rules from the interrogatories to the requests for production

and give them the whole package, and with Mr. Collado's

deposition on the 12th, they need all those materials before

the deposition.

MR. POLLOCK: Your Honor --

MR. VELAZQUEZ: Your Honor, if I may, we would prefer

a date certain.

THE COURT: Right. I'm getting there. I'm getting

there.

MR. VELAZQUEZ: I apologize.

THE COURT: So you're getting a list of questions on

Friday and you need, Mr. Pollock, you have your work cut out

for you preparing Mr. Collado. In the meantime -- December

12th is a Tuesday -- I think the discovery, you need to produce

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it no later than the 8th, the outstanding discovery.

MR. POLLOCK: Your Honor --

THE COURT: And hopefully you have been working on it.

MR. POLLOCK: Your Honor, we have been working on it

for Mr. Collado. For the 68 or 70 other class members, we

don't have their documents because the order that was under

appeal was whether each of the members of the class had to

respond individually to the discovery. So this is the same.

So to now contact 70 people to address 43 separate requests for

production is a bit onerous.

THE COURT: Well --

MR. POLLOCK: If we are talking about the more limited

discovery, we are still talking about ten, and we have

objections we have asserted to some of those. So we're still

talking about, I don't know, 730 requests, about 680 or 700

requests.

THE COURT: Let me ask you this.

MR. POLLOCK: This involves tax returns for everybody.

THE COURT: On 1, 5 and 6, those are not necessarily

relevant to Mr. Collado's representative deposition, right? So

you can work to getting the stuff that he needs for the

deposition by the 8th.

MR. POLLOCK: For which ones, your Honor?

THE COURT: One, 5 and 6, interrogatories, and

whatever flows from there to the requests for production.

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That's rank, name, and serial number of these individuals.

Correct?

MR. POLLOCK: I'm just taking a moment to take a look.

Yes. I mean, that's going to flow readily, but I

think the other -- there's ten requests for production,

including tax returns, communications between each member of

the class and Mr. Jones. That is going to take more than a

week for us to get when you're talking about 70 people.

MR. VELAZQUEZ: Your Honor, he's had months.

THE COURT: Yes.

MR. VELAZQUEZ: You ruled in September. It wasn't

appealed. I'm sorry, but as much as I would really like to

work with Mr. Pollock on this, he chose this path.

THE COURT: Yes.

MR. VELAZQUEZ: We cannot allow this to continue

happening, respectfully, your Honor.

THE COURT: All right.

MR. VELAZQUEZ: December 8th we need the answers.

THE COURT: So that is going to be my ruling.

MR. POLLOCK: Your Honor, the conferral was --

THE COURT: By December 8th. You need to respond to

outstanding discovery by December 8th. That's my ruling.

MR. POLLOCK: For Mr. Collado?

THE COURT: Sir, all outstanding written discovery.

MR. POLLOCK: Is that for Mr. Collado?

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THE COURT: If you-all want to work out that you don't

need to give him the name, address, and phone number of your

other individual plaintiffs or the tax returns, you-all work

that out, but my ruling is all outstanding discovery, written

discovery responses due by December 8th. You do whatever you

want to do with that.

MR. POLLOCK: And my question --

THE COURT: I'm just putting a date now on my prior

ruling.

MR. POLLOCK: My question, your Honor, is with respect

to the request for production, that is for Mr. Collado, is that

correct?

THE COURT: Sir, my ruling on the requests for

production was, apply the rulings on the interrogatories and

answer them accordingly.

So I'm putting a date on that now, December 8th. If

you can work something out, you work it out. I am not going to

get into the nitty gritty of it.

Like I said, Mr. Pollock, you just chose to sit. I

think you should have hedged your bet. 

MR. POLLOCK: Your Honor --

THE COURT: Now --

MR. POLLOCK: We had a discovery hearing and there was

an appeal. The order wasn't final until the appeal --

THE COURT: Sir.

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Case 1:22-cv-23074-BB Document 243-2 Entered on FLSD Docket 01/12/2024 Page 41 of 56
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MR. POLLOCK: -- was denied, which happened --

THE COURT: Sir, you were not so sure that you were

going to prevail.

MR. POLLOCK: Correct.

THE COURT: Due diligence means you prepare.

MR. POLLOCK: It's preparing on 700 requests for

production.

THE COURT: That's it. That's it, sir.

No. 5, how many plaintiffs must answer. OK. So I've

said Mr. Collado has to answer all the interrogatories and

Mr. Collado has to respond to all the requests for production.

So 5 and 6 are taken care of in terms of the representative

stuff.

Like I said, for the individuals, if you-all want to

work out something where they can wait for the tax returns past

the deposition date, you're free to work that out, but my

ruling is all outstanding written discovery is due by December

8th .

MR. POLLOCK: Your Honor, what about the objections?

MR. VELAZQUEZ: Your Honor, there are no objections.

We have not been served with a single objection. I don't

understand why he's continuing to say what about the

objections.

Mr. Pollock, point to me a written objection that you

submitted on any of our discovery, or show it to the court.

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Case 1:22-cv-23074-BB Document 243-2 Entered on FLSD Docket 01/12/2024 Page 42 of 56
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Even better.

Exactly. There are no objections, your Honor.

MR. POLLOCK: Well --

MR. VELAZQUEZ: Our original argument was that they

waived their objections because they failed to provide any

answers.

MR. POLLOCK: We served objections on September 22nd.

Those aren't before the court, but we did object. The initial

version of the discovery --

THE COURT: Right.

MR. POLLOCK: -- will translate them over, but we did

object.

THE COURT: Listen, I can only do so much for you.

OK. Those are my rulings. Like I said, I will be in Hawaii

sitting under a coconut tree. So you can go to Judge for

Torres. All right.

MR. REISS: Just a point of clarification, Judge.

THE COURT: Yes, sir.

MR. REISS: In terms of representative depo, usually

you give them areas of inquiry, not questions.

THE COURT: Yes. Areas of inquiry, of course.

MR. REISS: Yes. Only because you said questions a

couple of times, Judge. I just didn't want there to be --

THE COURT: I spoke in general terms.

MR. REISS: Yes. Yes, ma'am.

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Case 1:22-cv-23074-BB Document 243-2 Entered on FLSD Docket 01/12/2024 Page 43 of 56
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THE COURT: My analogy to corporate representative

deposition is what is guiding my ruling.

MR. REISS: Yes, ma'am.

MR. POLLOCK: And that still provides us with an

opportunity to object to the areas, is that correct, your

Honor, just like with the corporate representative's

deposition?

THE COURT: You-all work that out. I won't be here.

MR. POLLOCK: Understood. Thank you, your Honor.

MR. VELAZQUEZ: Your Honor, if I may, as it relates to

items 5 and 6, with respect to item 6, we know what the

representative answers are because the court ruled on that

already, which are the ones that we discussed here, 2, 3 and 4,

which is what Mr. Collado will be answering as it relates to

the interrogatories. Then the 1, 3 and 5 need to be responded

to individually by that date. However, as it relates --

THE COURT: I don't understand why you say 1, 3 and 5.

The order says 1, 5 and 6.

MR. VELAZQUEZ: My apologies, your Honor. 1, 5 and 6.

So 1, 5 and 6 will be responded to individually by December

8th.

THE COURT: Unless you reach some agreement that you

don't need to know their address or phone number before the

8th, but that is if you reach some agreement; otherwise, it has

to be supplied.

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Case 1:22-cv-23074-BB Document 243-2 Entered on FLSD Docket 01/12/2024 Page 44 of 56
44

 

MR. VELAZQUEZ: Then 2, 3 and 4 of the interrogatories

will be served by December 8th. It will be Mr. Collado

answering in a representative capacity for the group.

THE COURT: Correct.

MR. VELAZQUEZ: However, as it relates to No. 5,

because Mr. Pollock never conferred, we don't know what is

supposed to be answered individually or via group. Is the

court's order that --

THE COURT: What is interrogatory No. 5? I thought

interrogatories 1, 5 and 6 all had to do with people's

individual information.

MR. VELAZQUEZ: Yes. So No. 1, your Honor, is just

the name, who is answering.

Interrogatory No. 5 deals with the nature and amount

and manner of computation of all damages, your Honor,

essentially.

THE COURT: Right. So each person answers it for

themselves, right.

MR. VELAZQUEZ: Yes, as it relates to the request for

production as well.

THE COURT: So what is your question?

MR. VELAZQUEZ: So my question is, out of the ten

requests for production, your Honor, I don't know, or none of

us know, which one of them are being answered in a

representative capacity and which one of them have to be

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Case 1:22-cv-23074-BB Document 243-2 Entered on FLSD Docket 01/12/2024 Page 45 of 56
45

 

answered individually.

If the court's order is that all the opt-in plaintiffs

have to answer the requests for production individually, then

that is the court's order and that's fine.

THE COURT: Whatever requests for production relate to

interrogatories 1, 5 and 6 get answered individually.

MR. VELAZQUEZ: Understood.

THE COURT: Requests for production individually.

Interrogatory individually.

MR. VELAZQUEZ: Thank you, your Honor.

THE COURT: Whatever requests for production relate to

interrogatories 2, 3 and 4 are representative. I thought that

was clear from my prior order.

MR. REISS: We think it is clear too. If it is not

asking too much, so Judge Torres has a roadmap, maybe we could

put that in the order that is coming from today's hearing.

THE COURT: I will repeat what I said in docket entry

203.

MR. VELAZQUEZ: Remember, your Honor, though,

respectfully, docket 203 ordered the parties to confer.

THE COURT: Right. I didn't say I would copy and

paste. I said I would reflect that same ruling.

MR. REISS: Thank you, Judge.

MR. VELAZQUEZ: Understood, your Honor. Thank you

very much, and I hope you enjoy your time in Hawaii.

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Case 1:22-cv-23074-BB Document 243-2 Entered on FLSD Docket 01/12/2024 Page 46 of 56
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THE COURT: That was factitious. I've been to Hawaii.

I'm not ready to get under that coconut tree just yet.

MR. VELAZQUEZ: Not yet. OK.

THE COURT: Thank you very much.

(Adjourned)

C E R T I F I C A T E 

I hereby certify that the foregoing is an accurate 

transcription to the best of my ability of the digital audio 

recording in the above-entitled matter. 

January 12, 2024 s/ Joanne Mancari 

 Joanne Mancari, RPR, CRR, CSR 

 Court Reporter 

 jemancari@gmail.com 

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Case 1:22-cv-23074-BB Document 243-2 Entered on FLSD Docket 01/12/2024 Page 47 of 56
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 THE COURT: [135] 

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coming [3] 13/14 28/7 45/16

comment [2] 23/8 35/7

common [1] 16/17

communication [1] 13/15

communications [1] 39/6

complained [1] 11/21

complaint [2] 11/9 22/4

computation [1] 44/15

concern [3] 10/2 35/4 35/6

confer [9] 8/10 8/25 30/9 36/19 36/23

 37/1 37/3 37/11 45/20

conferral [1] 39/20

conferrals [1] 6/22

conferred [1] 44/6

connecting [1] 18/16

consistent [1] 10/8

consolidated [1] 14/14

consolidation [1] 15/14

constituting [1] 11/7

CONT'D [1] 2/1

contact [1] 38/9

contemplating [2] 10/23 35/1

contend [2] 12/12 14/22

continue [1] 39/15

continuing [1] 41/22

contract [1] 19/12

conversation [3] 23/23 24/4 24/21

conversations [6] 19/16 19/17 19/20

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cooperation [1] 30/18

copy [2] 13/15 45/21

copying [1] 13/24

Coral [1] 1/15

corporate [10] 22/10 22/11 23/5 23/17

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corporation [3] 23/18 23/24 26/1

correct [13] 10/17 19/25 23/21 29/19

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correctly [1] 5/6

could [2] 18/4 45/15

couldn't [1] 30/2

Counsel [1] 3/5

countering [1] 16/10

couple [3] 29/6 29/12 42/23

course [6] 4/4 14/9 15/11 19/7 26/13

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court [18] 1/1 2/12 3/13 6/25 8/9 8/14

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court's [3] 44/8 45/2 45/4

courtroom [1] 16/7

cover [2] 17/19 27/17

create [1] 30/24

crowd [1] 8/7

CRR [2] 2/12 46/13

CSR [2] 2/12 46/13

cut [1] 37/23

cutoff [2] 28/8 28/25

CV [1] 1/2

D

damages [2] 21/25 44/15

date [12] 13/2 13/5 28/14 29/11 31/21

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dated [1] 13/20

dates [2] 31/23 31/24

day [6] 4/15 5/4 5/6 32/23 33/1 33/2

days [6] 5/6 25/21 29/6 29/12 29/16 33/3

deadline [2] 9/1 30/6

deadlines [1] 30/25

deal [2] 27/7 36/17

deals [1] 44/14

December [9] 37/24 39/18 39/21 39/22

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deem [1] 7/15

deemed [1] 17/3

defendant [5] 1/8 2/3 2/7 3/12 20/5

defendants [9] 3/22 12/13 14/22 20/6

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defense [12] 4/3 5/7 7/25 8/24 16/1 16/1

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defer [1] 36/16

denied [2] 28/17 41/1

denying [1] 29/6

depend [2] 20/16 27/2

depending [2] 5/23 6/1

depo [6] 6/21 26/1 28/23 31/10 32/13

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deponent [1] 4/10

depose [9] 3/22 8/3 21/15 21/19 24/17

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deposed [7] 4/2 4/12 4/13 8/12 9/22

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deposing [8] 6/2 7/15 8/5 9/3 16/16 18/7

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deposition [25] 4/10 7/12 7/25 9/17

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Case 1:22-cv-23074-BB Document 243-2 Entered on FLSD Docket 01/12/2024 Page 49 of 56
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depositions [24] 4/4 4/5 4/8 4/24 5/4 5/5

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described [1] 11/8

detail [1] 17/1

determining [1] 30/1

developing [1] 19/3

did [4] 8/25 22/21 42/8 42/11

didn't [9] 19/22 21/19 23/9 26/3 26/24

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different [8] 8/7 9/15 15/24 17/22 19/5

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differently [1] 8/2

difficult [1] 15/17

digital [2] 1/10 46/10

dilemma [1] 19/18

diligence [1] 41/5

direct [1] 18/5

discovery [42] 1/10 3/20 8/21 9/1 9/6

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discussed [2] 34/2 43/13

discussing [1] 28/18

discussions [1] 3/23

disputing [1] 37/1

distribute [2] 14/23 14/24

distributed [2] 14/25 15/3

distribution [2] 15/8 20/2

DISTRICT [2] 1/1 1/1

divided [1] 6/9

do [29] 3/15 6/8 7/8 10/21 12/22 15/9

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dock [3] 4/22 4/25 6/4

docket [3] 36/11 45/17 45/20

document [2] 12/18 15/4

documents [6] 20/13 20/22 20/24 21/10

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does [6] 9/19 9/23 9/24 20/22 26/18 27/1

doesn't [9] 16/6 19/20 19/25 22/8 23/10

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doing [2] 3/9 37/5

don't [41] 3/23 5/18 6/22 8/11 8/17 9/20

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done [7] 4/11 4/14 9/7 9/8 20/3 25/6

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dots [1] 18/16

down [4] 11/21 20/4 22/6 33/20

DRIVE [4] 1/6 2/3 3/4 3/9

due [3] 40/5 41/5 41/17

duration [1] 6/20

during [4] 15/1 15/2 26/25 35/20

duty [3] 23/2 23/20 26/12

E

e.g [2] 12/14 14/23

each [20] 4/10 9/3 11/7 12/12 12/17

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educate [3] 22/19 22/24 23/2

efficient [1] 16/13

effort [1] 29/22

either [4] 17/1 18/4 19/11 34/7

else [7] 8/2 10/16 14/19 15/9 16/6 34/9

 35/15

email [4] 13/3 13/19 14/3 31/23

employee [1] 11/8

end [8] 13/8 28/23 31/5 32/10 32/11

 32/19 35/14 35/15

endorse [2] 25/14 26/11

endorsing [2] 26/8 27/14

enjoy [1] 45/25

enlarge [1] 17/1

entered [2] 28/4 28/16

entire [2] 5/4 16/18

entire-day [1] 5/4

entitled [2] 36/5 46/11

entity [2] 22/11 23/24

entry [2] 36/11 45/17

envision [1] 19/3

equals [1] 4/3

ESQ [3] 1/13 2/3 2/7

essentially [1] 44/16

et [3] 1/3 1/7 3/4

etc [1] 12/18

even [2] 30/16 42/1

every [9] 11/7 12/12 12/18 14/21 15/4

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everybody [9] 7/4 16/6 17/19 22/5 27/15

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everything [4] 17/23 23/2 25/19 25/22

exact [1] 28/14

Exactly [2] 37/4 42/2

exam [1] 24/1

example [1] 25/25

exceed [1] 25/20

excess [1] 31/23

expend [1] 29/22

explaining [1] 18/24

explanation [1] 19/1

extent [1] 9/20

F

facing [1] 30/6

fact [2] 12/12 14/21

factitious [1] 46/1

facts [6] 11/11 14/18 15/7 15/7 20/12

 20/23

failed [3] 14/23 18/25 42/5

fails [1] 18/2

failure [1] 14/24

fair [3] 23/16 26/5 35/14

fairest [1] 26/15

FAIRLAW [1] 1/14

fairlawattorney.com [1] 1/16

far [2] 22/3 29/9

February [2] 28/24 30/7

fictitious [1] 23/24

field [1] 26/5

fight [1] 27/1

fighting [1] 3/24

figure [2] 6/4 6/12

final [3] 29/13 29/14 40/24

finalizing [1] 21/4

find [7] 6/16 12/5 12/6 13/6 21/14 25/12

 32/25

fine [5] 6/18 8/19 12/7 12/9 45/4

finite [1] 35/16

FIRM [1] 1/14

first [3] 3/21 30/9 35/22

five [4] 11/19 11/21 13/4 15/15

FL [3] 1/15 2/4 2/9

FLORIDA [4] 1/1 1/4 19/11 19/11

flow [1] 39/4

flows [1] 38/25

foist [1] 35/10

follow [1] 10/12

followed [1] 30/11

following [1] 3/2

follows [3] 11/6 12/12 14/21

foregoing [1] 46/9

forgot [1] 3/13

formula [2] 20/3 30/1

forward [4] 13/8 13/10 27/21 28/24

found [2] 13/11 22/21

four [3] 5/5 8/22 21/2

frankly [2] 37/6 37/7

free [1] 41/16

Friday [2] 32/21 37/23

front [2] 10/13 11/4

full [1] 14/7

G

Gables [1] 1/15

gain [1] 33/25

gee [1] 25/7

general [2] 18/6 42/24

get [23] 4/14 14/13 14/15 16/19 17/1

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gets [4] 21/22 31/4 31/11 35/15

getting [5] 35/13 37/19 37/19 37/22

 38/21

give [8] 3/24 5/20 13/13 24/16 30/13

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given [2] 15/18 28/24

giving [1] 27/16

gmail.com [2] 2/13 46/14

go [15] 4/9 10/3 10/25 15/9 16/7 17/2

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goes [2] 16/21 20/17

going [43] 4/9 4/13 5/16 6/5 7/14 7/15

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Good [3] 3/6 3/8 3/11

got [3] 10/3 11/16 19/10

gotten [2] 16/23 30/18

great [1] 21/17

gritty [1] 40/18

group [3] 35/16 44/3 44/7

grow [1] 15/12

guess [7] 5/23 12/3 18/23 24/1 27/2 28/7

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guiding [1] 43/2

guy [1] 26/23

H

had [15] 3/23 8/3 19/16 19/18 19/19

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Case 1:22-cv-23074-BB Document 243-2 Entered on FLSD Docket 01/12/2024 Page 50 of 56
H

half [9] 5/19 5/25 6/3 6/13 7/2 7/3 7/4

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hand [2] 16/2 22/17

happened [2] 23/23 41/1

happening [1] 39/16

has [19] 4/3 4/25 9/13 11/1 13/23 15/25

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hasn't [1] 29/3

hate [1] 32/15

have [79] 

haven't [5] 9/7 15/18 16/23 20/4 31/21

having [3] 18/1 26/9 27/15

Hawaii [3] 42/14 45/25 46/1

he [25] 19/19 20/22 21/15 23/7 24/3

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he's [2] 39/9 41/22

heads [1] 27/17

heads-up [1] 27/17

hear [4] 10/21 19/2 27/9 33/11

heard [2] 23/8 28/10

hearing [7] 1/10 3/20 7/18 29/25 30/3

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hearings [1] 24/22

hearsay [1] 24/3

hedged [1] 40/20

held [1] 3/2

help [2] 35/24 36/21

here [9] 5/24 7/24 10/1 21/6 22/13 27/20

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here's [3] 21/17 22/20 32/1

hereby [1] 46/9

hidden [1] 24/8

him [7] 21/10 22/24 27/18 30/13 33/1

 36/8 40/2

his [11] 21/11 21/13 21/14 22/25 23/2

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hit [1] 28/13

honest [1] 6/17

honestly [1] 33/23

Honor [72] 

HONORABLE [1] 1/11

hope [1] 45/25

hopefully [1] 38/3

host [2] 4/22 4/22

hour [2] 14/4 27/21

hours [18] 4/10 4/12 5/7 5/15 5/19 5/24

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how [18] 3/21 4/11 8/20 9/2 10/21 11/10

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However [2] 43/16 44/5

humor [1] 17/14

I

I'd [3] 4/9 6/16 28/23

I'll [2] 13/8 13/10

I'm [36] 6/4 6/6 6/8 6/12 11/18 12/4

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I've [3] 11/16 41/9 46/1

ID [1] 11/19

idea [2] 16/11 16/19

identified [1] 11/12

identify [4] 11/6 12/18 14/17 15/4

identifying [2] 12/14 14/23

if [53] 

implemented [1] 16/20

in [90] 

inaccurate [2] 20/23 31/22

inaudible [1] 25/15

inclined [2] 18/18 18/18

including [1] 39/6

indicated [1] 10/4

individual [5] 10/20 20/5 21/25 40/3

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individually [9] 38/8 43/16 43/20 44/7

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individuals [11] 6/15 8/12 8/13 15/23

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information [5] 19/24 21/3 21/17 34/15

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initial [1] 42/8

initially [3] 8/22 11/20 34/14

inquiry [3] 10/25 42/20 42/21

ins [1] 4/13

insisted [1] 37/4

interrogatories [26] 7/19 8/6 8/13 9/21

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interrogatory [9] 11/6 14/20 17/7 23/13

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intervals [1] 27/21

into [8] 15/9 16/7 21/22 22/15 23/15 24/2

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involves [2] 15/12 38/18

is [166] 

issue [18] 4/2 5/7 5/7 6/21 7/18 8/25

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issues [10] 8/8 10/4 14/12 18/5 20/4

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it [133] 

it's [4] 4/21 25/12 29/16 41/6

item [7] 7/11 26/2 26/7 26/18 27/7 27/12

 43/11

items [3] 32/2 32/4 43/11

J

jacket [2] 3/13 3/18

JACKSON [1] 2/3

jacksonlewis.com [1] 2/5

January [1] 46/13

jemancari [2] 2/13 46/14

Joanne [3] 2/12 46/13 46/13

job [1] 33/22

jointly [1] 28/22

Jones [6] 3/10 19/4 19/19 19/21 20/5

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judge [29] 1/11 3/18 6/16 7/7 12/4 26/21

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juicy [1] 25/12

July [6] 13/1 13/19 13/20 13/21 28/10

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jumping [2] 14/13 14/15

just [29] 5/17 5/19 10/4 11/23 12/2 12/4

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justification [2] 6/4 6/13

K

keep [1] 7/3

keeping [2] 15/7 24/19

kept [1] 14/19

Kiki [1] 3/10

kind [11] 4/11 5/12 7/1 10/18 16/21 17/1

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know [30] 3/23 5/18 11/10 12/22 14/12

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knowing [2] 16/8 22/16

knowledge [2] 20/9 23/19

knows [4] 19/4 19/5 19/16 23/1

L

lack [1] 15/21

last [2] 25/24 29/15

last-minute [1] 25/24

later [4] 24/20 26/4 30/22 38/1

law [3] 19/11 20/6 24/1

lawsuit [2] 16/15 16/18

lead [1] 15/19

legitimate [2] 26/2 26/13

let [9] 5/19 6/7 10/21 13/7 19/2 22/2

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let's [1] 17/8

level [1] 23/17

levels [1] 20/9

LEVINE [2] 2/8 3/12

levinelawfirm.com [1] 2/10

LEWIS [1] 2/3

liability [1] 20/6

like [33] 4/8 4/9 5/10 5/11 5/22 7/1 8/10

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limine [5] 26/20 26/21 27/6 27/10 36/16

limine-type [1] 27/6

limit [3] 4/9 10/14 17/5

limited [5] 10/4 16/4 22/3 27/8 38/12

list [10] 23/2 26/14 28/21 28/22 31/5

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Listen [1] 42/13

lists [1] 35/19

litigate [1] 25/16

litigating [2] 16/2 25/17

little [2] 3/24 7/3

live [1] 7/6

LLC [4] 1/6 2/8 3/4 3/12

long [1] 36/6

longer [1] 7/3

look [5] 20/11 26/5 29/10 29/14 39/3

looking [10] 6/6 6/8 11/17 11/18 12/21

 16/17 17/21 18/12 22/14 34/10

looks [3] 5/22 13/2 14/2

Lorenzo [1] 1/14

luxury [1] 16/8

M

ma'am [2] 42/25 43/3

made [1] 16/13

magician [1] 30/23

MAGISTRATE [1] 1/11

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M

main [3] 4/4 7/13 15/13

major [1] 30/19

make [11] 3/17 5/17 8/15 9/15 9/19 14/3

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makes [5] 8/16 10/8 15/25 17/5 17/9

making [1] 20/17

manager [1] 19/23

managers [1] 19/20

Mancari [3] 2/12 46/13 46/13

manner [1] 44/15

many [3] 3/21 33/12 41/9

Mary [1] 2/8

master [3] 4/22 4/25 6/4

masters [1] 25/16

materials [1] 37/14

matter [3] 26/5 31/15 46/11

matters [6] 17/3 17/7 27/17 28/22 31/5

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maximum [1] 5/15

may [19] 3/22 17/21 18/20 19/5 19/17

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maybe [10] 6/10 6/13 7/1 18/16 22/23

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me [36] 3/24 5/19 6/7 8/16 9/13 10/13

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mean [15] 9/23 10/18 16/11 17/20 19/21

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means [1] 41/5

meantime [1] 37/24

meet [4] 7/1 36/19 37/3 37/11

member [1] 39/6

members [4] 7/13 9/25 38/5 38/7

mentioned [1] 20/22

merits [2] 6/3 15/21

Miami [3] 1/4 2/4 2/9

middle [1] 7/1

might [3] 11/17 18/2 29/18

minimum [3] 17/12 19/11 21/7

minute [3] 17/8 25/24 26/24

modify [1] 36/10

moment [2] 17/9 39/3

Monday [2] 29/15 32/14

months [1] 39/9

more [4] 17/1 17/18 38/12 39/7

morning [4] 3/6 3/8 3/11 3/14

Most [1] 11/5

motion [5] 26/20 26/21 27/6 27/10 36/16

move [1] 28/24

moving [1] 27/21

Mr [2] 30/19 32/7

Mr. [70] 

Mr. Collado [15] 28/20 29/9 29/21 31/7

 31/10 35/7 37/24 38/5 39/23 39/25 40/11

 41/10 41/11 43/14 44/2

Mr. Collado's [3] 32/13 37/13 38/20

Mr. Jones [4] 19/4 19/19 19/21 39/7

Mr. Pollock [33] 6/10 6/14 7/6 8/21 8/24

 8/25 9/19 14/2 19/2 20/22 21/3 21/6

 23/1 23/6 23/14 24/6 24/23 25/13 25/19

 25/25 27/16 29/1 29/2 30/12 33/11 35/15

 36/22 37/10 37/23 39/13 40/19 41/24

 44/6

Mr. Pollock's [2] 26/12 35/7

Mr. Smith [2] 19/5 24/3

Mr. Velazquez [10] 4/18 7/16 10/21 23/5

 25/19 25/22 26/14 28/21 31/4 32/9

Mr. Velazquez's [1] 34/18

Mrs. [1] 19/5

Mrs. Smith [1] 19/5

much [6] 25/7 39/12 42/13 45/15 45/25

 46/4

multiple [3] 4/14 23/21 23/22

must [1] 41/9

mutually [1] 33/2

my [44] 3/13 4/19 5/16 5/17 6/22 8/10

 10/2 12/23 13/7 14/1 14/13 14/14 16/11

 18/23 21/1 21/17 22/3 22/4 28/17 29/3

 31/24 32/15 33/6 35/2 35/6 35/19 36/10

 36/18 36/21 39/19 39/22 40/4 40/7 40/8

 40/10 40/13 41/16 42/14 43/1 43/2 43/19

 44/22 45/13 46/10

N

name [6] 10/19 11/7 11/22 39/1 40/2

 44/13

named [24] 14/7 17/19 17/23 22/24 23/4

 23/7 25/20 25/20 25/23 26/9 26/12 26/22

 27/15 32/5 33/7 33/10 33/13 33/15 33/16

 34/7 34/14 34/17 34/23 36/11

narrowing [1] 33/20

natural [1] 15/11

nature [2] 17/4 44/14

necessarily [3] 8/11 18/3 38/19

need [21] 9/17 17/2 24/10 32/2 32/25

 33/17 33/23 34/9 34/12 36/7 36/17 36/21

 37/8 37/14 37/23 37/25 39/18 39/21 40/2

 43/15 43/23

needs [4] 24/25 25/6 25/22 38/21

never [2] 19/19 44/6

next [1] 12/10

nitty [1] 40/18

no [39] 1/2 3/4 11/6 11/13 11/15 11/15

 11/22 11/23 11/25 12/1 12/11 13/16

 14/14 14/20 15/6 15/6 15/7 21/16 24/12

 26/5 26/7 26/7 26/8 26/18 27/7 27/12

 27/22 28/11 30/18 30/23 35/18 38/1 41/9

 41/20 42/2 44/5 44/9 44/12 44/14

non [2] 10/16 11/8

non-representative [1] 10/16

non-tipped [1] 11/8

none [2] 19/21 44/23

normal [1] 19/7

north [4] 1/6 3/3 3/9 21/10

not [52] 

noted [1] 6/22

nothing [4] 30/7 30/17 36/25 37/2

notice [6] 3/19 5/8 6/6 24/16 32/3 36/15

notices [2] 6/8 6/16

noticing [1] 3/18

November [1] 1/5

now [20] 4/1 8/5 13/10 15/9 15/17 16/4

 21/2 21/18 22/7 25/25 32/24 34/11 34/11

 36/17 37/10 37/11 38/9 40/8 40/16 40/22

number [7] 3/24 10/20 23/1 28/14 39/1

 40/2 43/23

numerous [1] 30/16

O

object [3] 42/8 42/12 43/5

objection [2] 41/21 41/24

objections [7] 38/14 41/19 41/20 41/23

 42/2 42/5 42/7

obviously [4] 7/13 10/20 10/25 16/21

occurred [2] 12/15 14/25

OCTAVIO [2] 1/3 3/3

October [3] 30/9 30/10 30/11

off [1] 29/18

off-chance [1] 29/18

oh [2] 21/16 26/23

OK [27] 4/6 4/16 5/2 5/10 6/3 6/18 6/24

 7/5 8/18 9/9 9/12 9/12 11/24 12/8 12/20

 13/12 13/16 13/18 13/22 26/16 33/2

 34/23 34/24 37/8 41/9 42/14 46/3

old [1] 11/17

on [77] 

once [1] 29/13

one [38] 4/25 5/12 5/13 6/6 8/8 11/18

 11/19 11/23 12/3 12/4 12/10 13/13 14/1

 16/2 16/20 17/13 19/16 19/20 21/2 21/12

 22/17 23/1 25/4 27/13 27/15 28/1 28/9

 30/21 32/23 33/1 33/5 33/6 33/20 33/24

 34/5 38/24 44/24 44/25

onerous [1] 38/10

ones [10] 7/2 8/6 9/5 9/18 11/17 11/18

 12/5 34/2 38/23 43/13

only [12] 4/25 5/13 14/4 18/4 21/1 26/18

 26/22 28/17 32/23 35/6 42/13 42/22

onward [1] 25/4

opportunity [7] 8/3 15/23 21/15 21/19

 24/17 31/14 43/5

opt [14] 4/2 4/13 5/4 5/9 6/1 6/21 7/21

 14/4 16/5 18/3 18/5 21/1 27/20 45/2

opt-in [13] 4/2 5/4 5/9 6/1 6/21 7/21 14/4

 16/5 18/3 18/5 21/1 27/20 45/2

opt-ins [1] 4/13

or [48] 

order [25] 28/4 28/8 28/16 29/3 29/5

 29/10 29/13 29/14 29/15 29/16 33/1 33/6

 35/2 36/10 36/18 36/23 36/25 38/6 40/24

 43/18 44/8 45/2 45/4 45/13 45/16

ordered [3] 11/1 31/16 45/20

original [1] 42/4

OTAZO [1] 1/11

OTAZO-REYES [1] 1/11

other [19] 15/20 15/23 16/21 19/21 20/4

 21/5 21/13 24/13 24/16 26/23 29/23

 29/24 30/3 31/12 33/17 35/10 38/5 39/5

 40/3

others [3] 19/18 24/15 34/16

otherwise [2] 17/23 43/24

our [10] 6/22 7/18 9/2 11/2 16/2 27/4

 30/9 37/5 41/25 42/4

out [25] 5/5 6/4 6/12 21/2 21/4 21/14

 22/21 24/5 28/21 28/22 31/4 32/10 32/19

 35/7 35/13 35/15 37/23 40/1 40/4 40/17

 40/17 41/15 41/16 43/8 44/22

outline [3] 6/23 14/14 30/22

outside [2] 16/5 17/2

outstanding [6] 29/1 38/1 39/22 39/24

 40/4 41/17

over [9] 3/24 5/5 12/22 25/21 26/10 37/8

 37/8 37/9 42/11

overtips [11] 11/10 11/11 11/12 12/14

 12/16 12/17 14/23 14/25 15/1 15/2 15/3

own [2] 18/10 22/8

P

P.C [1] 2/3

package [1] 37/13

page [1] 11/16

Pages [1] 1/8

paperless [1] 29/15

Case 1:22-cv-23074-BB Document 243-2 Entered on FLSD Docket 01/12/2024 Page 52 of 56
P

paragraph [1] 11/8

pare [1] 22/6

parrot [1] 34/16

particular [3] 6/1 16/15 18/5

parties [1] 45/20

PARTNERS [2] 2/8 3/12

parts [1] 35/21

pass [1] 30/14

past [2] 29/12 41/15

paste [1] 45/22

path [1] 39/13

pattern [1] 10/12

Pause [4] 5/21 6/19 12/25 13/9

payroll [1] 20/25

peculiar [2] 16/14 18/10

pending [2] 21/2 36/23

people [35] 5/12 6/11 7/14 8/5 8/20 9/2

 9/5 9/14 9/16 9/21 9/22 14/18 16/16

 18/9 18/12 19/23 20/15 21/18 22/18

 23/21 23/22 26/8 28/14 29/23 29/24 30/4

 31/12 31/17 33/7 33/12 33/17 33/24

 35/17 38/9 39/8

people's [1] 44/10

per [9] 4/3 4/16 5/6 5/11 5/12 5/15 8/23

 14/11 33/10

period [1] 4/14

person [13] 4/25 5/13 5/15 11/7 11/22

 19/16 21/12 21/13 21/25 24/17 33/7

 33/20 44/17

personnel [1] 25/2

persons [1] 11/12

perspective [2] 5/8 8/14

pertain [2] 10/15 16/15

pertaining [2] 18/5 21/7

pertains [1] 36/13

pertinent [1] 17/19

phone [4] 5/16 12/23 40/2 43/23

picture [1] 22/14

plaintiff [38] 1/4 1/13 3/7 4/4 4/11 4/20

 6/1 7/13 16/6 17/19 17/24 18/5 21/1

 22/18 22/24 23/2 23/7 25/20 25/20 25/23

 26/9 26/13 26/18 26/22 27/15 28/5 32/5

 33/7 33/10 33/13 33/15 33/16 34/6 34/7

 34/14 34/17 34/23 36/11

plaintiff's [2] 23/4 23/4

plaintiffs [20] 3/21 4/2 5/9 7/21 7/22 9/11

 14/5 14/7 15/23 16/5 17/12 18/3 22/4

 23/1 25/24 27/20 34/1 40/3 41/9 45/2

plaintiffs' [3] 4/6 6/21 22/14

plan [2] 5/11 27/23

playing [2] 24/4 26/5

please [3] 3/5 12/12 14/21

plus [1] 29/23

point [3] 20/17 41/24 42/17

pointed [1] 35/7

POLLOCK [35] 1/13 3/6 6/10 6/14 7/6

 8/21 8/24 8/25 9/19 14/2 19/2 20/22

 21/3 21/6 23/1 23/6 23/14 24/6 24/23

 25/13 25/19 25/25 27/16 29/1 29/2 30/12

 33/11 35/15 36/22 37/10 37/23 39/13

 40/19 41/24 44/6

Pollock's [2] 26/12 35/7

portion [1] 10/14

position [14] 4/3 4/6 4/16 4/25 5/11 5/13

 8/1 11/2 11/7 14/12 16/1 19/22 33/10

 37/5

positions [3] 4/17 6/14 18/20

possible [1] 19/1

practical [1] 24/11

practically [2] 23/3 30/7

precise [1] 5/20

prefer [1] 37/17

prejudiced [1] 25/5

prepare [10] 15/18 16/8 21/11 23/20

 25/2 25/22 26/4 26/12 27/18 41/5

prepared [3] 24/25 26/10 26/11

preparing [2] 37/24 41/6

prerogative [1] 21/14

present [1] 24/15

presumably [4] 16/17 33/4 34/15 36/13

pretrial [1] 20/17

prevail [1] 41/3

prior [7] 6/22 7/18 24/22 33/6 36/18 40/8

 45/13

problem [5] 8/17 9/21 10/8 30/19 32/17

proceed [2] 31/7 31/10

proceedings [1] 3/2

process [1] 21/4

produce [1] 37/25

produced [4] 20/24 20/25 21/8 29/4

production [17] 8/7 30/10 36/18 37/12

 38/10 38/25 39/5 40/11 40/14 41/7 41/11

 44/20 44/23 45/3 45/5 45/8 45/11

proposed [4] 4/3 8/22 15/13 34/13

proposing [2] 27/19 33/9

prosecute [1] 24/25

proven [1] 20/7

provide [4] 4/8 23/17 32/6 42/5

provided [2] 20/4 26/14

provides [1] 43/4

providing [1] 31/23

pull [1] 13/7

purpose [1] 22/16

purposes [2] 7/24 9/14

pursuant [2] 4/12 20/3

put [2] 33/1 45/16

putative [1] 19/10

puts [2] 7/25 16/1

putting [2] 40/8 40/16

Q

question [11] 3/21 8/14 9/24 11/13 11/14

 11/15 16/22 40/7 40/10 44/21 44/22

questions [12] 10/3 15/12 15/19 15/20

 17/16 17/18 18/2 20/16 23/6 37/22 42/20

 42/22

quick [1] 5/19

quite [2] 37/5 37/7

R

raised [1] 6/21

rank [2] 10/19 39/1

rapidly [1] 9/1

rationale [1] 18/23

reach [4] 5/16 8/9 43/22 43/24

reaching [1] 12/23

read [4] 11/23 11/25 12/3 13/16

readily [1] 39/4

ready [1] 46/2

real [1] 5/19

realize [1] 18/2

really [4] 22/23 23/13 23/15 39/12

reason [3] 4/24 12/24 17/20

reasonable [6] 5/11 5/14 6/12 7/5 31/16

 36/6

recall [3] 7/17 11/20 17/11

receipts [1] 21/4

received [8] 9/10 11/9 11/10 11/12 15/1

 29/5 29/10 31/21

recent [1] 12/5

recollection [1] 22/4

record [3] 3/5 5/3 21/5

recording [2] 1/10 46/11

records [2] 20/25 21/10

reduced [1] 11/21

reducing [1] 13/4

reflect [1] 45/22

reflected [1] 5/8

refused [1] 36/22

regard [1] 26/7

REISS [4] 2/7 3/11 30/19 32/7

relate [3] 10/22 45/5 45/11

related [1] 7/19

relates [29] 4/2 5/9 10/2 11/2 14/3 14/4

 15/20 16/9 17/17 18/4 18/19 19/15 20/9

 20/18 20/25 21/3 21/6 21/12 21/25 26/17

 27/9 27/12 30/16 34/20 43/10 43/14

 43/16 44/5 44/19

relationship [1] 9/4

relevant [3] 36/7 36/8 38/20

remainder [1] 29/9

remember [5] 5/6 17/13 20/2 33/19

 45/19

rep [3] 26/1 26/1 35/11

repeat [1] 45/17

Reporter [2] 2/12 46/14

represent [1] 18/14

representation [1] 20/23

representative [47] 

representative's [3] 26/3 27/14 43/6

representatives [7] 7/15 8/7 9/14 9/15

 9/17 17/21 22/19

represents [2] 18/14 19/21

request [4] 30/9 31/14 40/11 44/19

requested [2] 21/3 21/6

requesting [1] 31/19

requests [17] 8/6 30/10 36/18 37/12 38/9

 38/15 38/16 38/25 39/5 40/13 41/6 41/11

 44/23 45/3 45/5 45/8 45/11

required [1] 33/6

requirement [1] 37/1

respect [3] 29/20 40/10 43/11

respectfully [3] 31/13 39/16 45/20

respond [7] 9/21 23/22 30/4 34/14 38/8

 39/21 41/11

responded [2] 43/15 43/20

responding [2] 28/15 37/6

response [1] 28/11

responses [3] 30/16 31/8 40/5

responsibility [1] 21/14

responsive [1] 23/22

rest [2] 27/25 29/21

result [1] 15/14

retained [3] 12/13 12/16 12/17

retention [1] 12/15

returns [4] 38/18 39/6 40/3 41/15

review [1] 21/11

revised [2] 11/18 12/21

Rey [2] 12/22 13/19

rey.velazquez [1] 2/5

REYES [1] 1/11

REYNALDO [2] 2/3 3/8

right [47] 

rightfully [1] 22/13

RIVER [7] 1/6 2/3 2/8 3/3 3/9 3/10 3/12

RJ [2] 2/8 3/12

roadmap [1] 45/15

role [1] 35/11

Roman [2] 3/10 20/5

Case 1:22-cv-23074-BB Document 243-2 Entered on FLSD Docket 01/12/2024 Page 53 of 56
R

route [2] 26/22 27/14

RPR [2] 2/12 46/13

rule [3] 18/18 30/23 32/2

ruled [5] 7/18 7/21 19/12 39/11 43/12

rules [4] 4/7 4/12 27/4 37/12

ruling [15] 7/24 16/12 20/17 22/3 30/17

 35/2 36/24 39/19 39/22 40/4 40/9 40/13

 41/17 43/2 45/22

rulings [2] 40/14 42/14

run [1] 35/23

S

said [17] 4/16 10/13 14/18 25/8 27/24

 29/17 31/17 31/17 34/10 36/18 40/19

 41/10 41/14 42/14 42/22 45/17 45/22

same [9] 7/24 9/13 10/12 12/23 19/22

 34/15 36/19 38/8 45/22

San [1] 1/14

sandbagged [1] 8/1

say [30] 7/12 15/19 15/24 16/4 16/5

 18/12 18/14 18/14 18/15 18/15 21/9

 21/16 21/17 21/19 22/20 24/8 25/7 26/7

 26/21 26/23 26/23 26/24 27/13 29/11

 29/14 32/4 33/4 41/22 43/17 45/21

saying [12] 5/15 7/14 9/6 10/14 16/21

 18/18 22/5 22/18 25/8 27/9 27/22 30/19

says [7] 23/10 23/10 23/25 26/2 35/8

 35/23 43/18

scheduled [5] 5/4 5/5 5/18 5/23 5/25

scheme [1] 22/6

school [1] 24/1

scope [4] 10/22 17/6 17/8 36/7

searched [1] 11/20

second [2] 6/7 13/13

see [9] 6/7 13/7 13/25 17/25 20/10 20/14

 20/18 30/13 35/21

seem [4] 8/15 16/19 19/25 27/23

seems [6] 5/10 9/13 16/24 27/23 31/16

 34/18

selected [7] 8/21 8/21 8/23 8/24 9/2 9/2

 18/13

sense [9] 8/15 8/16 9/15 9/19 10/8 16/13

 17/5 17/9 23/11

sent [6] 11/18 12/22 13/3 28/10 30/9

 31/23

separate [1] 38/9

September [6] 16/12 28/4 29/4 31/20

 39/11 42/7

serial [2] 10/19 39/1

serious [1] 30/25

served [4] 5/9 41/21 42/7 44/2

servers [3] 18/15 18/20 25/3

sessions [3] 26/10 27/16 32/5

set [3] 12/21 28/20 32/23

seven [8] 4/12 4/23 14/8 25/21 26/10

 27/16 32/5 33/1

shame [1] 26/3

she [1] 27/5

shield [1] 16/4

shorter [1] 4/14

shortly [1] 13/5

shot [1] 35/22

should [4] 18/21 25/4 36/19 40/20

show [1] 41/25

showing [2] 24/11 24/20

side [1] 26/12

significance [1] 5/23

signing [1] 31/17

simple [1] 22/12

since [5] 29/1 29/16 31/20 32/13 35/13

single [1] 41/21

sir [8] 8/19 27/22 39/24 40/13 40/25 41/2

 41/8 42/18

sit [2] 28/14 40/19

sitting [3] 29/7 30/13 42/15

situation [3] 8/11 18/10 35/21

six [1] 33/24

small [2] 34/11 34/11

Smith [3] 19/5 19/5 24/3

so [101] 

some [10] 18/2 20/3 23/12 24/11 25/12

 30/25 35/10 38/14 43/22 43/24

somebody [2] 8/2 34/9

someone [3] 19/16 23/25 24/15

something [8] 15/24 18/4 22/8 27/2

 28/10 35/8 40/17 41/15

sometime [1] 13/5

sorry [3] 30/12 35/18 39/12

sort [7] 5/11 17/20 22/13 24/19 28/7

 31/1 34/10

sound [1] 22/9

sounding [1] 23/14

sounds [7] 7/5 22/22 25/8 25/12 30/12

 30/24 33/21

South [1] 2/4

SOUTHERN [1] 1/1

speak [3] 18/4 28/18 32/15

speaking [1] 18/8

spillover [1] 33/2

spoke [1] 42/24

spread [1] 5/5

stands [1] 9/16

started [1] 15/18

Starting [1] 30/8

state [4] 3/5 11/10 12/12 14/21

stated [1] 15/25

states [5] 1/1 1/11 11/6 12/11 14/20

step [2] 20/1 22/2

stick [2] 4/8 17/8

still [11] 12/21 17/14 27/20 28/5 28/11

 33/7 36/13 36/17 38/13 38/14 43/4

story [1] 23/14

strategy [2] 16/9 21/18

streamline [2] 16/12 22/6

Street [1] 2/8

struggle [1] 17/25

stuff [5] 28/15 35/22 36/8 38/21 41/13

sub [2] 26/8 27/14

sub-representative [1] 26/8

sub-representative's [1] 27/14

subject [9] 4/10 8/1 17/7 28/22 29/3 30/3

 31/5 31/15 35/14

submitted [1] 41/25

substantive [2] 11/19 11/22

such [4] 12/14 12/17 14/24 15/4

suggesting [3] 32/7 32/8 34/5

suggestion [2] 28/17 31/2

Sunday [1] 32/14

supplied [1] 43/25

support [1] 20/12

supporting [4] 11/11 14/18 15/7 15/8

supports [4] 12/13 12/19 14/22 15/5

supposed [1] 44/7

sure [4] 5/17 14/3 16/20 41/2

suspenders [1] 5/12

sword [2] 16/3 16/7

T

tacks [1] 28/21

tactics [1] 37/6

tailored [1] 25/15

take [10] 6/18 7/2 22/2 22/20 22/24

 24/13 29/14 32/25 39/3 39/7

taken [3] 36/9 36/10 41/12

takes [1] 36/15

taking [1] 39/3

talk [2] 17/7 20/11

talking [5] 21/9 38/12 38/13 38/15 39/8

tax [4] 38/18 39/6 40/3 41/15

tell [10] 5/24 6/10 6/14 11/3 17/10 23/5

 26/24 27/3 27/5 37/2

telling [1] 18/17

tells [1] 25/19

ten [5] 4/8 4/9 38/13 39/5 44/22

tend [1] 33/18

tens [2] 20/24 21/9

terms [3] 41/12 42/19 42/24

territory [1] 17/2

testifies [2] 19/19 26/19

testify [10] 8/2 15/24 16/22 17/8 18/13

 18/19 21/25 26/22 27/5 35/16

testimony [12] 7/12 9/25 18/21 19/16

 20/15 21/23 21/24 22/25 23/17 24/14

 25/3 34/25

than [7] 10/25 15/24 19/5 21/5 24/16

 38/1 39/7

Thank [11] 3/18 7/10 14/10 26/16 36/1

 36/3 43/9 45/10 45/23 45/24 46/4

that [281] 

that's [17] 6/18 8/19 12/3 12/7 12/9

 22/16 25/7 27/6 29/1 30/2 30/15 39/1

 39/4 39/22 41/8 41/8 45/4

their [7] 18/19 18/19 23/18 34/6 38/6

 42/5 43/23

them [22] 6/9 8/3 10/19 12/4 13/16 18/7

 18/10 21/11 22/19 23/7 24/13 24/16 26/4

 31/14 32/23 36/14 37/13 40/15 42/11

 42/20 44/24 44/25

themes [1] 30/21

themselves [1] 44/18

then [34] 4/12 7/8 7/11 7/12 12/10 12/11

 14/18 14/19 14/20 15/6 15/22 16/6 18/8

 20/16 21/16 22/1 22/17 23/1 23/22 24/2

 25/7 26/2 26/18 26/23 26/24 33/4 34/17

 35/10 35/23 36/9 36/10 43/15 44/1 45/3

theory [1] 16/15

there [27] 4/13 4/13 14/12 14/12 14/16

 16/23 18/2 19/23 21/10 22/4 23/12 23/20

 24/15 25/24 26/15 28/10 28/16 35/22

 36/21 37/2 37/19 37/20 38/25 40/23

 41/20 42/2 42/23

there's [4] 4/24 5/1 24/4 39/5

thereof [1] 15/21

Thereupon [1] 2/14

these [20] 4/11 7/14 9/16 15/19 16/5

 16/5 16/14 17/3 17/17 17/21 18/3 18/12

 21/18 22/18 23/6 24/2 33/5 33/24 37/6

 39/1

they [35] 4/7 5/5 5/22 8/2 8/7 9/6 9/8

 9/17 10/19 11/10 12/22 14/18 16/15 18/4

 18/8 18/13 18/19 19/22 20/8 20/11 21/19

 22/15 23/17 23/22 24/12 24/17 28/13

 28/14 31/14 31/17 31/17 37/14 41/15

 42/4 42/5

They're [1] 28/1

thing [6] 5/12 19/3 21/1 22/7 22/23 26/2

things [5] 16/12 16/17 17/1 22/6 25/24

think [33] 4/7 4/11 5/13 6/11 9/22 9/24

 10/5 17/5 17/20 18/1 18/11 20/1 21/22

Case 1:22-cv-23074-BB Document 243-2 Entered on FLSD Docket 01/12/2024 Page 54 of 56
T

think... [20] 22/13 23/16 24/12 24/13

 25/14 25/18 26/14 28/13 29/18 31/11

 31/13 32/6 33/20 35/13 36/4 36/5 37/25

 39/5 40/20 45/14

third [1] 11/9

this [41] 3/13 6/25 7/18 13/15 13/20

 15/21 17/9 19/3 20/1 20/10 20/14 20/17

 20/25 22/6 22/7 22/9 22/22 22/24 23/3

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 25/15 25/23 26/23 26/24 28/15 29/25

 30/3 31/13 35/16 38/8 38/17 38/18 39/13

 39/13 39/15

those [24] 6/14 9/5 10/14 10/15 11/23

 14/13 15/13 15/18 16/18 17/16 17/18

 17/19 18/9 19/13 20/14 21/15 29/23

 31/24 36/19 37/14 38/14 38/19 42/8

 42/14

though [3] 30/16 32/12 45/19

thought [8] 4/19 7/2 22/9 22/23 23/12

 30/25 44/9 45/12

thousands [2] 20/24 21/9

three [10] 5/6 5/25 6/3 6/13 14/12 15/13

 16/5 16/14 29/16 36/16

through [3] 20/14 22/9 22/23

tidbit [1] 25/12

time [9] 4/14 5/20 6/18 10/19 24/7 27/24

 29/22 30/24 45/25

times [2] 20/21 42/23

tip [1] 12/15

tipped [1] 11/8

tips [18] 11/9 11/10 11/12 12/13 12/16

 12/16 14/19 14/23 14/24 14/25 15/2 15/2

 15/7 15/8 19/20 19/23 20/3 21/7

today [2] 28/18 34/2

today's [1] 45/16

together [1] 25/18

told [2] 14/17 24/3

too [4] 17/14 25/7 45/14 45/15

topic [1] 36/5

topics [5] 10/7 26/13 26/13 32/6 32/8

Torres [3] 35/24 42/16 45/15

total [2] 4/4 4/23

track [1] 31/11

traditionally [1] 11/8

TRANSCRIBED [2] 1/10 2/12

transcription [1] 46/10

translate [1] 42/11

treat [2] 23/3 36/19

tree [2] 42/15 46/2

trial [19] 13/25 16/22 21/17 21/23 21/24

 22/15 24/2 24/7 24/16 24/18 25/11 25/23

 26/19 26/22 27/3 27/6 27/8 28/8 35/18

trials [1] 14/1

true [1] 22/18

trying [7] 3/17 6/4 6/12 12/5 13/6 24/2

 30/18

Tuesday [1] 37/25

two [36] 4/3 4/16 5/7 5/11 5/12 5/15 5/18

 5/19 5/24 6/5 6/11 7/2 7/3 7/4 8/23 8/24

 9/2 9/2 14/4 14/11 20/21 22/20 25/2

 25/3 25/3 25/21 26/10 27/15 27/21 32/5

 33/3 33/7 33/10 33/12 33/23 35/21

type [2] 25/6 27/6

U

unable [1] 8/9

unbeknownst [1] 16/9

under [8] 4/7 19/11 19/11 24/19 27/4

 38/6 42/15 46/2

understand [6] 18/1 18/25 24/12 35/11

 41/22 43/17

understanding [1] 21/1

Understood [3] 43/9 45/7 45/24

Unfortunately [1] 6/8

UNITED [2] 1/1 1/11

unlawful [1] 12/15

unlawfully [6] 12/13 12/15 14/22 14/25

 15/1 15/3

Unless [1] 43/22

unnecessarily [1] 29/22

until [2] 14/15 40/24

up [12] 3/17 9/23 13/7 22/5 22/8 24/10

 25/25 26/4 26/9 27/17 28/7 30/11

upon [1] 35/10

us [9] 6/14 21/15 21/22 30/19 31/11

 35/10 39/8 43/4 44/24

use [3] 16/3 16/7 16/25

usually [1] 42/19

utilize [1] 21/24

V

VELAZQUEZ [12] 2/3 3/9 4/18 7/16

 10/21 23/5 25/19 25/22 26/14 28/21 31/4

 32/9

Velazquez's [1] 34/18

version [1] 42/9

very [6] 15/17 18/24 19/1 30/25 45/25

 46/4

via [1] 44/7

violation [2] 20/6 20/10

volunteering [1] 32/9

W

wage [3] 17/12 19/11 21/7

wait [2] 26/24 41/15

waiters [4] 4/21 17/22 18/9 25/15

waiting [3] 29/9 29/21 30/13

waived [1] 42/5

want [16] 5/12 10/11 14/3 15/9 23/6

 24/13 25/11 25/11 29/11 29/14 29/22

 35/5 40/1 40/6 41/14 42/23

wants [3] 25/19 26/23 27/3

was [44] 3/17 6/21 6/21 8/21 10/5 13/2

 13/4 13/25 13/25 16/8 16/12 18/23 18/24

 20/3 22/3 22/4 22/9 23/12 28/10 28/17

 28/17 29/3 29/11 29/18 29/20 29/24 30/1

 30/12 30/21 32/7 34/3 34/13 34/14 35/2

 37/1 38/6 38/7 39/20 40/14 40/23 41/1

 42/4 45/13 46/1

wasn't [3] 18/16 39/11 40/24

waste [2] 10/18 27/23

way [13] 4/14 5/18 7/9 13/14 23/1 23/3

 24/11 24/13 26/9 26/11 26/15 36/19 37/1

we [118] 

we'd [1] 4/8

we're [7] 7/1 7/24 8/1 8/11 9/3 24/1

 38/14

we've [2] 10/3 30/18

week [12] 15/1 15/2 21/2 28/23 29/15

 31/5 32/10 32/11 32/20 35/14 35/15 39/8

weeks [1] 21/2

well [26] 3/15 6/10 11/11 13/24 14/12

 16/11 17/18 18/7 18/23 19/4 19/6 20/20

 21/13 22/2 22/18 25/10 26/1 26/17 26/20

 31/21 31/24 32/1 36/22 38/11 42/3 44/20

went [3] 9/1 33/19 33/20

were [29] 3/2 4/20 5/5 7/22 8/9 8/20 9/2

 10/4 10/14 12/17 12/22 13/3 14/12 15/3

 17/3 19/22 23/13 29/7 29/9 29/17 29/21

 30/17 31/24 32/7 32/7 33/9 34/10 41/2

 41/2

what [67] 

whatever [5] 18/20 38/25 40/5 45/5

 45/11

when [14] 7/12 11/20 12/22 13/3 19/7

 20/1 20/11 21/9 22/10 23/24 29/11 30/7

 37/2 39/8

where [11] 8/1 8/11 10/12 11/18 15/19

 15/19 16/1 16/24 31/1 36/18 41/15

whether [4] 20/5 27/2 31/14 38/7

which [27] 4/3 9/24 12/12 12/14 14/21

 14/24 19/1 19/8 20/3 20/13 25/8 25/25

 29/10 29/24 30/3 30/22 31/16 34/2 34/21

 35/1 36/6 38/23 41/1 43/13 43/14 44/24

 44/25

while [2] 13/25 14/2

who [29] 6/3 6/11 8/6 8/20 9/5 9/14 9/18

 9/21 12/15 14/25 15/1 15/6 16/22 17/8

 19/21 19/24 24/16 26/3 26/23 27/5 27/15

 29/23 30/1 30/3 31/12 33/5 33/7 35/15

 44/13

whoever [1] 9/13

whole [10] 7/23 16/11 16/15 19/3 22/7

 22/16 22/22 23/14 34/8 37/13

wholesale [2] 10/2 10/9

whom [1] 24/15

why [11] 5/1 14/15 16/19 29/2 31/17

 33/16 34/8 34/12 34/16 41/22 43/17

will [28] 14/13 14/15 17/7 25/23 25/23

 26/7 26/15 30/20 32/4 32/25 32/25 33/1

 33/1 33/5 33/5 33/12 36/6 36/10 36/11

 36/11 36/12 42/11 42/14 43/14 43/20

 44/2 44/2 45/17

willing [1] 7/1

wine [1] 4/22

within [4] 7/3 23/23 29/12 36/7

without [3] 22/15 25/8 30/1

witness [2] 35/11 35/19

witnesses [4] 8/23 8/24 24/7 27/8

won't [3] 25/24 35/24 43/8

wondering [1] 29/2

work [14] 20/14 25/6 25/7 27/4 37/23

 38/21 39/13 40/1 40/3 40/17 40/17 41/15

 41/16 43/8

workable [1] 27/23

worked [1] 21/7

working [6] 29/8 29/16 29/17 29/20 38/3

 38/4

workweek [4] 12/14 12/18 14/24 15/4

would [34] 4/10 7/2 7/23 8/3 8/10 8/12

 8/15 9/16 9/17 10/9 10/18 11/25 13/15

 15/20 17/23 18/3 18/14 18/15 18/15 22/6

 24/15 27/2 27/7 27/13 28/25 30/13 31/14

 33/24 34/1 35/14 37/17 39/12 45/21

 45/22

wouldn't [2] 9/14 17/18

wraps [1] 24/20

written [15] 8/6 8/21 9/5 9/18 10/12

 16/25 22/3 28/5 28/25 29/3 31/8 39/24

 40/4 41/17 41/24

Y

yes [36] 4/1 5/22 7/17 8/19 14/1 14/6

 14/9 17/13 17/14 18/11 18/18 24/24

 27/11 28/3 28/19 31/3 31/6 31/9 32/15

 32/22 32/24 34/4 34/22 35/9 35/12 39/4

 39/10 39/14 42/18 42/21 42/22 42/25

 42/25 43/3 44/12 44/19

yet [7] 9/7 15/19 16/23 19/12 30/7 46/2

Case 1:22-cv-23074-BB Document 243-2 Entered on FLSD Docket 01/12/2024 Page 55 of 56
Y

yet... [1] 46/3

you [173] 

you're [10] 8/5 10/14 10/23 16/4 16/17

 28/11 30/24 37/22 39/8 41/16

you've [1] 14/17

you-all [7] 3/23 16/19 22/8 40/1 40/3

 41/14 43/8

your [98] 

Case 1:22-cv-23074-BB Document 243-2 Entered on FLSD Docket 01/12/2024 Page 56 of 56