UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

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

OCTAVIO COLLADO 

For himself and all others 

similarly situated, 

Plaintiff, 

v. 

450 NORTH RIVER DRIVE, LLC, 

D/B/A KIKI ON THE RIVER, 

RJ RIVER, LLC, AND 

ROMAN JONES, 

Defendants. 

_______________________________________/

DEFENDANTS 450 NORTH RIVER DRIVE, LLC, D/B/A KIKI ON THE RIVER, 

ROMAN JONES, AND RJ RIVER, LLC, JOINT RESPONSE IN OPPOSITION TO 

PLAINTIFF’S OBJECTION TO AND APPEAL OF THE MAGISTRATE JUDGE’S 

DISCOVERY ORDER DATED SEPTEMBER 6, 2023 

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

(“Jones”), and RJ RIVER, LLC (“RJ”) (collectively “Defendants”), by and through their 

undersigned counsel, hereby file their response in opposition to Plaintiff’s Objection to and Appeal 

of Order. [ECF No. 213]. Defendants state the following in support thereof: 

1. On September 6, 2023, Magistrate Judge Alicia M. Otazo-Reyes conducted a 

hearing on discovery issues raised by Defendants and Plaintiff, Octavio Collado (“Collado”). 

[ECF No. 204]. The hearing lasted approximately one-hour. Id. At the hearing, Magistrate Judge 

Otazo-Reyes heard the arguments of counsel, and she made rulings within her broad discretion to 

oversee discovery on each of the issues presented. On the same day as the hearing, Magistrate 

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Judge Otazo-Reyes entered her detailed written Order (“the Order”) explaining her rulings on each 

of the disputes raised by Defendants and Plaintiff. [ECF No. 203]. 

2. Plaintiff and the Opt-in Plaintiffs waived objections to Kiki’s interrogatories 

because they failed to serve timely responses and objections to the interrogatories at issue. 

3. Moreover, no rulings in the Order are clearly erroneous or contrary to the law. As 

Defendants explain in more detail below, there is legal authority supporting each of Magistrate 

Judge Otazo-Reyes’ rulings. Accordingly, the rulings cannot be clearly erroneous or contrary to 

law. Thus, Plaintiff’s objections and appeal are meritless and must be denied. 

MEMORANDUM OF LAW 

Local Rule 26.1(e)(2)(a) explains that objections to interrogatories and request for 

production must be made within the time provided by the Federal Rules. Additionally, Local Rule 

26.1(e)(2)(a) confirms that “[a]ny ground not stated in an objection within the time provided by 

the Federal Rules of Civil Procedure, or any extensions thereof, shall be waived.” Additionally, 

Courts in the Southern District of Florida have held that a failure to timely respond to discovery 

waives the objections. See Kramer Sci. Lab. Prods. Corp. v. Golf Med. Corp., No. 11-61610-CIVZLOCH, 2011 U.S. Dist. LEXIS 141485, *6-7 (S.D. Fla. Dec. 8, 2011) (stating “[h]ere, it is 

beyond dispute that Defendant failed to file objections to the interrogatories and production 

requests in a timely manner . . . . Accordingly, Defendant is ordered to provide complete responses 

to the production requests and interrogatories[.]”). 

Moreover, to alter a magistrate judge’s order on discovery the “appealing parties . . . bear 

the heavy burden of showing that the orders are ‘clearly erroneous or contrary to law.’” Doe v. 

Lynn Univ., Inc., No. 9:16-CV-80850-ROSENBERG/BRANNON, 2017 U.S. Dist. LEXIS 7528, 

*2-3 (S.D. Fla. Jan. 19, 2017) (emphasis added) (quoting 28 U.S.C. § 636(b)(1)(A). Additionally, 

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“[i]t is extremely difficult to justify alteration of the magistrate judge’s non-dispositive action 

. . . because clear error is a highly deferential standard of review.” Id. (emphasis added) (internal 

quotation marks omitted) (citing Holton v. City Thomasville School Dist., 425 F. 3d 1325, 1350 

(11th Cir. 2005) and 12 Wright, Miller and Marcus, Federal Practice and Procedure Civ. 2d § 

309). 

Generally, an order is considered clearly erroneous when “although there is evidence to 

support it, the reviewing court on the entire evidence is left with the definite and firm conviction 

that a mistake has been committed.” Doe, 2017 U.S. Dist. LEXIS 7528, *3-4 (quoting Holton, 

425 F. 3d at 1350) (emphasis added). An order may be deemed contrary to law only “where it 

fails to apply or misapplies relevant statutes, case law or rules of procedure.” Doe, 2017 U.S. Dist. 

LEXIS 7528, *4. Here, Plaintiff has not identified any issues with Magistrate Judge Otazo-Reyes’ 

Order that are clearly erroneous or contrary to law. 

A. Plaintiff Waived all Objections to Defendants Interrogatories 

Plaintiff failed to properly and timely serve any objections to the interrogatories served on 

him and the Opt-In Plaintiffs. Kiki served its first set of interrogatories on Plaintiff and the OptIn Plaintiffs on June 16, 2023. Plaintiff’s counsel subsequently advised that Plaintiff was going to 

pursue a protective order seeking representative discovery but never filed such a motion or served 

formal answers or objections to the interrogatories served June 16, 2023. Thereafter, Kiki 

voluntarily reduced the number of interrogatories from twenty-five to five substantive 

interrogatories to address Plaintiff’s concerns regarding the individualized responses and to avoid 

seeking Court intervention. The reduced interrogatories were served on July 10, 2023, and the 

five interrogatories were selected from the original twenty-five that were previously served. As 

previously noted, the hearing on Kiki’s motion to compel occurred on September 6, 2023, without 

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Plaintiff serving any responses or objections to the original interrogatories or the subsequently 

served reduced interrogatories. Kiki noted and preserved its position that Plaintiff had waived 

objections to its interrogatories because of his failure to timely respond or object to the 

interrogatories. Plaintiff finally served untimely responses and objections to the reduced 

interrogatories on September 22, 2023, which is seventy-four days after they were served.1 

Accordingly, Plaintiff and the Opt-in Plaintiffs waived objections to Kiki’s interrogatories, 

and they should be directed to comply with Magistrate Judge Otazo-Reyes’ well-reasoned order. 

See Kramer Sci. Lab. Prods. Corp., 2011 U.S. Dist. LEXIS 141485, at *6-7 (defendant ordered to 

provide complete responses to interrogatories and request for production because of failure to 

timely serve objections). 

B. Plaintiffs Must Individually Respond to the Three Interrogatories as Ordered 

by Magistrate Judge Otazo-Reyes 

Contrary to Plaintiff’s claims, Magistrate Judge Otazo-Reyes was well within her authority 

and discretion to require Plaintiff and each Opt-in Plaintiff to answer the two substantive 

interrogatories2 because discovery in FLSA conditional certification cases is not limited to 

representative discovery. See Hernandez v. Starbucks Coffee Co. No. 0:09-cv-60073-WPD, 2010 

U.S. Dist. LEXIS 151766, *1-17 (S.D. Fla. Apr. 23, 2010) (individual discovery permitted in an 

FLSA conditional collective action). In fact, courts in the Southern District of Florida allow 

defendants to conduct individual discovery when a case is pending as a conditional collective 

1

 Plaintiff’s disregard of the Court’s local rules and the Federal Rules of Civil Procedure is 

particularly egregious and disturbing in this case considering Defendants have produced thousands 

of documents and their answers to Plaintiff’s interrogatories while Plaintiff served untimely 

objections and has not answered a single interrogatory or produced a single document responsive 

to Kiki’s request to produce. 

 

2

 The third interrogatory requiring an individualized response is number 1, which only requests 

the responding party to provide identifying information. 

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action pursuant to 29 U.S.C. § 216(b) because (1) the opt-in plaintiffs are active participants in the 

litigation who elected to join the lawsuit and (2) defendants need the individualized information 

to develop defenses to move to decertify the putative collective. Id.; Kerschman v. Nationwide 

Relocation Servs. No. 10-62426-DIMITROULEAS/Snow, 2012 U.S. Dist. LEXIS 203381, (S.D. 

Fla. May 7, 2012) (“In this district it appears that the Defendants are entitled to at least some 

individualized discovery to determine whether or not the plaintiffs are similarly situated as was 

permitted in both Kaas and Hernandez.”); see also Daniel v. Quail Int’l, Inc., No. 2:07-CV-53, 

2010 U.S. Dist. LEXIS 294 (M.D. GA Jan. 5, 2010) (stating “the Court concludes that 

individualized discovery of the Plaintiff class members is permissible in this action. Plaintiffs' 

Motion for Representative Discovery (Doc. 50) is therefore denied.”). 

In Hernandez, the Southern District of Florida court required the opt-in plaintiffs in a 

Section 216(b) collective action to provide individual discovery responses to the defendant’s 

written discovery requests. 2010 U.S. Dist. LEXIS 151766, at *10-11. The defendant served 

plaintiff with a set of discovery requests that included three (3) interrogatories and four (4) requests 

for production. The defendant argued, and the court agreed, that it needed individual discovery to 

determine if managers were properly classified. The defendant explained that since it was a 

Section 216(b) collective, rather than a Rule 23 class, “the opt-in plaintiffs are active participants 

in the litigation.” Id. The court agreed with the defendant and required each opt-in plaintiff to 

answer the interrogatories that were individualized in nature. 

Similarly, in Kerschman, the Southern District of Florida court permitted the defendant to 

conduct limited individual discovery in a collective action. 2012 U.S. Dist. LEXIS 203381 at *16-

17. The court noted that in the Southern District “it appears that the Defendants are entitled to at 

least some individualized discovery to determine whether or not the plaintiffs are similarly 

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situated” and that its “also proper for Defendants to seek information that could disprove the 

Plaintiff’s claims, as well as information that would assist in damages calculations or support 

a motion to decertify the class.” Id. (emphasis added). Therefore, the court allowed the 

defendant to obtain answers to specific interrogatories that were individualized in nature. Id.

Here, Magistrate Judge Otazo-Reyes’ rational and ruling is consistent with the analysis and 

rulings in Hernandez and Kerschman for the following reasons: 

1. Defendants need the individualized information regarding alleged damages pertaining 

to the tips and minimum wages purportedly owed to develop defenses and possibly 

move to decertify the putative collective.3 The defenses applicable to the requested 

damages information in interrogatory number 5 pertains to whether tips were withheld 

or taken from each plaintiff, as alleged, and if so, what amount of the allegedly withheld 

or taken tips belongs to each plaintiff. Similarly, the defenses applicable to the 

requested damages information in interrogatory number 6 pertains to whether each 

plaintiff was not paid minimum wage, as alleged, after adding the direct wage and 

commissions they were paid, and if so, what amount each plaintiff is purportedly owed 

in minimum wages. 

2. Representative discovery to determine the alleged tip and minimum wage damages is 

prejudicial to Defendants. For example, requiring Defendants to pay a speculative 

amount of damages to distribute among the conditionally certified class assumes 

improperly that each plaintiff is owed the same amount in tips and minimum wages. 

In other words, because one class member claims they are owed $10,000 in tips and 

minimum wages does not mean every class member is owed the same amount. Such 

an assumption is flawed because it is very likely that some, if not all the class members 

received the tips they were entitled to receive and/or were paid at least minimum wage 

during their entire employment. Such class members should not be rewarded because 

some other members claim they did not receive all their tips and/or were not paid 

minimum wage. Also, Plaintiff’s proposed representational discovery pertaining to tips 

and minimum wage exposes Defendants to grossly inflated damages for the entire 

conditional class based on the interrogatory answers of a handful of class members. 

3. Kiki served the plaintiffs with only five substantive interrogatories and Magistrate 

Judge Otazo-Reyes reviewed those interrogatories and Kiki’s argument, and correctly 

ordered individualized answers to interrogatories 5 and 6 because they requested 

specific information related to the defenses pertaining to each plaintiff’s alleged 

damages regarding the tips and minimum wages purportedly owed. 

3

 Significantly, the order allows representative answers for the remaining interrogatories (2-4).

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4. The opt-in plaintiffs in this case are active participants in the litigation that elected to 

join the lawsuit. 

Therefore, Magistrate Judge Otazo-Reyes’ ruling was not clearly erroneous or contrary to law as 

reflected by the above and the holdings in Hernandez and Kerschman. 

Moreover, Plaintiff’s appeal presents arguments that are misplaced and fail to establish that 

Magistrate Judge Otazo-Reyes’ ruling is clearly erroneous or contrary to law as it relates to the 

limited individualized damages discovery. In sum, the appeal tries, but fails to establish that 

discovery in FLSA conditional certification cases is limited to representative discovery. 

First, the appeal falls short of establishing a “definite and firm conviction that a mistake 

has been committed” by Magistrate Judge Otazo-Reyes and/or that the ruling “fails to apply or 

misapplies relevant statutes, case law or rules of procedure.” Doe, 2017 U.S. Dist. LEXIS 7528, 

*3-4 (quoting Holton, 425 F. 3d at 1350). The Hernandez and Kerschman opinions out of the 

Southern District of Florida entirely undermine Plaintiff’s efforts on these issues. 

Second, interrogatory number 5, which only seeks information regarding tip damages, does 

not require individual answers pertaining interrogatory number 4, which predominantly focuses 

on obtaining information as to when and who unlawfully distributed and received tips, and 

documents supporting those allegations. Moreover, Magistrate Judge Otazo-Reyes’ order does 

not direct individualized responses to interrogatory number 4. 

Third, as established above, the benefit to Defendants of obtaining individualized answers 

to the interrogatories pertaining to tip and minimum wage damages outweighs any alleged burden 

or expense Plaintiff claims. Moreover, Plaintiff’s counsel exaggerates the time necessary to 

answer interrogatories 5 and 6. As an initial matter, he includes interrogatory number 1 in the 

calculation when it merely seeks information identifying the person answering interrogatories 5 

and 6. Additionally, the process of obtaining the court ordered damages information is 

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administrative in nature and can be handled by legal assistants or paralegals. Lastly, if Plaintiff’s 

counsel does not have the capacity to handle class action cases, he should not take them and his 

inability to handle the rigors of a class case cannot be allowed to interfere or prevent Defendants’ 

legitimate discovery needs. 

Fourth, individualized answers to interrogatories 5 and 6 are not cumulative and duplicative 

of responses that would be provided on a representative basis. As previously argued and necessary 

to restate to address Plaintiff’s theory, because one class member claims they are owed $10,000 in 

tips and minimum wages does not mean every class member is owed the same amount. Such an 

assumption is prejudicial to Defendants because it will result class members receiving more than 

they are entitled to receive in the form of tips and/or minimum wages if a violation if found, and 

subjects Defendants to grossly inflated damages for the entire conditional class based on the 

interrogatory answers of a handful of class members. 

Finally, the cases Plaintiff cites are too general and inapplicable to the particular individual 

discovery ordered in this case pertaining to tip and minimum wage damages. See Donovan v. New 

Floridian Hotel, Inc., 676 F.2d 468, 472 (11th Cir. 1982) (representative discovery issue pertained 

to prima facie case and not amount of damages claimed); Grochowski v. Phoenix Construction, 

318 F.3d 80, 88 (2d Cir. 2003) (representative discovery issue pertained to number of hours 

plaintiffs worked and not amount of damages claimed); Reich v. Southern New England Telecomm. 

Corp., 121 F.3d 58, 67 (2d Cir. 1997) (representative discovery issue pertained to prima facie case 

and not amount of damages claimed); Tyson Foods, Inc., v. Bouaphakeo, 577 U.S. 442 (2016) 

(representative discovery issue pertained to establishing liability and not amount of damages 

claimed). 

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C. Defendants’ Objections to Plaintiff’s Request for Production Nos. 15 

and 16 were Properly Sustained 

Pursuant to Federal Rule of Civil Procedure 34, a party is permitted to “inspect, copy, test, 

or sample . . . items in the responding party’s possession, custody, or control.” Fed. R. Civ. P. 34. 

Critically, “[t]he burden is on the party seeking discovery to establish that the opposing party has 

‘control’ over documents held by an affiliate.” Wright v. Daniel Bluman and Daniel Bluman, LLC, 

No. 20-81688-Civ-Reinhart, 2021 U.S. Dist. LEXIS 260059, *5-6 (S.D. Fla. June 8, 2021) 

(quoting Seakrock v. Stripling, 736 F.2d 650 653 (11th Cir. 1984)). Control is not limited to 

physical possession of records, and it includes the legal right to obtain documents upon command. 

Wright, 2021 U.S. Dist. LEXIS 260059, at *6. Determining if a party has control over records that 

are not in its possession is a highly factual inquiry. Id. 

Notably, in Wright, the Southern District of Florida explained that a defendant did not have 

control over text messages and WhatApp communications that were on a phone that was given to 

the defendant’s family caretaker. Id. There, the plaintiff sought a forensic examination of text 

messages and WhatsApp communications on cell phones that were used by the defendant. Id. at 

3-4. The defendant explained that the Samsung Galaxy that plaintiff sought to examine was not 

in his possession, custody, or control because it was gifted to the family caretaker prior to the start 

of the litigation. Id. As the defendant did not have the legal right to obtain the cell phone from 

the caretaker on demand, the court held it was not in the defendant’s possession, custody, or 

control. Id. at 6. 

Like the defendant in Wright, Defendants in this case do not have possession, custody, or 

control over the WhatsApp communications Plaintiff is requesting in Request for Production Nos. 

15 and 16. Defendants do not have possession, custody, or control over these records because the 

WhatsApp chats would be saved to employees’ personal cell phones, if they exist at all, which 

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Defendants do not have the legal right to obtain upon command. Further, there is no factual record 

evidence that Plaintiff can rely on to establish that Defendants have the legal authority to obtain 

these records on command. Therefore, Magistrate Judge Otazo-Reyes’ ruling was not clearly 

erroneous or contrary to law. 

Further, the cases Plaintiff cites do not establish that Magistrate Judge Otazo-Reyes’ 

current order is clearly erroneous or contrary to law. At most, the cases may suggest that 

Magistrate Judge Otazo-Reyes had discretion to order Defendants to ask Kiki’s employees to 

search their personal electronic devices and produce responsive documents. See Matter of Skanska 

USA Civil Se. Inc., No. 3:20-CV-05980-LC/HTC, 2021 U.S. Dist. LEXIS 208691, *4 (N.D. Fla. 

Aug. 5, 2021). However, Magistrate Judge Otazo-Reyes cannot rule on an argument that was not 

presented during the hearing. And, even if we assume for discussion purposes that Plaintiff raised 

the argument, which he did not, Magistrate Judge Otazo-Reyes’ ruling sustaining Defendants’ 

objection does not rise to the level of a “definite and firm conviction that a mistake has been 

committed” and/or that the ruling “fails to apply or misapplies relevant statutes, case law or rules 

of procedure.” Doe, 2017 U.S. Dist. LEXIS 7528, *3-4 (quoting Holton, 425 F. 3d at 1350). 

To the extent Plaintiff claims Defendants should be required to download and export its 

employees’ WhatsApp communications, there is no basis in law for that claim. Plaintiff seemingly 

cites to Matter of Skanska USA Civil Se. Inc., No. 3:20-CV-05980-LC/HTC, 2021 U.S. Dist. 

LEXIS 208691, *4 (N.D. Fla. Aug. 5, 2021) to try to support his proposition that Defendants 

should be required to download and export its employees’ WhatsApp chats and produce the 

records. However, in Matter of Skanska USA Civil Se. Inc., the court explains there was no 

obligation for the defendant to “extract and review all of the cell phone data” on its employee’s 

personal cell phone because “courts have only required the employer to ask the employee to search 

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and produce the responsive information.” Id. at *37-38. Therefore, assuming arguendo that the 

Court overrules Magistrate Judge Otazo-Reyes’ Order, Plaintiff’s suggestion that the Court require 

Defendants to obtain each employees’ cell phone, download its contents, and extract the data is 

improper and would be contrary to law. 

CONCLUSION 

For the foregoing reasons, Defendants, 450 North River Drive, LLC, d/b/a Kiki on the 

River, RJ River LLC, and Roman Jones, respectfully requests that this Honorable Court enter an 

order: (1) denying Plaintiff’s Objection to and Appeal of Order [ECF No. 203] and (2) granting 

such other and further relief as this Court deems just and proper. 

Dated: October 5, 2023 

Respectfully submitted, 

JACKSON LEWIS P.C. LEVINE & PARTNERS, P.A. 

One Biscayne Tower, Suite 3500 3350 Mary Street 

Two South Biscayne Boulevard Miami, Florida 33133 

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

Telephone: (305) 577-7600 

/s/ Reynaldo Velazquez /s/ Allan Reiss 

Reynaldo Velazquez, Esq. Allan Reiss, Esq 

Florida Bar No.: 069779 Florida Bar No. 858500 

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

Roman Sarangoulis, Esq. 

Florida Bar No. 1011944 Counsel for RJ River, LLC

Email: roman.sarangoulis@jacksonlewis.com 

Counsel for 450 North River Drive, LLC, 

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

CERTIFICATE OF SERVICE 

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

October 5, 2023, on all counsel of record on the Service List below via transmission of Notices of 

Electronic Filing generated by CM/ECF. 

s/ Roman Sarangoulis 

Roman Sarangoulis, Esq. 

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SERVICE LIST 

Brian Pollock, Esq. 

Florida Bar No. 174742 

Email: brian@fairlawattorney.com 

FAIRLAW FIRM 

135 San Lorenzo Ave. 

Coral Gables, Florida 33146 

Telephone: (305) 230-4884 

Attorneys for Plaintiff 

Reynaldo Velazquez, Esq. 

Florida Bar No.: 069779 

Email: rey.velazquez@jacksonlewis.com 

Roman Sarangoulis, Esq. 

Florida Bar No. 1011944 

Email: roman.sarangoulis@jacksonlewis.com

JACKSON LEWIS P.C. 

One Biscayne Tower 

2 South Biscayne Boulevard, Suite 3500 

Miami, Florida 33131 

Telephone: (305) 577-7600 

Counsel for 450 North River Drive, LLC, Kiki on 

the River and Roman Jones

Allan Reiss, Esq. 

Florida Bar No. 858500 

Email: Asr@Levinelawfirm.com 

LEVINE & PARTNERS, P.A. 

3350 Mary Street 

Miami, Florida 33133 

Telephone: (305) 372-1352 

Attorneys for RJ River, LLC

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