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’S UNOPPOSED MOTION FOR EXTENSION 

OF TIME TO RESPOND TO PLAINTIFF’S RENEWED MOTION FOR 

CONDITIONAL CERTIFICATION OF A COLLECTIVE ACTION

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

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

undersigned counsel and pursuant to the Federal Rules of Civil Procedure, hereby file their

Unopposed Motion for Extension of Time to Respond to Plaintiff Octavio Collado’s (“Plaintiff”)

Motion for Conditional Certification of a Collective Action, and in support states as follows: 

1. On December 7, 2022, Plaintiff filed his Amended Complaint asserting claims for 

the recovery of tips/overtips and minimum wage violations. The Amended Complaint included 

three discrete causes of action asserting claims pursuant to the Fair Labor Standards Act, Florida 

Minimum Wage Act, and Florida common law. 

Case 1:22-cv-23074-BB Document 78 Entered on FLSD Docket 02/10/2023 Page 1 of 5
CASE NO.: 1:22-CV-23074-BLOOM/OTAZO-REYES

2

2. On December 19, 2022, Plaintiff filed his Motion for Conditional Certification of 

a Collective Action (the “Motion”), which requests the court conditionally certify Count I, titled 

Violation(s) of the Fair Labor Standards Act, as a collective action, and appoint him as the 

representative. [E.C.F. No. 44]. 

3. On January 17, 2023, Defendants filed their Joint Response in Opposition to 

Plaintiff’s Motion for Conditional Certification of a Collective Action. [E.C.F. No. 62].

4. On January 27, 2023, Plaintiff filed a Renewed Motion for Conditional 

Certification of a Collective Action (the “Renewed Motion”). 

5. Therefore, Defendants’ deadline to respond to the Renewed Motion is February 10, 

2023. 

6. Defendants are in the process of preparing their response to the Renewed Motion, 

and undersigned counsel has been working diligently to complete the response. 

7. However, despite its diligent efforts Defendants have been unable to complete their 

response within the short 14-day period it was allotted per the Local Rules. 

8. In accordance with Local Rule 7.1, undersigned counsel conferred with Plaintiff’s 

counsel on February 10, 2023, and requested a brief one-week extension of time through February

17, 2023, to respond to the Renewed Motion. Plaintiff’s counsel confirmed that he does not have 

any objections to the requested extension.

9. In addition, Defendants have agreed to toll the statute of limitations for the Plaintiff 

to identify potential plaintiffs by a corresponding 7 days in order to alleviate any potential 

prejudice related to the requested relief. 

Case 1:22-cv-23074-BB Document 78 Entered on FLSD Docket 02/10/2023 Page 2 of 5
CASE NO.: 1:22-CV-23074-BLOOM/OTAZO-REYES

3

10. Accordingly, Defendants Kiki, Jones, and RJ River requests this Court provide it 

with an extension of time up to and including February 17, 2023, to file a response to the Renewed 

Motion for Conditional Certification of a Collective Action. 

11. This is the first requested extension by Defendants to respond to the Renewed 

Motion for Conditional Certification of a Collective Action.

12. The requested extension is requested in good faith and will not prejudice any party 

to this action or impede the preparation of this case. 

WHEREFORE, Defendants 450 North River Drive, LLC, d/b/z Kiki on the River, Roman 

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

450 North River Drive, LLC, d/b/a Kiki on the River, and Roman Jones’ Unopposed Motion for 

Extension of Time to Respond to the Motion for Conditional Certification of a Collective Action

extending the time in which the Defendants have to respond to the Motion to February 17, 2023, 

while also granting any such other further relief the Court deems just and appropriate under the 

circumstances.

CERTIFICATE OF GOOD FAITH

Defendants hereby certify that movant has conferred with Plaintiff’s counsel regarding the 

matters set forth in this Motion. Plaintiff has no objection to the relief sought herein.

Dated: February 10, 2023

Case 1:22-cv-23074-BB Document 78 Entered on FLSD Docket 02/10/2023 Page 3 of 5
CASE NO.: 1:22-CV-23074-BLOOM/OTAZO-REYES

4

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. Counsel for RJ River, LLC

Florida Bar No. 1011944

Email: roman.sarangoulis@jacksonlewis.com

Counsel for 450 North River Drive, LLC, 

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

CERTIFICATE OF SERVICE

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

February 10, 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.

Case 1:22-cv-23074-BB Document 78 Entered on FLSD Docket 02/10/2023 Page 4 of 5
CASE NO.: 1:22-CV-23074-BLOOM/OTAZO-REYES

5

SERVICE LIST

Brian Pollock, Esq.

Florida Bar No. 174742

Email: brian@fairlawattorney.com

FAIRLAW FIRM

135 San Lorenzo Ave.

Coral Gables, Florida 33146

Telephone: (305) 230-4884

Attorneys for Plaintiff

Reynaldo Velazquez, Esq.

Florida Bar No.: 069779

Email: rey.velazquez@jacksonlewis.com

Roman Sarangoulis, Esq.

Florida Bar No. 1011944

Email: roman.sarangoulis@jacksonlewis.com

JACKSON LEWIS P.C.

One Biscayne Tower

2 South Biscayne Boulevard, Suite 3500

Miami, Florida 33131

Telephone: 305-577-7600

Facsimile: 305-373-4466

Counsel for 450 North River Drive, LLC, Kiki on 

the River

Allan Reiss, Esq.

Florida Bar No. 858500

Email: Asr@Levinelawfirm.com

Levine & Partners, P.A.

3350 Mary Street

Miami, Florida 33133

Telephone: (305) 372-1352

Facsimile: (305) 372-1352

Attorneys for RJ River, LLC

4890-0587-0160, v. 1

Case 1:22-cv-23074-BB Document 78 Entered on FLSD Docket 02/10/2023 Page 5 of 5