135	San	Lorenzo	Avenue,	Suite	770,	Coral	Gables,	FL	33156

TEL 305.230.4884			FAX 305.230.4844

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

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

OCTAVIO COLLADO,

Plaintiff, COLLECTIVE ACTION

vs.

450 NORTH RIVER DRIVE, LLC,

D/B/A KIKI ON THE RIVER, 

RJ RIVER, LLC AND 

ROMAN JONES,

Defendants.

______________________________/

NOTICE OF DISCOVERY HEARING

Plaintiff, Octavio Collado, and Defendants, 450 North River Drive, LLC d/b/a Kiki on 

the River, RJ River, LLC, and Roman Jones, notice the Court and all parties of the discovery 

hearing scheduled before Magistrate Judge Alicia M. Otazo-Reyes at 10:30 a.m. on September

6, 2023, by Zoom (instructions to be provided by the Court) on the following issue(s):

A. Defendants’ Responses to Requests for Production.

The parties conducted multiple and extensive conferrals regarding the Requests for 

Production served on Defendants, and the following issues remain:

RFP No. 4 (Plaintiff agreed to limit his request to responsive documents relating to tips, 

wages, service charges, and distributing tips.)

RFP No. 6 (Plaintiff agreed to limit his request to responsive documents relating to the 

POS, tips, overtips, cash tips, reporting tips, collecting tips, distributing tips, resolving disputes 

regarding tips and wages, tip pooling, and service charge.)

Case 1:22-cv-23074-BB Document 200 Entered on FLSD Docket 09/05/2023 Page 1 of 3
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RFP No. 10

RFP No. 11 (Plaintiff explained that the terms “business structure of Defendants,” 

“business structure,” and “the business” refer to LLC members, persons who own and operate 

Kiki accounts receivables, accounts payable, payrolls, and recruit, hire, furnish, or evaluate workers 

for Kiki)

RFP Nos. 15 and 16

RFP Nos. 18, 19, 20 – production of the responsive materials in native digital format (as 

an export)

RFP No. 21

RFP Nos. 22 and 29 (Defendant, 450 North River Drive, LLC indicated that responsive 

documents existed but no longer exist, and so the circumstances of same should be provided)

RFP Nos. 24 and 28

RFP No. 39

B. Defendant’s Discovery to Plaintiff and Opt-In Plaintiffs

Defendant, 450 North River Drive, LLC d/b/a Kiki on the River, propounded its 

“Requests for Production to Plaintiff and Opt-In Plaintiffs” and its “First Set of Interrogatories to 

Plaintiff and Opt-In Plaintiffs.”

Plaintiff advised the Defendant that it was improper to propound discovery to each of the 

Opt-In Plaintiffs, as doing so would create thousands of discovery requests to each Opt-In Plaintiff.

In an effort to resolve the issue raised by Plaintiff and without waiving their right to obtain 

responses to the originally served request to produce and interrogatories, Defendant proposed 

limiting the discovery to five Request for Production and five Interrogatories to each Opt-In 

Plaintiff, but Plaintiff still maintains that propounding discovery to each Opt-In Plaintiff is 

Case 1:22-cv-23074-BB Document 200 Entered on FLSD Docket 09/05/2023 Page 2 of 3
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improper, would result in hundreds of discovery requests, and that discovery can be accomplished 

through limited discovery to one representative from each category of employee who joined 

(servers, captains, bottle servers, food runners, bussers, and barbacks).

If the parties resolve any issues surrounding the discovery identified above, they will advise 

the Court.

Respectfully submitted this 6th day of August 2023,

s/Brian H. Pollock, Esq.

Brian H. Pollock, Esq. (174742)

Brian@fairlawattorney.com

FAIRLAW FIRM

135 San Lorenzo Avenue

Suite 770

Coral Gables, FL 33146

Tel: 305.230.4884

Counsel for Plaintiff

s/Allan S. Reiss, Esq.

Allan S. Reiss (858500)

Asr@levinelawfirm.com

Levine & Partners, P.A.

3350 Mary Street

Miami, FL 33133

Tel: 305.372.13.50

Fax: 305.372.1352

Counsel for RJ River, LLC

s/ Reynaldo Velazquez 

Reynaldo Velazquez, Esq. 

Florida Bar No.: 069779 

Email: rey.velazquez@jacksonlewis.com

Roman Sarangoulis, Esq.

Florida Bar No.: 1011944 

Email: roman.sarangoulis@jacksonlewis.com

JACKSON LEWIS P.C. 

One Biscayne Tower, Suite 3500 

Two South Biscayne Boulevard 

Miami, Florida 33131 

Telephone: (305) 577-7600 

Counsel for 450 North River Drive, LLC d/b/a 

Kiki On The River and Roman Jones

Case 1:22-cv-23074-BB Document 200 Entered on FLSD Docket 09/05/2023 Page 3 of 3