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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.

_____________________________________ / 

COURT NOTICE

This is a Court-Authorized Notice. This is not a solicitation from a lawyer. 

IF YOU ARE OR IF YOU WERE WORKING AS A FRONT-OF-THE-HOUSE 

TIPPED EMPLOYEE AT KIKI ON THE RIVER BETWEEN JUNE 7, 2020, AND 

THE PRESENT, AND BELIEVE YOU RECEIVED SOME BUT NOT ALL THE 

TIPS YOU EARNED, THEN THIS COLLECTIVE ACTION LAWSUIT MAY 

AFFECT YOUR RIGHTS.

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

the River, RJ River, LLC, and Roman Jones (collectively “Kiki on the River”), in federal 

court in Miami, Florida, alleging that he and the other similarly situated front-of-thehouse tipped employees (such as captains, servers, bottle servers, bussers, food runners, 

bartenders, barbacks, hosts, hostesses, and dockmasters) were not paid all the tips they 

earned in violation of the Fair Labor Standards Act. The case name is Octavio Collado v. 

450 North River Drive, LLC, RJ River, LLC, and Roman Jones. The Case is pending in 

the Southern District of Florida with Case Number 1:22-CV-23074-BLOOM/OTAZOREYES. 

The Defendants deny Mr. Collado’s claims and contend that they acted lawfully and did 

not improperly retain or distribute any tips.

The Court has not decided whether Mr. Collado or the Defendants are correct. There is 

no money available now and no guarantees there will be any money available to you. You 

have a choice about whether you want to join this lawsuit and assert your legal rights in 

this case. 

Case 1:22-cv-23074-BB Document 168-1 Entered on FLSD Docket 07/21/2023 Page 1 of 3
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YOUR LEGAL RIGHTS AND OPTIONS IN THIS LAWSUIT

RETURN YOUR CONSENT 

FORM BEFORE 

SEPTEMBER 22, 2023

Be a part of this lawsuit.

By timely returning the Consent Form, you 

become a party plaintiff to this lawsuit against 

Kiki on the River, whether the outcome is 

favorable or unfavorable. By joining, you gain 

the possibility of receiving the tips you claim 

are owed to you if they are recovered after a 

trial or settlement, but you give up your right 

to separately sue Kiki on the River for any

claims made in this lawsuit. 

DO NOTHING

You will not be a part of this lawsuit.

If you do decide not to timely return the 

Consent Form or otherwise fail to do so, you 

will not participate in this lawsuit and if money 

is recovered, you will not share in it. But you 

will keep any rights to sue Defendants for any 

claims alleged in this lawsuit. 

NOTICE OF RIGHT TO JOIN LAWSUIT

If you choose to join this lawsuit, you may select your own separate counsel to represent you or 

you can choose to be represented by the FairLaw Firm, which represents Octavio Collado and the 

other people who already joined the lawsuit.

It is a violation of federal law for the Defendants to fire, discipline, or in any manner discriminate 

or retaliate against you for taking part in this case. If you believe that you have been penalized, 

discriminated against, or disciplined in any way due to your receiving this notification, considering 

whether to join this lawsuit, or joining this lawsuit, you may contact any lawyer of your choosing.

ATTORNEY FEES

Mr. Collado entered into a contingency fee agreement with the FairLaw Firm, which means that if 

he does not win, Plaintiff’s counsel will not charge him for any attorneys’ fees or costs. A copy of 

the contingency fee agreement executed by the named Plaintiff may be obtained upon request from 

the FairLaw Firm. If there is a monetary recovery or settlement, the Court will approve the amount 

of the attorney fees and costs the FairLaw Firm receives.

To join the lawsuit, you must complete the “Consent to Join Pursuant to 29 U.S.C. § 216(b)” form 

and send it to FairLaw Firm by mail, fax, or email on or before September 22, 2023. 

Case 1:22-cv-23074-BB Document 168-1 Entered on FLSD Docket 07/21/2023 Page 2 of 3
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Representative Plaintiff’s Counsel: 

Brian H. Pollock, Esq. 

FairLaw Firm 

135 San Lorenzo Avenue 

Suite 770 

Coral Gables, FL 33156 

Tel: (305) 230-4884 

Fax: (305) 230-4844 

brian@fairlawattorney.com 

www.fairlawattorney.com 

Case 1:22-cv-23074-BB Document 168-1 Entered on FLSD Docket 07/21/2023 Page 3 of 3