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. 

_______________________________________/

COLLECTIVE ACTION

DEFENDANTS’AGREED MOTION FOR EXTENSION OF TIME TO RESPOND TO 

PLAINTIFF’S MOTION FOR CLASS CERTIFICATION PURSUANT TO RULE 23 

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

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

Motion for Class Certification Pursuant to Rule 23(B)(3), and in support states as follows: 

1. On July 19, 2023, Plaintiff filed his Motion for Class Certification Pursuant to Rule 

23(B)(3) (the “Motion”). 

2. Currently, Defendants’ deadline to respond to the Motion is August 2, 2023. 

3. Notably, Reynaldo Velazquez, Esq., lead counsel for Kiki and Jones, was out of the 

office and on vacation from July 20-23, 2023. 

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4. Upon Mr. Velazquez’s return to the office on July 24, 2023, he had several workrelated matters to address before he was able to begin reviewing the Motion, which included, 

among other matters, preparation for a mediation on July 27, 2023, pertaining to a workers 

compensation retaliation claim and a position statement that was due July 26, 2023 (EEOC 

conveyed an extension will not be granted). 

5. Mr. Velazquez commenced analyzing the Motion today, July 27, 2023, to assess 

and formulate the strategy to begin preparing the response to the Motion. As a result, Defendants’ 

counsels were delayed approximately one week in their ability to jointly analyze and strategize 

regarding their response to the Motion, which is approximately 17 pages in length. 

6. Although Defendants will work diligently in completing their response, they 

foresee their inability to meet the current due date of August 2, 2023. 

7. As a result of the forgoing, and additional work-related responsibilities moving 

forward, Defendants respectfully request a one-week extension of time to file their response to the 

Motion, which will afford them the time lost because of Mr. Velazquez’s vacation and the workrelated matters that had to be addressed before he had an opportunity to review the Motion. 

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

counsel on July 27, 2023, and requested a one-week extension of time through August 9, 2023, to 

respond to the Motion. Plaintiff’s counsel confirmed that he does not have any objections to the 

requested extension. 

9. Accordingly, Defendants Kiki, Jones, and RJ River respectfully request this Court 

grant them an extension of time up to and including August 9, 2023, to file a response to the Motion 

for Class Certification Pursuant to Rule 23(B)(3). 

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10. This is the first requested extension by Defendants to respond to the Motion for 

Class Certification Pursuant to Rule 23(B)(3). 

11. 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 request that this Honorable Court enter an Order granting 

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

Extension of Time to Respond to the Motion for Class Certification Pursuant to Rule 23(B)(3) 

extending the time in which the Defendants have to respond to the Motion to August 9, 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: July 27, 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/ Roman Sarangoulis /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 

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CERTIFICATE OF SERVICE 

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

July 27, 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. 

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, 

d/b/a 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 

Facsimile: (305) 372-1352 

Attorneys for RJ River, LLC 

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