UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

FT. LAUDERDALE DIVISION

Case No.: 0:22cv62090

CHRISTOPHER ALLEN ROLDAN, 

Individuals,

Plaintiffs,

v.

CORAL SPRINGS HONDA

d/b/a PAGE BROTHERS ASSOCIATES, INC. 

A Florida Corporation,

Defendant.

______________________________/

DECLARATION OF ATTORNEY JOSHUA FEYGIN

BEFORE ME, personally appeared Attorney JOSHUA E. FEYGIN, who 

being first dully sworn deposes and states as follows:

1. The undersigned represents Plaintiff, CHRISTOPHER ALLEN 

ROLDAN (hereinafter “Mr. Roldan” or “Plaintiff”), in “CHRISTOPHER ALLEN 

ROLDAN, an individual v. CORAL SPRINGS HONDA d/b/a PAGE BROTHERS 

ASSOCIATES, INC., a Florida Corporation,” bearing case number 0:22cv62090, 

currently pending in the Federal District Court for the Southern District of Florida 

(“Roldan Lawsuit”).

2. Undersigned counsel is over the age of eighteen and make this 

declaration based upon personal knowledge and experience.

Case 0:22-cv-62090-KMW Document 12-1 Entered on FLSD Docket 01/31/2023 Page 1 of 13
3. The Roldan Lawsuit involves individual consumer protection claims 

advanced by Mr. Roldan against Defendant, CORAL SPRINGS HONDA d/b/a 

PAGE BROTHERS ASSOCIATES, INC., a Florida Corporation arising from a 

consumer motor vehicle lease transaction.

4. From 2016 through the present, the undersigned has practiced with a 

focus on representing consumers in consumer protection claims in state and federal 

court.

5. Much of said practice has been dedicated to advancing claims relative 

to consumer loan or lease transactions for motor vehicles.

6. Part and parcel to such representation, the undersigned has filed several 

dozen arbitration demands with the American Arbitration Association (hereinafter 

the “AAA”) against a multitude of business throughout the State of Florida.

7. Through his practice, the undersigned has routinely observed the AAA 

dismissing proceedings initiated by consumers as a direct result of the respective 

respondents’ failure to comply with one or more arbitration rules of the AAA.

8. The dismissals typically fall into one of three (or sometimes more) of 

the following categories: (1) refusal to pay filing fee; (2) refusal to pay consumer 

clause registration fee; or (3) non-compliance in previously filed consumer matters.

9. As to a respondent’s failure to pay filing fees- Pursuant to the consumer 

rules of the AAA, the tribunal charges consumers a maximum of $200 to initiate 

Case 0:22-cv-62090-KMW Document 12-1 Entered on FLSD Docket 01/31/2023 Page 2 of 13
arbitration.1 Upon the filing of the initiating demand, in most cases, the AAA 

assesses a $300 case filing fee, a $1,400 case management fee, and a $1,500 

arbitrator compensation fee. 2In the event a respondent fails to pay such fees, the 

AAA will afford the respondent an opportunity to cure the payment deficiency 

before ultimately dismissing the case. Representative copies of AAA 

correspondences wherein arbitration proceedings were terminated due to want of 

payment are attached as Composite Exhibit “A.”

10. As to refusal of business to comply with consumer clause registryPursuant to the AAA Consumer Rules, any entity that utilizes the auspices of the 

AAA to conduct arbitration proceedings must first submit its arbitration clause for 

review by the AAA to ensure it complies with the tribunal’s requirements. The AAA 

charges $500 for said review. 3 Often times, businesses will fail to pay both the initial 

filing fees along with the consumer arbitration clause review fee. See Exhibit A.

11. As it relates to non-compliance in previously filed consumer mattersOftentimes whenever a business fails to pay the aforementioned fees, the AAA will 

decline to administer future arbitration proceedings. 

12. As detailed herein, the likelihood of a business failing to comply with 

the AAA rules is not a farfetched proposition.

1 See: https://www.adr.org/sites/default/files/Consumer_Fee_Schedule_2.pdf

2

Id.

3

Id.

Case 0:22-cv-62090-KMW Document 12-1 Entered on FLSD Docket 01/31/2023 Page 3 of 13
13. It is in the interest of justice that this Court retain jurisdiction in the 

instant matter to allow Mr. Roldan to seek this Honorable Court’s intervention to 

compel the Defendant to comply with the AAA’s requirements or failing that, to 

determine that a waiver occurred with respect to the same.

I DECALRE under penalty of perjury, under the laws of the State of Florida, 

that the forgoing statements are true and accurate to the best of my knowledge.

DATED this 31st day of January, 2023.

___________________

Joshua E. Feygin

Case 0:22-cv-62090-KMW Document 12-1 Entered on FLSD Docket 01/31/2023 Page 4 of 13
EXHIBIT A

Case 0:22-cv-62090-KMW Document 12-1 Entered on FLSD Docket 01/31/2023 Page 5 of 13
 

1101 Laurel Oak Road

Voorhees, NJ 08043

November 30, 2022

Joshua Feygin, Esq.

Joshua Feygin, PLLC

1930 Harrison Street

Suite 208F

Hollywood, FL 33020

Via Email to: josh@jfeyginesq.com 

Ricardo A. Reyes, Esq.

Tobin & Reyes, PA

225 NE Mizner Boulevard

Mizner Park Tower

Suite 510

Boca Raton, FL 33432

Via Email to: rar@tobinreyes.com 

Case Number: 01-22-0004-0072

Todd S. Greenbaum

-vsDeerfield Automotive, LLC

Dear Parties:

As of this date we have not received the required fees from Deerfield Automotive, LLC in this matter. 

Accordingly, we must decline to administer this case and have closed our file. According to R-1(d) of the 

Consumer Arbitration Rules, should the AAA decline to administer an arbitration, either party may choose to 

submit its dispute to the appropriate court for resolution.

Additionally, and because Deerfield Automotive, LLC failure to remit the foregoing constitutes a failure to adhere 

to our policies regarding consumer claims, we may decline to administer future consumer arbitrations involving 

Deerfield Automotive, LLC. The AAA’s consumer policies can be found on the AAA’s website, www.adr.org . 

We request that Deerfield Automotive, LLC remove the AAA name from its consumer arbitration clause so that 

there is no confusion to the public regarding our decision. 

If Deerfield Automotive, LLC advises the AAA in the future of its intention to comply with the AAA’s Consumer 

Arbitration Rules and if applicable, resolves any outstanding payment obligations, the AAA may consider at its 

sole discretion, accepting newly filed consumer cases going forward.

Pursuant to the AAA’s current policy, in the normal course of our administration, the AAA may maintain certain 

electronic case documents in our electronic records system. Such electronic documents may not constitute a 

complete case file. Other than certain types of electronic case documents that the AAA maintains indefinitely, 

electronic case documents will be destroyed 18 months after the date of this letter. 

If you have any questions, please email ConsumerFiling@adr.org. 

Case 0:22-cv-62090-KMW Document 12-1 Entered on FLSD Docket 01/31/2023 Page 6 of 13
Sincerely,

Consumer Filing Team

Email: ConsumerFiling@adr.org

Fax: (877)304-8457

Case 0:22-cv-62090-KMW Document 12-1 Entered on FLSD Docket 01/31/2023 Page 7 of 13
 

1101 Laurel Oak Road

Voorhees, NJ 08043

May 25, 2022

Arisa Burgest

11 Teal Lake Drive

Savannah, GA 31419

Via Email to: arisaburgest@yahoo.com 

Auto Boutique

10100 Atlantic Boulevard

Jacksonville, FL 32225

Via Mail & Email to: sales@autoboutique.com 

Case Number: 01-22-0001-4660

Arisa Burgest

-vsAuto Boutique

Dear Parties:

As of this date we have not received the required waiver and fees from Auto Boutique in this matter. Accordingly, 

we must decline to administer this case and have closed our file. According to R-1(d) of the Consumer Arbitration 

Rules, should the AAA decline to administer an arbitration, either party may choose to submit its dispute to the 

appropriate court for resolution. 

Any payment submitted by a party will be refunded shortly. 

Further, because Auto Boutique failure to remit the foregoing constitutes a failure to adhere to our policies 

regarding consumer claims, we may decline to administer future consumer arbitrations involving Auto Boutique. 

The AAA’s consumer policies can be found on the AAA’s website, www.adr.org . We request that Auto Boutique

remove the AAA name from its consumer arbitration clause so that there is no confusion to the public regarding 

our decision. 

If Auto Boutique advises the AAA in the future of its intention to comply with the AAA’s Consumer Arbitration 

Rules and if applicable, resolves any outstanding payment obligations, the AAA may consider at its sole 

discretion, accepting newly filed consumer cases going forward.

Pursuant to the AAA’s current policy, in the normal course of our administration, the AAA may maintain certain 

electronic case documents in our electronic records system. Such electronic documents may not constitute a 

complete case file. Other than certain types of electronic case documents that the AAA maintains indefinitely, 

electronic case documents will be destroyed 18 months after the date of this letter. 

If you have any questions, please email ConsumerFiling@adr.org. 

Sincerely,

Consumer Filing Team

Email: ConsumerFiling@adr.org

Fax: (877)304-8457

Case 0:22-cv-62090-KMW Document 12-1 Entered on FLSD Docket 01/31/2023 Page 8 of 13
 

1101 Laurel Oak Road

Voorhees, NJ 08043

May 5, 2022

Joshua Feygin, Esq.

Joshua Feygin, PLLC

1800 East Hallandale Beach Boulevard

Suite 85293

Hallandale Beach, FL 33009

Via Email to: josh@jfeyginesq.com 

Keith D. Silverstein, Esq.

Keith D. Silverstein, P.A.

1111 Brickell Avenue

Suite 1550

Miami, FL 33131

Via Email to: keith@silversteinpa.com 

Case Number: 01-22-0000-9064

Mayra Lopez

-vsU Drive Motors, LLC

Dear Parties:

As of this date we have not received the required fees from U Drive Motors, LLC in this matter. Accordingly, we 

must decline to administer this case and have closed our file. According to R-1(d) of the Consumer Arbitration 

Rules, should the AAA decline to administer an arbitration, either party may choose to submit its dispute to the 

appropriate court for resolution. 

Any payment submitted by a party will be refunded shortly. 

Further, because U Drive Motors, LLC failure to remit the foregoing constitutes a failure to adhere to our policies 

regarding consumer claims, we may decline to administer future consumer arbitrations involving U Drive Motors, 

LLC . The AAA’s consumer policies can be found on the AAA’s website, www.adr.org. We request that the 

business remove the AAA name from its consumer arbitration clause so that there is no confusion to the public 

regarding our decision. 

If U Drive Motors, LLC advises the AAA in the future of its intention to comply with the AAA’s Consumer 

Arbitration Rules and if applicable, resolves any outstanding payment obligations, the AAA may consider at its 

sole discretion, accepting newly filed consumer cases going forward.

Pursuant to the AAA’s current policy, in the normal course of our administration, the AAA may maintain certain 

electronic case documents in our electronic records system. Such electronic documents may not constitute a 

complete case file. Other than certain types of electronic case documents that the AAA maintains indefinitely, 

electronic case documents will be destroyed 18 months after the date of this letter. 

If you have any questions, please email ConsumerFiling@adr.org. 

Case 0:22-cv-62090-KMW Document 12-1 Entered on FLSD Docket 01/31/2023 Page 9 of 13
Sincerely,

Consumer Filing Team

Email: ConsumerFiling@adr.org

Fax: (877)304-8457

Case 0:22-cv-62090-KMW Document 12-1 Entered on FLSD Docket 01/31/2023 Page 10 of 13
 

1101 Laurel Oak Road

Voorhees, NJ 08043

August 4, 2022

Joshua Feygin, Esq.

Joshua Feygin, PLLC

1800 East Hallandale Beach Boulevard

Suite 85293

Hallandale Beach, FL 33009

Via Email to: josh@jfeyginesq.com 

William C. Diaz-Rousselot, Esq.

Kurkin Forehand Brandes, LLP

18851 Northeast 29th Avenue

Suite 303

Aventura, FL 33180-2808

Via Email to: wdiazr@kfb-law.com 

Case Number: 01-22-0002-6580

Patrick Pumphrey

-vsGunther VW of Coconut Creek

Dear Parties:

As of this date we have not received the required fees from Gunther VW of Coconut Creek in this matter. 

Accordingly, we must decline to administer this case and have closed our file. According to R-1(d) of the 

Consumer Arbitration Rules, should the AAA decline to administer an arbitration, either party may choose to 

submit its dispute to the appropriate court for resolution. 

Further, because Gunther VW of Coconut Creek failure to remit the foregoing constitutes a failure to adhere to 

our policies regarding consumer claims, we may decline to administer future consumer arbitrations involving 

Gunther VW of Coconut Creek. The AAA’s consumer policies can be found on the AAA’s website, www.adr.org

. We request that Gunther VW of Coconut Creek remove the AAA name from its consumer arbitration clause so 

that there is no confusion to the public regarding our decision. 

If Gunther VW of Coconut Creek advises the AAA in the future of its intention to comply with the AAA’s 

Consumer Arbitration Rules and if applicable, resolves any outstanding payment obligations, the AAA may 

consider at its sole discretion, accepting newly filed consumer cases going forward.

Pursuant to the AAA’s current policy, in the normal course of our administration, the AAA may maintain certain 

electronic case documents in our electronic records system. Such electronic documents may not constitute a 

complete case file. Other than certain types of electronic case documents that the AAA maintains indefinitely, 

electronic case documents will be destroyed 18 months after the date of this letter. 

If you have any questions, please email ConsumerFiling@adr.org. 

Sincerely,

Consumer Filing Team

Case 0:22-cv-62090-KMW Document 12-1 Entered on FLSD Docket 01/31/2023 Page 11 of 13
Email: ConsumerFiling@adr.org

Fax: (877)304-8457

Case 0:22-cv-62090-KMW Document 12-1 Entered on FLSD Docket 01/31/2023 Page 12 of 13
 

1101 Laurel Oak Road, Suite 100

Voorhees, NJ 08043

July 31, 2018

Darren R. Newhart, Esq.

Consumer Law Organization, PA

721 US Highway 1

Suite 201

North Palm Beach, FL 33408

Via Email to: darren@cloorg.com

Arrigo Dodge Chrysler Jeep RAM West Palm Beach

6500 Okeechobee Boulevard

West Palm Beach, FL 33411

Via Mail 

Case Number: 01-18-0001-9053

Talley Wright

-Vs- 

 Arrigo Enterprises, Inc.

Dear Parties:

As of this date we have not received the required fees from the business Arrigo Enterprises, Inc. in this matter. 

Accordingly, we must decline to administer this case and have closed our file. According to R-1(d) of the 

Consumer Arbitration Rules, should the AAA decline to administer an arbitration, either party may choose to 

submit its dispute to the appropriate court for resolution. 

Any payment submitted by a party will be refunded shortly. 

Further, because the business' failure to remit the foregoing constitutes a failure to adhere to our policies 

regarding consumer claims, we may decline to administer future consumer arbitrations involving Arrigo 

Enterprises, Inc. The AAA's consumer policies can be found on the AAA's website, www.adr.org. We 

request that the business remove the AAA name from its consumer arbitration clause so that there is no 

confusion to the public regarding our decision. 

Pursuant to the AAA's current policy, in the normal course of our administration, the AAA may maintain certain 

electronic case documents in our electronic records system. Such electronic documents may not constitute a 

complete case file. Other than certain types of electronic case documents that the AAA maintains indefinitely, 

electronic case documents will be destroyed 18 months after the date of this letter. 

If you have any questions, please email ConsumerSpecialist@adr.org

Sincerely,

Consumer Filing Team

Email: ConsumerSpecialist@adr.org

Fax: (877)304-8457

Case 0:22-cv-62090-KMW Document 12-1 Entered on FLSD Docket 01/31/2023 Page 13 of 13