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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

FT. LAUDERDALE DIVISION

Case No.:0:22cv62090

CHRISTOPHER ALLEN ROLDAN,

An Individual,

Plaintiff,

v.

CORAL SPRINGS HONDA

d/b/a PAGE BROTHERS ASSOCIATES, INC.

A Florida Corporation,

Defendant.

______________________________/

COMPLAINT AND DEMAND

FOR JURY TRIAL

Plaintiff, CHRISTOPHER ALLEN ROLDAN, brings this action against

PAGE BROTHERS ASSOCIATES, INC., a Florida corporation, under the

Consumer Leasing Act (“CLA”), 15 U.S.C. § 1667, and its implementing

regulations, 12 C.F.R. § 1013 et seq. (“Regulation M”).

JURISDICTION AND VENUE

1. The Court has federal question jurisdiction under 28 U.S.C. § 1331

because the claim arises from the CLA, a federal statute. 15 U.S.C. § 1667d(c).

2. Venue is proper before this Court because the acts and transactions

giving rise to Plaintiff’s action occurred in this district, Plaintiff resides in this

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district, and Defendant transacts business in this district.

PARTIES

3. Plaintiff is a natural person who at all relevant times resided in Broward

County, Florida.

4. Defendant is a Florida limited liability company with principal offices

in Broward County, FL.

FACTUAL ALLEGATIONS 

5. In June of 2019, Defendant leased a new 2019 Honda Accord

(“Vehicle”) to Plaintiff. 

6. The Vehicle was leased under a Closed-End Vehicle Lease Agreement 

(“Lease”). A partially redactec copy of the Lease is attached as Exhibit A.

7. In the Lease, Defendant provided Plaintiff with the option to buy the 

Vehicle before the end of the lease term.

8. More particularly, the Lease provided: “I have the option to purchase 

the Vehicle at any time (Unless a governmental agency has seized the Vehicle and 

instructed Lessor not to release the Vehicle to me). This purchase option may only 

be exercised by the Lessee. If I purchase the Vehicle prior to the end of the Lease 

Term, the purchase price will be the Adjusted Lease Balance (defined below), plus 

(a) any payments or other charges due and unpaid under this Lease and (b) any taxes 

and fees required by law in connection with the purchase.” Id. ¶ 28 “PURCHASE 

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OPTION PRIOR TO THE END OF LEASE TERM”(hereinafter the “Purchase 

Option”). 

9. At or about November, 2021, Plaintiff contacted HONDA LEASE 

TRUST, (“HLT”) which was assigned the Lease, and asked about the process to buy 

the Vehicle. 

10. HLT directed Plaintiff to buy the Vehicle through Defendant. 

11. In November of 2021, Plaintiff visited Defendant to exercise the 

purchase option. 

12. To buy the Vehicle, Defendant charged Plaintiff a $992.00 “Predelivery 

Service Charge,” as well as a $449.00 “Electronic Registration Filing Fee.”

13. These fees were never disclosed in the Lease. 

14. In total, Plaintiff was charged $1,441.00 in undisclosed fees to exercise 

the Purchase Option. 

COUNT I AS TO DEFENDANT’S VIOLATION OF FEDERAL 

CONSUMER LEASING ACT 15 U.S.C. § 1667a

15. The CLA governs the disclosures in the Lease because the lease term 

ran for 36 months and was for less than $58,300. 15 U.S.C. § 1667(1).

16. Plaintiff is a natural person who leased the Vehicle primarily for 

personal, family, and household purposes. 15 U.S.C. § 1667(1)-(2).

17. Defendant had to comply with the CLA’s disclosure requirements 

because it was a “lessor” under the CLA. 

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18. Defendant is a large car dealership that has leased, offered, or arranged 

to lease vehicles more than five times in the preceding calendar year or more than 

five times in the current calendar year. 15 U.S.C. § 1667(3); Reg. M § 1013.2(h).

19. As described above, Defendant had substantial involvement in the lease 

transaction with Plaintiff. 

20. Upon information and belief, Defendant financially gains on the resale 

of the vehicle at the end of the Lease term. 

21. The Lease is governed by the disclosure requirements of 15 U.S.C. 

§ 1667a and 12 C.F.R. § 213.4. 

22. The disclosure of the purchase option in the Lease had to be accurate, 

clear, conspicuous, and complete. 12 CFR § 1013.3(a). 

23. Defendant violated 15 U.S.C. § 1667 and 12 CFR § 1013.4(i) by 

choosing not to disclose in the purchase option price that payment of the $992.00 

“Predelivery Service Charge” and $449.00 “Electronic Registration Filing Fee” was 

required to exercise the Purchase Option.

24. Defendant violated 15 U.S.C. § 1667 and 12 CFR § 1013.4(i) by 

choosing not to disclose in the Purchase Option that payment of $1,441.00 more 

was required to exercise the Purchase Option. 

25. Defendant violated 12 CFR § 1013.3(a) because the Purchase Option 

was unclear, inaccurate, and incomplete. 

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26. The above described omissions were material to Plaintiff’s decision to 

enter into the Lease, and Plaintiff detrimentally relied on these material omissions. 

27. Plaintiff suffered financial loss in that Plaintiff paid $1,441.00 more 

than what the Lease required to buy the Vehicle. 

28. Had Defendant provided an accurate, complete, and clear purchase 

option price in the Lease, which it was required to do, Plaintiff would have 

negotiated better terms or elected declined to lease the Vehicle. 

29. Defendant’s illegal conduct was the actual and proximate cause of the 

actual damages suffered by Plaintiff.

30. Pursuant to 15 U.S.C. § 1640, Plaintiff is entitled to recover actual and 

statutory damages from Defendant, and reasonable attorney’s fees and costs. 

PRAYER FOR RELIEF

WHEREFORE, Plaintiff for relief and judgment against Defendant as 

follows:

A. Actual and Statutory Damages as provided by law;

C. Pre-judgment and post-judgment interest, as allowed by law;

D. Reasonable attorneys' fees and costs;

E. Injunctive relief requiring Defendant to honor its obligation under its 

Lease agreements to sell the Leased vehicles for the price identified on the Lease 

agreement; and

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F. Such other and further relief as is just and proper.

JURY DEMAND

Plaintiff hereby demands a trial by jury on all issues so triable.

Respectfully submitted,

/s/ Joshua E. Feygin

SUE YOUR DEALER – A LAW FIRM

FL Bar No.: 124685

Email: Josh@JFeyginesq.com

JOSHUA FEYGIN, PLLC

1930 Harrison St. Ste. 208F

Hollywood, FL 33020

Tel: (954) 228-5674

Fax: (954) 697-0357

/s/ Darren R. Newhart

Darren R. Newhart, Esq.

FL Bar No: 0115546

E-mail: darren@newhartlegal.com

NEWHART LEGAL, P.A.

P.O. Box 1351

Loxahatchee, FL 33470

Telephone: (561) 331-1806

Facsimile: (561) 473-2946

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