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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

PALM BEACH DIVISION

Case No.: 9:22-cv-81961-AMC

JONATHAN LEE REIGROD, 

An Individual,

Plaintiff,

v.

GARBER DELRAY INC.,

d/b/a DELRAY BUICK GMC,

A Florida Corporation, 

Defendant.

______________________________/

ATTORNEY JOSHUA FEYGIN’S AFFIDAVIT 

IN SUPPORT OF ATTORNEY’S FEES AND COSTS

Joshua Feygin states upon his oath and under the penalty of perjury that he is 

competent to testify and makes this Declaration based upon personal knowledge, 

and, if called upon to testify, would testify as follows:

1. I submit this declaration to provide the Court with my qualifications 

in support of the amount of attorney’s fees and costs sought herein.

2. I received my B.A. from Florida International University in 2013. 

3. I graduated from Florida International University School of Law in 

2016 and was admitted to the Florida Bar in 2016.

4. I am admitted to practice in the State Bar of Florida, the Federal 

District Court of the Southern District of Florida, Middle District of Florida, 

Case 9:22-cv-81961-AMC Document 9-4 Entered on FLSD Docket 02/09/2023 Page 1 of 7
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Northern District of Florida, Eastern District of Michigan, the District of Colombia

and the State Bar of Vermont. 

5. My practice is predominately focused on the representation of 

consumers under consumer protection statutes. 

6. During my career, I have successfully resolved several hundred

individual consumer law claims both in state court and through arbitration.

7. I am a member of the National Association of Consumer Advocates

since 2018.

8. I am presently serving on the steering committee for the 2023 Spring 

Training Conference of the National Association for Consumer Advocates for the 

Auto Fraud Track.

9. I presented as a guest speaker at the 2022 Florida Bar Consumer 

Protection Law Committee Seminar on Auto Fraud.

10. I have been called upon and quoted by various news media outlets to 

provide expert insight into auto fraud matters. Some notable appearances are listed 

below.

• Ron Hurtibsie, Auto-related fraud is rampant in Florida. Here’s how to 

avoid getting taken,https://www.sun-sentinel.com/business/fl-bz-floridathird-worst-for-auto-scams-20210427-f57v2y37wfa7zhlx6rfe5pzctystory.html, April 27, 2021.

• Ron Hurtibsie, How to avoid falling victim to South Florida’s online car 

sales scams, https://www.sun-sentinel.com/business/money/fl-bz-carscams-ss-prem-20210228-cpfbypxtija43epkte4ej4drmi-story.html, 

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February 28, 2021. 

• Michelle Quesada, Car leaseholder struggles to exercise buyout 

agreement terms, https://www.wptv.com/money/consumer/carleaseholder-struggles-to-exercise-buyout-agreement-terms, February 13, 

2022.

• Jeff Weinsier, Car dealerships continue to engage in illegal malpractice 

with fees, dealer says, 

https://www.local10.com/news/local/2022/05/20/car-dealershipscontinue-to-engage-in-illegal-malpractice-with-fees-attorney-says/ May 

20, 2022.

• Jackie Callaway, Vehicle owners getting hit with sticker shock when 

attempting to buy out lease, 

https://www.abcactionnews.com/money/consumer/taking-action-foryou/vehicle-owners-getting-hit-with-sticker-shock-when-attempting-tobuy-out-lease, August 17, 2022.

• Ron Hurtibsie, Car dealers accused of price-gouging customers who 

exercise option to buy leased vehicles, https://www.sunsentinel.com/business/fl-bz-car-dealers-lease-buy-out-fees-20221112-

yauo46l6brbyvhpn63ri4ufhiy-story.html November 12, 2022.

• Ron Hurtibsie, Complaints about auto-lease buyout fees prompt 

subpoenas from state Attorney General, https://www.sunsentinel.com/business/fl-bz-lease-buy-out-costly-confusion-20221121-

odunffuvkbcb7hdmi4bs5skycq-story.html, November 21, 2022

• Michelle Quesada, Service fees can quickly add up for car buyers. Here's 

what to do, https://www.wptv.com/marketplace/automotive/service-feescan-quickly-add-up-for-car-buyers-heres-what-to-do, January 12, 2023.

11. Moreover, I have been retained by numerous car dealerships 

throughout the State of Florida as special counsel for consumer compliance 

consulting and loss mitigation analysis, such as South Motors Automotive 

Group; South Motor Company of Dade County; Pompano Imports, Inc. d/b/a 

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Vista Motor Company; and, Midway Mall, Inc., d/b/a Midway Ford, to name a 

few. 

12. According to the 2017-2018 United States Consumer Law Attorney 

Fee Report, the median attorney rate for lawyers in South Florida who handle car 

cases is $400. 

13. I expended 16.7 hours in the prosecution of this action inclusive of an 

estimated 0.2hrs for the filing and submission of the Plaintiff’s Motion for Default 

Final Judgment and Proposed Order.

14. Of the 16.7 hours, 2 hours were for administrative or secretarial work 

which was reduced to $100/hour for a total of $200.

15. The remaining 14.7 hours of incurred time was for substantive legal 

work.

16. Furthermore, I have advanced $432.00 in hard costs during the 

prosecution of this action as set forth in my time and cost log attached hereto as 

Exhibit “A.” 

17. I certify that all of the time entries submitted were required in the 

prosecution of this claim, and that my time was kept contemporaneously during the 

course of this action as reflected in Exhibit A.

18. On July 11, 2021, the Honorable County Court Judge Chiaka 

Ihekwaba awarded the undersigned a rate of $300 per hour as a reasonable hourly 

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rate. Maria Diaz Pizzaro, et al., v. Matrix Auto Sales Inc., et al., 29 Fla. L. 

Weekly Supp. 340a.

19. Given the above, $350.00/hour is a reasonable hourly rate for my 

efforts for a total of $5,145.00 for substantive legal work performed and $200.00 

for administrative work for a total of $5,345 in reasonable attorney’s fees for the 

prosecution of this action along with $432.00 in taxable costs.

VERIFICATION

I, Joshua Feygin, under penalties of perjury, declare that I have read the 

foregoing Affidavit and that the facts stated in it are true.

_____________________

JOSHUA FEYGIN, ESQ.

FL Bar No.: 124685

Email: Josh@JFeyginesq.com

SUE YOUR DEALER – A 

LAW FIRM

1930 Harrison St.

208F

Hollywood, FL 33020

Tel: (954) 228-5674

Fax: (954) 697-0357

Dated: February 9, 2023

Case 9:22-cv-81961-AMC Document 9-4 Entered on FLSD Docket 02/09/2023 Page 5 of 7
EXHIBIT A

Case 9:22-cv-81961-AMC Document 9-4 Entered on FLSD Docket 02/09/2023 Page 6 of 7
Date Description Hours $ / Hour Amount

10/17/2022 Client intake, legal research and review of 15 U.S.C. § 1667. 0.7 $ 350.00 $245.00

10/20/2022 Preparation and issuance of retainer to client for electronic execution via DocHub. 0.2 $ 100.00 $20.00

10/23/2022 Review of retainer to ensure properly completed by Client. File prep, calendaring of statute of 

limitations deadline. 0.5 $ 100.00 $50.00

12/20/2022 Preparation of jury instructions. 1.8 $ 350.00 $630.00

12/20/2022 Preparation of initial discovery (Requests for Production- 1.1hr and Requests for Admissions1.3hr). 2.4 $ 350.00 $840.00

11/8/2022 Preparation of Complaint, compiling and redacting exhibit. 1.1 $ 350.00 $385.00

12/20/2022 Preparation of summons inclusive of researching Defendant's registered agent. Locating situs of 

R/A to confirm R/A will be accessible during statutory hours. 0.4 $ 350.00 $140.00

12/20/2022 Preparation of corporate disclosure/certificate of interested parties including research into same 

via SUNBIZ. 0.6 $ 350.00 $210.00

12/20/2022 Preparation of Civil Cover Sheet 0.2 $ 350.00 $70.00

12/21/2022 Email to cocounsel with complaint for review. Revisions that followed. Final review of initial 

pleadings. Review of local rules for filing requirements. Determining proper division to file 

case in. Initiation of lawsuit.

0.6 $ 350.00 $210.00

12/21/2022 Review of filed complaint and attachments. 0.3 $ 350.00 $105.00

12/21/2022 Review of issued summons. Dispatch to process server for service of process upon Defendant. 0.4 $ 100.00 $40.00

12/21/2022 Review of Notice of Assignment of Judge Judge Aileen M. Cannon and U.S. Magistrate Judge 

Bruce E. Reinhart. Notation in file to meet & confer w/ OC upon appearance re: consent to 

magistrate.

0.2 $ 350.00 $70.00

12/23/2022 Review of return of service of process. Filing return of service with court. Calendaring of 

Defendant's deadline to respond with reminders. 0.4 $ 100.00 $40.00

1/18/2023 Review of calendar notification re: expiration of Defendant's responsive deadline; review of 

docket for return of service to confirm; preparation and filing of Motion for Clerk's Default as 

to Defendant Delray Buick GMC

0.3 $ 350.00 $105.00

1/18/2023 Review of Clerk's Entry of Default as to GARBER DELRAY INC. 0.1 $ 350.00 $35.00

1/19/2023 Update email to Client advising lawsuit filed, default entered, steps moving forward. 0.1 $ 100.00 $10.00

1/20/2023 Followup email from Client requesting clarification of status of proceedings. Response that 

followed.

0.2 $ 100.00 $20.00

1/20/2023 Review of ORDER ON DEFAULT FINAL JUDGEMENT PROCEDURE 0.3 $ 350.00 $105.00

1/20/2023 Setting deadline in calendar for Motion for Default Judgment 0.2 $ 100.00 $20.00

1/21/2023 Review of Notice of Appearance of Co-counsel, Darren Newhart 0.1 $ - $0.00

2/3/2023 Initial drafting of Motion for Default Judgment inclusive or preliminary research into same. 1.3 $ 350.00 $455.00

2/8/2023 Supplemental drafting of Motion for Default Judgment, additional research inclsuive of review 

of Local Rule 7.1(a)(2), retention of Attorney R. Murphy as expert re: reasonableness of 

attorney's fees and costs. Preparation of proposed order.

3.2 $ 350.00 $1,120.00

2/8/2023 Preparation of affidavit of damages on behalf of Plaintiff and issuance of same for execution. 0.4 $ 350.00 $140.00

2/8/2023 Preparation of and execution of affidavit in support of attorney's fees. 0.5 $ 350.00 $175.00

2/9/2023 Filing of Motion for Default; submission of proposed Order [ESTIMATED] 0.2 $ 350.00 $70.00

COSTS

12/21/2022 Filing fee. $402.00

12/21/2022 Service of process fee. $30.00

 Total 

Hours 16.7

 Billable $5,345.00

 Total 

Costs $432.00

 TOTAL $ 5,777.00 

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