THE CITY OF NEW YORK

OFFICE OF ADMINISTRATIVE TRIALS AND HEARINGS, TRIALS DIVISION

NEW YORK CITY DEPARTMENT OF
CONSUMER AND WORKER PROTECTION,
NOTICE TO RESPONDENTS
Petitioner,
OATH Index No. ___________
v.

J.F. MOTORS, LLC, J.F. MOTORS 2, INC.,

BEST LUXURY MOTORS 2, LLC, NYC
MOTORCARS OF FREEPORT CORP., and
FAISAL KHAN, individually, as member, owner,
and officer of J.F. Motors, LLC, J.F. Motors 2,
Inc., and Best Luxury Motors 2, LLC,

Respondents.

To each above-named Respondents, TAKE NOTICE THAT:

YOU HAVE A RIGHT TO FILE AN ANSWER with the New York City Office of
Administrative Trials and Hearings (“OATH”), 100 Church Street – 12th Floor, New York, New
York 10007. Pursuant to Section 1-24 of Title 48 of the Rules of the City of New York, if you
choose to file an answer, your answer must be filed within eight days of service if the petition was
served via personal delivery or thirteen days of service if the petition was served by mail, unless
the administrative law judge assigns a different deadline. Alternatively, an administrative law
judge may require you to file an answer. Failure to file an answer when required may result in
sanctions against you.

YOU HAVE THE RIGHT TO BE REPRESENTED BY AN ATTORNEY OR

OTHER REPRESENTATIVE, if you choose. If you choose to be represented, your attorney or
representative must file a notice of appearance with OATH.

YOUR FAILURE OR YOUR AUTHORIZED REPRESENTATIVE’S FAILURE

TO APPEAR AT THE HEARING, CONFERENCE, OR TRIAL may result in a waiver of the
right to a hearing or other disposition against you and a default decision and order being entered
against you.

OATH’S RULES OF PRACTICE AND PROCEDURE are published in Title 48 of the

Rules of the City of New York. Copies of OATH’s rules are available at OATH’s offices at 100
Church Street – 12th Floor, New York, New York 10007 and on OATH’s website:
http://www.nyc.gov/oath.
 OATH WILL ISSUE A RECOMMENDED DECISION IN THIS MATTER, which
the Commissioner of the Department of Consumer and Worker Protection (“DCWP”) may adopt,
reverse, modify, or send back to OATH, in whole or in part, for additional proceedings, pursuant
to Section 2203(h)(1) of the New York City Charter.

WITHIN THIRTY (30) DAYS OF THE ISSUANCE OF THE RECOMMENDED

DECISION, Respondents may submit to the Commissioner of DCWP by regular mail, email, or
delivery to DCWP at its main office, a written argument setting forth the reasons why the
Commissioner should adopt, reverse, or modify the decision, or send the decision, in whole or in
part, back to OATH for additional proceedings.

IF A FINAL ORDER OF THE COMMISSIONER REQUIRES YOU TO PAY A

CIVIL PENALTY, failure to pay that penalty in a timely manner could lead to the denial of an
application for a license, permit or registration, or to the suspension, termination or revocation of
a license, permit or registration issued to you by a city agency.

Dated: November 1, 2021

New York, New York

For: Peter A. Hatch, Commissioner

NYC Department of Consumer and Worker Protection

By: ________________________________
Bradley McCormick
Senior Staff Counsel
42 Broadway, 9th Floor
New York, NY 10004
bmccormick@dcwp.nyc.gov
(212) 436-0325

To: J.F. Motors, LLC d/b/a World Auto

4301-4309 Northern Blvd.
Long Island City, NY 11101
jfmotors@hotmail.com

J.F. Motors, LLC d/b/a World Auto

c/o Faisal Khan
105 Cross Road
North Bellmore, NY 11710

J.F. Motors 2, Inc.

d/b/a Luxury Automotive Club
60-20 Northern Blvd.
Woodside, NY 11377

2
J.F. Motors 2, Inc. d/b/a Automania
5511 Northern Boulevard
Woodside, NY 11377
nyautomania@gmail.com

Best Luxury Motors 2, LLC

d/b/a Luxury Automotive Club
6107 Northern Blvd.
Flushing, NY 11377
luxuryofwoodside@gmail.com

NYC Motorcars of Freeport Corp.

c/o Murray Honig, Esq
88 Middle Neck Rd
Great Neck, NY 11021

NYC Motorcars of Freeport Corp.

415 W Sunrise Hwy
Freeport, NY 11520

Faisal Khan
105 Cross Road
North Bellmore, NY 11710

Richard Simon, Esq.

Attorney for Respondents J.F. Motors, LLC, J.F. Motors 2, Inc.,
Best Luxury Motors 2, LLC
rsimonesq@yahoo.com

2
THE CITY OF NEW YORK
OFFICE OF ADMINISTRATIVE TRIALS & HEARINGS, TRIALS DIVISION

NYC DEPARTMENT OF CONSUMER AND

WORKER PROTECTION,
PETITION
Petitioner,
OATH Index No. _______
-against-

J.F. MOTORS, LLC, J.F. MOTORS 2, INC.,

BEST LUXURY MOTORS 2, LLC, NYC
MOTORCARS OF FREEPORT CORP., and
FAISAL KHAN, individually, as member,
owner, and officer of J.F. Motors, LLC, J.F.
Motors 2, Inc., and Best Luxury Motors 2, LLC,

Respondents.

The New York City Department of Consumer and Worker Protection (“DCWP” or “the

Department”) brings this action against Respondents J.F. Motors, LLC d/b/a World Auto (“World

Auto”), J.F. Motors 2, Inc., Best Luxury Motors 2, LLC d/b/a Luxury Automotive Club, NYC

Motorcars of Freeport Inc., and Faisal Khan (together, “Respondents”), and alleges as follows:

INTRODUCTION

1. Respondents are an interconnected web of second-hand automobile dealers

(“SHADs”) and their owner, who, together, are engaged in a systematic scheme to defraud New

York City consumers. The central element of their scheme is selling fake “certified pre-owned”

automobiles to consumers for thousands of dollars more than their advertised prices, a practice

Respondents have engaged in hundreds of times.

2. Respondents’ certified pre-owned (“CPO”) scam is effective and profitable because

many consumers are particularly attracted to CPO automobiles. Although there is no national

standard for CPO automobiles, they are considered to be in better condition, are subject to more
rigorous inspections, have a clean history, and are backed by a special warranty. 1 Many consumers

are willing to pay a premium for the reassurance that they are buying a quality car that will not

require expensive repairs. 2

3. Consumer Reports estimates that CPO automobiles sell for $850 to $3,000 more

than their non-CPO counterparts. 3 And a Cars.com analysis of 200,000 late-model used cars found

that CPO automobiles were advertised for an average of $1,017 more than the same models with

no certification. 4

4. Eager to cash in, Respondents have been for years claiming that all of their

automobiles are CPO. World Auto has even called itself “THE HOME OF CERTIFIED PRE-

OWNED VEHICLES.” Nothing could be further from the truth.

5. Respondents notionally participate in a CPO program sponsored by the National

Independent Automobile Dealers Association (“NIADA”). All NIADA CPO automobiles (1) must

pass a 125-point inspection, (2) are backed by a free 10-year/100,000-mile powertrain warranty,

and (3) come with a vehicle history report. Respondents promise all of these CPO benefits to

consumers, but they do not deliver a single one.

6. Even worse, Respondents sell all their second-hand automobiles at prices greater

than the advertised prices. Respondents misrepresent to consumers that the higher prices are due

at least in part to a mandatory certification fee, a practice that fragrantly violates the New York

1
See J.D. Power N.A.D.A. Guides, What is a CPO Car? CPO Cars vs Used Cars,
https://www.nadaguides.com/Cars/Certified-Pre-Owned/What-is-a-CPO-Car (last accessed Sept. 10,
2021); Kelley Blue Book, A Guide to Certified Pre-Owned Cars, https://www.kbb.com/certified-pre-
owned/ (last accessed Sept. 10, 2021); Jon Linkov, Mike Monticello, Consumer Reports, The Truth About
Certified Pre-Owned Cars (Aug. 3, 2021), https://www.consumerreports.org/used-cars/the-truth-about-
certified-pre-owned-cars-a8333898965/; Kelsey Mays, Cars.com, Are Certified Pre-Owned Cars Worth It?
(Aug. 31, 2020), https://www.cars.com/articles/are-certified-pre-owned-cars-worth-it-426164/.
2
See J.D. Power, supra.; Kelley Blue Book, supra.
3
See Linkov, supra.
4
See Mays, supra.
2
City Consumer Protection Law (“CPL”) and the SHAD laws and rules, and is expressly prohibited

by NIADA.

7. Even though NIADA CPO vehicles come with a free warranty, Respondents

illegally require some consumers to purchase vehicle service contracts (“VSCs”). But when those

same consumers attempt to have repairs done under the VSC, they are told by the VSC

administrator that there is no record of their VSC on file. In essence, Respondents forced these

consumers to pay thousands of dollars for nothing.

8. After all that, Respondents still are not finished abusing their customers. Among

other things, Respondents fleece buyers from out of state by misrepresenting to them the amount

paid to government agencies on their behalf for tax, title, and registration; fail to provide

consumers with accurate information about financing and the NYC Used Car Cancellation Option;

purport to grant themselves a unilateral right to cancel or renegotiate retail instalment contracts

(“RICs”)—and charge the consumer a fee for it—through illegal contingency clauses; and fail to

offer Spanish language documents to consumers with whom they negotiate a deal in Spanish.

9. Finally, Respondents frequently use sales documents that identify as the seller

different entities within their web of companies. As a result, anyone seeking to hold Respondents

accountable is left asking “who exactly sold this car?”

10. Ultimately, every consumer who buys a car from Respondents is a victim, and the

harms suffered are compounded upon one another. None of Respondents’ customers get the

promised benefit of owning a CPO automobile, estimated conservatively to be worth at least $850.

And Respondents’ customers pay an average of $7,037 above Respondents’ advertised prices.

Because Respondents finance their automobiles at an average annual percentage rate of 11.14%

3
for 72 months, Respondents’ typical customer is fleeced for $10,539. 5 Consumers who are coerced

into buying worthless VSCs are robbed of an additional $4,984, 6 and customers from out-of-state

are taken for an additional $284. 7

11. Respondents’ deceptive and illegal conduct violates the CPL and DCWP’s

licensing laws, codified in Chapters One, Two and Five of the New York City Administrative

Code (“NYC Code”); and the DCWP Rules, codified in Title Six of the Rules of the City of New

York (“RCNY” or “Rules”).

12. By this proceeding, and as against Respondents, DCWP seeks restitution for

aggrieved consumers, civil penalties, the revocation of all SHAD licenses issued to Respondents,

and such other relief as authorized by section 2203(h) of Chapter 64 of the New York City Charter

(“Charter”) and the NYC Code.

PARTIES

13. DCWP is a mayoral agency of the City of New York responsible for protecting and

enhancing the daily economic lives of New Yorkers to create thriving communities. DCWP is

charged with the protection and relief of the public from deceptive, unfair, and unconscionable

practices, and for the maintenance of standards of integrity, honesty, and fair dealing among

persons engaging in licensed activities. Charter section 2203(h) and Chapter 20 of the NYC Code

authorize DCWP to enforce the licensing laws and rules governing SHADs and the CPL.

14. Respondent JF Motors, LLC d/b/a World Auto is a New York Limited Liability

Company. World Auto was licensed to conduct business as a SHAD at 4309 Northern Boulevard,

5
Including applicable sales tax at New York City rate of 8.875%.
6
Average price of undelivered VSC plus finance charges of 11.14% APR for 72 months, and applicable
sales tax at New York City rate of 8.875%.
7
Average difference between government fees collected and government fees paid on consumer’s behalf
plus finance charges of 11.14% APR for 72 months. Sales tax inapplicable.
4
Queens, New York under DCWP license number 1326676 from July 22, 2009 until its license

expired on August 14, 2021. World Auto filed Articles of Dissolution with the State of New York

Department of State (“DOS”) on December 22, 2020.

15. Respondent JF Motors 2, Inc. (“JF2”) is a New York Domestic Business

Corporation. Its principal executive offices are located at 6020 Northern Boulevard., Queens, New

York. JF2 has been licensed to conduct business as a SHAD at 6020 Northern Boulevard under

DCWP license number 2003106 since January 31, 2014. Since 2014, Respondents have done

business at this location under various trade names, including Auto Solution, NYC Motorcars,

NYC Motorcars of Woodside, and Luxury Automotive Club. JF2 filed a certificate of assumed

name on October 19, 2018 to do business as NYC Motorcars at this location, and then on February

7, 2020, filed a new certificate of assumed name to do business as Luxury Automotive Club. JF2

has never notified DCWP of its use of any trade name for this location, even though they are

required by law to do so. 8 Hereinafter, the term “JF2 at 6020” refers to the JF2 dealership located

at 6020 Northern Boulevard.

16. JF2 has also been licensed to conduct business as a SHAD at 5511 Northern

Boulevard, Queens, New York under DCWP license number 2072899 since June 7, 2018. JF2 uses

the assumed name Automania at this location, and duly notified DCWP of same. Hereinafter, the

term “Automania” refers to JF2 d/b/a Automania at 5511 Northern Boulevard.

17. Respondent Best Luxury Motors 2, LLC d/b/a Luxury Automotive Club (“LAC”)

is a New York Limited Liability Company that has been licensed to conduct business as a SHAD

at 6107 Northern Boulevard, Queens, New York under DCWP license number 2094591 since

February 9, 2020. Although LAC notified DCWP of its assumed name Luxury Automotive Club,

8
See NYC Code § 20-113.
5
there is no record of LAC ever filing a certificate of assumed name with the DOS.

18. NYC Motorcars of Freeport Corp. is a New York Domestic Business Corporation

located at 415 W. Sunrise Highway, Freeport, Nassau County, New York, that illegally deals in

second-hand automobiles in New York City without a license.

19. Respondents’ business entities are completely intermingled so as to render them

indistinguishable. 9 They operate as a common enterprise under common ownership, operating

under common control, sharing business premises, commingling business entities, and sharing

advertising and marketing. Respondents’ retail sales documents frequently name one dealer on the

bill of sale and a different dealer on the retail instalment contract. The name of the selling dealer

on Respondents’ retail sales documents often does not correspond to the location where the sale is

occurring. And, often one dealer will sell an automobile while title is held by a different dealer,

which is illegal in New York State. 10

20. Faisal M. Khan is the sole owner or member of each Respondent business, except,

on information and belief, NYC Motorcars of Freeport Corp. He controls and dominates

Respondents’ day-to-day operations. Respondent businesses’ deceptive and illegal practices are so

systematic and widespread—occurring in every transaction—that they could not be executed

without Mr. Khan’s participation or knowledge.

STATEMENT OF FACTS

I. The “Certified Pre-Owned” Scam

21. The centerpiece of Respondents’ marketing is their claim that they sell NIADA

CPO automobiles. Nothing could be further from the truth.

9
References to a particular dealership or individual are for narrative clarity and should not be construed to
limit the liability of other Respondents. Use of a particular dealership name generally refers to where the
transaction took place or the entity that produced records in response to a given subpoena.
10
15 NYCRR § 78.16(c).
6
 22. NIADA CPO is a certification program sponsored by the National Independent

Automobile Dealers Association.

23. The purchase of an NIADA CPO automobile from a qualified, scrupulous dealer

has three primary benefits: (1) the automobile undergoes a 125-point inspection by a qualified

mechanic, (2) the buyer receives a complete vehicle history report, such as a CARFAX, and (3)

the purchase includes a 10-year/100,000-mile powertrain warranty.

24. Under the NIADA program, these benefits are pre-existing features built into the

price of the automobile without any additional cost to the buyer. NIADA certification is not an

add-on product purchased in addition to the automobile itself.

25. All of Respondents’ websites (worldautocars.com, automaniaonline.com,

luxuryautomotiveclub.com) advertise the features and benefits provided with an NIADA CPO

automobile, using promotional materials provided by the NIADA. However, Respondents do not

provide any of the advertised features or benefits of the NIADA CPO program.

A. Respondents falsely claim that their automobiles are NIADA CPO.

26. Respondents maintained a website at worldautocars.com from some time before

March 14, 2019 until about November 6, 2020. During that time, World Auto exclaimed on the

top of every page of the website that it was “THE HOME OF CERTIFIED PRE-OWNED

VEHICLES,” and it displayed the NIADA CPO Certified logo prominently throughout the

website. Every automobile offered for sale on worldautocars.com was labelled “certified” or

“certified pre-owned.”

27. From at least May 12, 2020 to present, Respondents have advertised on

automomaniaonline.com that automobiles offered for sale at Automania are NIADA CPO, with

the NIADA CPO logo displayed prominently throughout the website.

28. From at least September 17, 2020 to present, Respondents have advertised on
7
luxuryautomotiveclub.com that automobiles offered for sale at LAC are NIADA CPO. Every

automobile offered for sale on luxuryautomotiveclub.com is labelled “certified” or “certified pre-

owned.”

B. Respondents do not conduct the advertised 125-point inspection.

29. Respondents advertise that their NIADA CPO automobiles undergo a 125-point

inspection by one of “our licensed mechanics,” and make available on their websites a sample

copy of the NIADA 125-point inspection checklist. See Exhibit A.

30. NIADA requires that the qualified mechanic conducting the inspection on the

dealer’s behalf complete the NIADA checklist, checking off every one of the 125 items to be

inspected. The mechanic then prints and signs their name above a certification statement. The

buyer is given a copy of this inspection form, and also signs it, acknowledging receipt of the

inspection checklist and a vehicle history report.

31. Respondents do not complete, maintain, or provide consumers with a copy of the

NIADA inspection checklist. In response to DCWP document requests, Respondents did not

provide a single NIADA 125-point inspection checklist, and admitted that the automobiles in their

inventory only underwent an “official NYS Inspection,” not the 125-point NIADA inspection.

32. Indeed, Respondents sold numerous second-hand automobiles that would not pass

NIADA’s 125-point inspection. For example:

a. Selina Cruz and Jhonikar Almanzar bought a purportedly NIADA CPO 2017

Nissan Pathfinder from Respondents on March 20, 2020. Immediately after

buying it, they discovered the Pathfinder had numerous mechanical problems

that would have prevented it from passing the 125-point inspection: emissions

failed to meet required standards (checklist item #13), the heated seats did not

work (#43), the interior overhead light did not work (#54), windshield wipers
8
 were broken (#58), side-view mirror controls did not work (#62), there was

an abnormal wind noise (#92), and the air-conditioning did not work (#99).

Respondents failed to repair most of these defects and refused to take the

automobile back.

b. Respondents sold a purportedly NIADA CPO 2017 Volkswagen Passat to

Antonio Flores and Mayra Plaza. Six weeks and 396 miles later, one of the

tires blew out because of dry rot (cracking in tires, #82, #83). Respondents

refused to pay for or replace the Passat’s tires.

c. Respondents sold a purportedly NIADA CPO 2018 Mercedes GLC to Patrick

Allala despite the remote keyless entry not working (#32) and the rear

windshield wiper missing (#58, #59, #60).

d. Respondents sold a purportedly NIADA CPO 2017 Kia Sportage to Tracy

Weeks that had a broken air conditioner (#46).

e. Respondents sold a purportedly NIADA CPO 2017 Honda Civic to Gabriel

Rojas that had rusted brakes (#86), which cost him $529.25 to repair.

f. Respondents sold purportedly NIADA CPO automobiles to Christopher Reid

(2016 Acura MDX), Ely Isabel Yill Gomez (2014 Infiniti Q50), and Earl

Atkinson (2018 Infiniti QX60) despite the automobiles each being subject to

at least one open safety recall (#12).

33. Respondents have falsely claimed that their automobiles undergo a 125-point

inspection on worldautocars.com every day from on or before March 14, 2019 to October 21, 2020,

on automania.com every day from on or before May 12, 2020 to present, and on

luxuryautomotiveclub.com from September 17, 2020 to present.

9
 C. Respondents do not provide consumers with a vehicle history report.

34. Despite their claims, Respondents often fail to provide consumers with a vehicle

history report.

35. A vehicle history report is a document that shows the history of an automobile,

including its various owners, any service that was performed to the vehicle, any damage the

automobile has suffered, and any accidents the automobile was a part of, among other pieces of

information. A CARFAX report is a vehicle history report.

36. Respondents failed to provide vehicle history reports to at least Selina Cruz (2017

Nissan Pathfinder), Antonio Flores and Mayra Plaza (2017 Volkswagen Passat), Samuel Perez

(2014 Nissan Maxima), Patrick Allala (2018 Mercedes GLC), and Gabriel Rojas (2017 Honda

Civic).

D. Respondents do not provide consumers with the advertised limited warranty.

37. Respondents have prominently advertised on all three of their websites that their

NIADA CPO automobiles come with a 10-year/100,000-mile powertrain warranty, plus roadside

assistance, emergency trip interruption coverage, and car rental reimbursement.

38. LAC makes the additional claim that the warranty is “honored at ANY

corresponding dealership within the U.S. or Canada.” (emphasis in original).

39. These claims were advertised on worldautocars.com from at least October 24, 2019

to October 21, 2020, on automaniaonline.com since at least May 12, 2020 and continuing today,

and on luxuryautomotiveclub.com since at least September 17, 2020 and continuing today.

40. Indeed, All NIADA CPO automobiles are supposed to come with a ten-

year/100,000-mile powertrain warranty with roadside assistance, emergency trip interruption

coverage, and car rental assistance at no charge.

41. However, many consumers who buy a purported NIADA CPO automobile from

10
Respondents are not given any documentation of any warranty whatsoever. And in their retail

installment contracts (“RICs”), which memorialize the sale and financing terms of each deal,

Respondents expressly deny any warranties (other than those required by law) unless the consumer

has a documented warranty.

E. Respondents charge consumers for illusory vehicle service contracts.

42. In lieu of providing consumers with the promised free 10-year/100,000-mile

powertrain warranty, Respondents sell hundreds of VSCs.

43. VSCs are similar to—and often confused with—warranties. Whereas a warranty is

included in the automobile’s price, a VSC, sometimes called an “extended warranty,” is an add-

on product sold to consumers for an additional price. 11 Respondents’ warranties and VSCs are

administered by a third-party.

44. VSCs sold by Respondents often provide less coverage for shorter periods of time

compared to Respondents’ promised warranty. For example:

a. Respondents failed to provide Araceli Marquez-Fuentes with the 10-

year/100,000-mile powertrain warranty for her 2015 Jeep Cherokee. Instead,

they misrepresented to her that the finance company required her to buy a

VSC called Performance First Image Guard, which has a term of only five

years and does not cover any powertrain components.

b. Instead of giving Darling Betancourt Peralta the advertised 10-year/100,000-

mile powertrain warranty on his 2018 Mazda CX-9, Respondents sold him—

for $3,250—a 4-year/45,000-mile “Total Exclusionary” VSC, misleadingly

omitting that it excludes repairs to the powertrain, among other things.

11
See Colleen Tressler, FTC Consumer Information Blog, Auto Warranties and Service Contracts 101,
https://www.consumer.ftc.gov/blog/2015/01/warranties-and-service-contracts-101 (Jan. 15, 2015).
11
 Indeed, when the Mazda’s engine failed 16 months later, the VSC provider

refused to cover any of the $8,766.53 repair cost.

c. Respondents sold the same Total Exclusionary VSC to Tracy Weeks for

$2,485, misrepresenting to her that it covered “everything” on her 2017 Kia

Sportage for five years. She was also not provided with the advertised 10-

year/100,000-mile powertrain warranty.

d. Respondents also sold a six-year Total Exclusionary VSC to Gabriel Rojas

for $3,180, misrepresenting to him that it was a “bumper to bumper”

warranty. Respondents falsely told him that the Total Exclusionary VSC

rendered the 10-year/100,000-mile powertrain warranty unnecessary because

the Total Exclusionary VSC included powertrain coverage.

45. Therefore, the product is less valuable than the one Respondents should provide for

free as part of the NIADA CPO program. But, to make their deception even more brazen,

Respondents frequently fail to provide the VSC at all, simply pocketing the consumers’ money.

For example:

a. Respondents charged Antonio Flores and Mayra Plaza $3,250 for a VSC for

their 2017 Volkswagen Passat. When Ms. Plaza tried to file a claim, the VSC

administrator told her they did not have a VSC.

b. Respondents charged Patrick Allala $5,818 for “SERVICE CONTRACT +

ALL OTHER CHAR” for the 2018 Mercedes-Benz GLC 300 he purchased.

Respondents then charged him another $3,985 for a VSC. Dr. Allala did not

want the VSC, but Respondents misrepresented to him that they could not sell

the car without it. When Dr. Allala called the warranty and VSC

12
 administrator, he was told that although he had the NIADA powertrain

warranty, they had no record of his $3,985 VSC.

46. Respondents are able to deceive consumers about their warranty and VSC coverage

because they only give consumers the first page of the VSC, which does not show the complete

terms, conditions, and coverage exclusions and limitations. Consumers only receive their complete

warranty or VSC by later requesting it from the warranty or VSC administrator.

II. Falsely Advertised Prices and Added Fees

A. Respondents charge consumers prices for second-hand automobiles far above what they
advertise online.

47. Respondents have misrepresented their prices daily on worldautocars.com from

March 16, 2019 to October 21, 2020; on automaniaonline.com from at least May 16, 2020 through

the present; and on luxuryautomotiveclub.com from at least January 6, 2021 through the present.

48. DCWP compared the cash sale prices of 119 automobiles sold by Respondents to

their prices advertised on worldautocars.com. 12 Respondents sold all 119 above the advertised

price. See Exhibit B.

49. DCWP compared the cash sale prices of 84 automobiles sold by Respondents to

their prices advertised on automaniaonline.com. Respondents sold all 84 above the advertised

price. See Exhibit C.

50. DCWP compared the cash sale prices of five automobiles sold by Respondents to

their prices advertised on luxuryautomotiveclub.com. Respondents sold all five above the

advertised price. See Exhibit C.

12
“Cash price” or “cash sale price” refers to the price of an automobile before taxes, itemized fees, and
finance charges.
13
 B. Respondents invent fake fees to account for their higher-than-advertised prices.

51. The only fees SHADs may legally collect in addition to the sale price of an

automobile are taxes, and fees paid to government entities on the buyer’s behalf related to title and

registration, and a fee payable to the dealer if they provide that service to the buyer.

52. Respondents convince consumers to accept their inflated prices by flouting this

restriction, charging illegal fees that they often fabricate entirely.

53. Respondents do not itemize the fake fees in their bills of sale or RICs where they

would catch the attention of finance companies, NIADA, or the Department. Instead, Respondents

roll the fictitious fees into the automobile’s cash price, communicating the fees to consumers orally

or through a document that is not made a part of the sales contract.

54. Respondents routinely tell consumers that they are required to pay an additional

“certification fee,” which is expressly prohibited by NIADA. But, the fake certification fee is just

the beginning. For example:

a. Samuel Perez visited World Auto after finding a 2014 Nissan Maxima offered

for sale by the dealer on cargurus.com for $14,400. 13 It was not until Mr.

Perez was at the dealership and had decided to buy the car that the salesperson

told him there would be an additional $2,800 certification fee. The finance

manager then surreptitiously added another unexplained $2,287 to the cash

price.

b. Kishauna McLaurin visited World Auto after finding a 2014 Infiniti Q50

advertised by Respondents on Capital One’s website for $17,580.

Respondents charged her a cash price of $22,407, including a fee for the fake

13
Prices on cargurus.com are provided by the advertising dealer.
14
 certification.

c. Araceli Marquez-Fuentes found a 2015 Jeep Cherokee advertised by World

Auto on carfax.com for $16,995. She called World Auto, who confirmed the

$16,995 price, but when she arrived at the dealer, they told her there was a

$3,600 “certification fee” in addition to the price of the car. She wound up

paying $8,385 above the advertised price.

d. Antonio Flores and Mayra Plaza found a 2017 Volkswagen Passat at LAC

with a $12,000 price displayed on it but were charged a cash price of $17,500

for the car. The additional $5,500 was largely unexplained, but Mr. Flores

was given an unsigned contract for a $1,979 theft deterrent system that was

never requested or installed. Furthermore, Respondents charged $6,884 to

Mr. Flores’s credit cards for the down payment, but only credited him $6,800,

claiming—only verbally—that the remaining $84 was for credit card fees.

e. Respondents sold a 2018 Mercedes GLC to Patrick Allala for a cash price of

$34,095 despite it being advertised at $24,871. When asked by Dr. Allala to

account for the $9,224 discrepancy, Respondents wrote on a separate

document, “SERVICE CONTRACT + ALL OTHER CHAR (5000+)” and

“CAPITAL ONE APR (10%) $3,406.” Respondents then—on top of the cash

price—charged Dr. Allala another $3,985 for a VSC they claimed was

required, and another $15,291.20 for Capital One’s actual finance charges, of

which $1,404.89 is effectively interest on the fake finance charges.

f. Respondents sold a 2017 Honda Civic to Gabriel Rojas for an “internet

special price” of $15,795, then added an illegal $4,995 certification fee and

15
 an illegal $995 “dealer prep” fee, plus another unexplained $1,995, bringing

the cash price to $23,780.

C. Respondents misrepresent to out-of-state residents the amount due for sales tax, title and
registration, and pocket the difference.

55. When New York dealers, including Respondents, sell an automobile, they usually

arrange title and registration, and collect and remit taxes and fees to government agencies on their

customers’ behalf. Dealers are permitted to charge a separately itemized fee for this service: $75

prior to August 18, 2021, now $175. 14 Fees payable to the government are calculated by the dealer

and itemized on the bill of sale and RIC. Tax, title, and registration fees are determined by and

paid to the state in which the automobile will be registered.

56. When Respondents perform this service for their customers who live outside New

York State, they misrepresent the amount payable to the state for tax, title, and registration.

57. Respondents overcharged out-of-state residents for tax, title, and/or registration in

all thirty of such transactions reviewed by the Department. See Exhibit D.

58. The fees for title and registration of an automobile in New Jersey range from

$131.50 to $169, depending on the automobile’s model year and weight. 15 Respondents charged

at least 16 New Jersey residents between $262 and $400 for title and registration fees.

59. The fees for title and registration of an automobile in Connecticut total $190.16

Respondents charged at least eight Connecticut residents between $350 and $412 for title and

registration fees.

14
See NYS Register, August 18, 2021, p. 20; 15 NYCRR §§ 77.8, 77.19.
15
See New Jersey Motor Vehicle Commission, Vehicles, Licensing, Registration and Regulations,
https://nj.gov/nj/trans/vehicles (last accessed Sept. 16, 2021).
16
See Conn. Dept. of Motor Vehicles, How to Register Your New Vehicle of Vessel,
https://portal.ct.gov/DMV/CIVLS---Modernization/Registration-CIVLS/Expected-Documents#passcl
(last accessed Sept. 16, 2021).
16
 60. The fees for title and registration of an automobile in Pennsylvania total $164. 17

Respondents charged at least four Pennsylvania residents between $350 and $425 for title and

registration fees.

61. Respondents collected $1,464.12 for Virginia sales tax and $312 for government

fees from Kishauna McLaurin but paid only $933 in sales tax and $12 in fees on to the

Commonwealth of Virginia on her behalf.

62. Respondents also overcharged consumers from Florida, Massachusetts, Maryland,

and Rhode Island for government fees.

III. Misleading and Confusing Disclaimers

63. Every webpage advertising an automobile on Respondents’ websites contains a

lengthy, dense block of text written in a tiny light gray font on white background at the very bottom

of the webpage (the “Fine Print”). This Fine Print includes material exclusions, reservations,

limitations, modifications that confuse, materially modify, and unreasonably limit the principal

message of the advertisements, which is the prominently displayed price.

64. All of Respondents’ Fine Print is less than one-third the size of the largest text on

the webpage on which the Fine Print appears.

65. To further obscure material terms and conditions, Respondents hide them in

paragraphs full of meaningless text giving the reader the misimpression that there is no important

information contained in the block.

66. Although the content of Respondents’ Fine Print changes from time to time and

website to website, the following text for a 2019 Nissan Altima advertised on

automaniaonline.com on May 19, 2021 is typical:

See Penn. Bureau of Motor Vehicles Schedule of Fees (MV-70S),

17
available at
https://www.dot.state.pa.us/Public/DVSPubsForms/BMV/BMV%20Forms/MV-70S.pdf.
17
 * Welcome to Automania, Located at Woodside, NY., where Complete Customer
Satisfaction and Remarkable Quality of service comes first. We are here to help
you find a vehicle that best fits your lifestyle from our selection of used cars,
Minivans and SUVs. We perform a Multiple Point Inspection by New York State
licensed technicians to ensure that it meets the safety and quality standards
completely & give our customers a piece of mind with their purchase. You are not
going to be sold a car that has a reported accident, structural damage or possess
signs of collisions. Free Carfax car history report is available on every single
vehicle we sell. All cars are sold cosmetically As-Is. We want to ensure that our
customers receive full transparency on any vehicle which they intend to buy.
Please call to verify availability of vehicle prior to visit. Dealer is not responsible for
any errors to this listing, accuracy, description or condition of the listed vehicle's
equipment, accessories, price, specials, or any warranties. All Internet special
pricing is valid until 12:01AM. Must bring an ad to take full advantage of internet
special price. All pricing and details are believed to be accurate, but we do not
warrant or guarantee such accuracy. Prices subject to change. APR is subject to
customer credit worthiness. Zero down is also available for qualifying customers.
All vehicles are special promotions Prices are subject to change daily based on
vehicle market value. The internet advertised price excludes all other offers and
discounts and does not include: (i)applicable taxes/fees, including sales, use and
tire taxes/fees; (ii) title/license plate/registration/DMV fees; (iv) vehicle inspection
fees (v) vehicle destination and transportation costs; (vi)
repair/rehabilitation/reconditioning costs and fees incurred by the dealer,
including but not limited to brakes, tires, and fluids; (vii) dealer
document/service/prep/processing fees; (viii) finance charges; and (ix) any
additional fees required by law. Prices also exclude any additional charges
included with the cost of closing/financing, including any governmental charges
and taxes, any finance charges, documentation, preparation or VSC. The in-store
price may exceed our special online pricing. Sorry but we cannot extend special
pricing without a printed copy of the on-line pricing. To take advantage of our
special Internet discounts, please print this page and present it to your salesperson
at the BEGINNING of the transaction. Special Internet pricing posted on this
ad/coupon/promotion is only available to customers who reference such pricing
& present the ad at time of sale otherwise our store standard list price applies.
Please be advised this ad is a Special Internet only ad. Prices can be modified and
adjusted weekly, daily, and sometimes hourly due to inquiries, bidding and website
traffic on any particular Vehicles. Call us today At 718-255-1353 to schedule your
test drive. se habla español.

(font type and size as in original).

67. Respondents’ Fine Print often includes a hidden requirement that the consumer

must print and present the internet advertisement to the dealer in order to purchase the automobile

at the advertised price. This material limitation appears in the fine print of the following websites

on the following dates:

a. worldautocars.com from at least March 14, 2019 through October 21, 2020

(“All Internet special pricing is valid only for up to 24 Hours after ad is printed

out. Must bring ad to take full advantage of internet special price.”);

18
 b. automaniaonline.com from at least December 11, 2020 to present (“To take

advantage of our special Internet discounts, please print this page and present

it to your salesperson at the BEGINNING of the transaction.”); and

c. luxuryautomotiveclub.com from at least December 11, 2020 to present.

68. Although Respondents’ hidden Fine Print describes the price as an internet special,

there are no conspicuous notices of any price being a special discount, nor what the price of each

automobile would be without such special discount.

69. Respondents’ Fine Print frequently includes some hidden requirement that the

consumer must finance through the dealer to get the advertised price, which is prohibited by NYC

Code § 20-268.1(a). This material limitation appears in the Fine Print of the following websites on

the following dates:

a. worldautocars.com from at least March 14, 2019 through October 21, 2020;

d. automaniaonline.com from at least May 12, 2020 through November 30,

2020; and

e. luxuryautomotiveclub.com from at least September 17, 2020 through

November 30, 2020.

70. Respondents’ Fine Print sometimes purports to add thousands of dollars to the

advertised price. For example:

a. from at least June 20, 2019 through October 21, 2020, the Fine Print on

worldautocars.com stated that the automobiles’ advertised prices were after a

$1,995 down payment;

19
 b. from at least May 12, 2020 through November 30, 2020, the Fine Print on

automaniaonline.com stated that the automobiles’ advertised prices were after

a $1,995 down payment; and

c. from at least September 17, 2020 through November 30, 2020, the Fine Print

on luxuryautomotiveclub.com stated that the automobiles’ advertised prices

were after a $2,995 down payment.

IV. Other Illegal Sales Practices

A. Respondents fail to provide accurate Cancellation Option forms to consumers.

71. City law requires SHADs to give consumers an opportunity to review the terms of

sale and financing of their automobile purchase for two weekdays and to cancel the transaction

within that timeframe for any reason, or no reason at all (the “NYC Used Car Cancellation

Option”). Respondents do not adequately inform—and often misinform—consumers about the

NYC Used Car Cancellation Option.

72. SHADs must provide each consumer with a NYC Used Car Cancellation Option

form, which notifies consumers of the deadline to cancel their automobile purchase. Respondents

failed to fill in this deadline on every one of 43 NYC Used Car Cancellation Option forms reviewed

by DCWP. See Exhibit E, p. 1.

73. Respondents often fail to provide consumers with the NYC Used Car Cancellation

Option form at all. See Exhibit E, p. 2.

74. Selina Cruz for example did not know the cancellation option existed until she

attempted to return the Pathfinder (within the two-day period) and Respondents refused to take it

back.

75. Gabriel Rojas asked Respondents to allow him to take his paperwork home to

review before committing to the purchase of a 2017 Honda Civic. Respondents told him he had to

20
“sign today,” and failed to inform him of the NYC Used Car Cancellation Option. Two days later,

having had a chance to review his paperwork, Mr. Rojas tried to cancel the contract, but

Respondents told him if he cancelled, they would keep his $3,000 down payment and his $2,800

trade in.

76. While Ms. Marquez-Fuentes was completing paperwork for her purchase of a 2015

Jeep Cherokee, Respondents misrepresented to her that she could not cancel without losing her

$15,000 down payment, even though the transaction had not even been completed.

D. Respondents use illegal contingency clauses.

77. When consumers finance their automobile purchase through the dealer,

Respondents compel consumers to execute an “Addendum to Buyer’s Order: Contingency

Clause.”

78. The contingency clause purports to condition the sale on “your final credit approval

from the assignee [] and the actual assignment of the agreement from [Respondents] to the

Assignee.” The agreement purports to grant the consumer “temporary possession” of the

automobile and requires the consumer to return it within 24 hours if Respondents fail to assign the

RIC.

79. Respondents also compel financing consumers to execute a “Lender Verification

Acknowledgment” similarly purporting to condition the sale on Respondents’ ability to assign the

RIC.

80. Such conditions are illegal under City law. See NYC Code § 20-268.1(b). This is

because, historically, SHADs have used such contingency clauses to coerce consumers into less

advantageous financing terms after taking possession of the automobile.

81. Respondents compelled at least 16 consumers to sign one or both contingency

clauses. See Exhibit F.

21
 E. Respondents misrepresent financing terms on Financing Disclosure Forms or fail to
provide the forms at all.

82. SHADs must give a Financing Disclosure form to every consumer who finances

the purchase a second-hand automobile, using a form created and made available by DCWP. See

6 RCNY § 2-106.

83. Respondents have failed on numerous occasions to provide consumers with

complete and accurate copies of the Financing Disclosure form.

84. For the following retail sales, Respondents entered an amount for “total sale price

of automobile with all selected add-ons and financing charges” that does not match the Total Sale

Price on the RIC: Jessica M. Avelar (2016 Nissan Sentra), Malcolm Myers (2018 Dodge Charger),

Roybert A. Rotundo (2016 Audi A6), Kylee Rae Verrill (2016 Honda Accord).

85. On the Financing Disclosure form for Joe Benitez’s purchase of a 2016 Jeep

Cherokee, Respondents entered a false Automobile Cash Price without Add-on Products and

Services, a false Total Cash Price without Add-on Products and Services, a false Total Sale Price

without Add-on Products and Services, and a false Total Sale Price with All Selected Add-ons and

Finance Charges.

86. The Financing Disclosure form for Sanjit Das’s purchase of a 2015 Lexus RX lists

the APR as 0%, but it is 5.29% on the RIC.

87. Respondents failed to give copies of the Financing Disclosure form to Dr. Allala

(2018 Mercedes GLC), Mr. Atkinson (2018 Infiniti QX60), Mr. Betancourt Peralta (2018 Mazda

CX-9), Ms. Cruz (2017 Nissan Pathfinder), Mr. Flores and Ms. Plaza (2017 Volkswagen Passat),

Ms. Marquez-Fuentes (2015 Jeep Cherokee), Mr. Rojas (2017 Honda Civic), and Ms. Weeks

(2017 Kia Sportage). On copies provided to the Department, Respondents miscalculated sales tax

on Ms. Cruz’s form, and failed to itemize the tire and wheel insurance on Ms. Marquez-Fuentes’s

22
form.

88. The Financing Disclosure form for Robert Spagnoli’s purchase of a 2016 Jeep

Grand Cherokee is illegible. It cannot be compared to the RIC for the sale because Respondents

failed to produce it, even though it was requested in a subpoena.

89. Similarly, although requested in a subpoena, Respondents failed to produce a

completed financing disclosure form for Wilber Tobar’s purchase of a 2015 Jeep Grand Cherokee.

F. Respondents misrepresent automobile and add-on prices on retail instalment contracts.

90. Respondents charge consumers thousands of dollars for add-on products of dubious

value, such as tire and wheel insurance and theft deterrent systems. Respondents do not itemize

these add-on products on their RICs; instead, they just add them to the cash price of the automobile.

This has the effect of misleading consumers and the assignee finance companies about the true

cash price of the automobile and the existence of add-on products. It also violates the federal Truth

in Lending Act, which requires “a separate written itemization of the amount financed, including

. . . [a]ny amounts paid to other persons by the creditor on the consumer’s behalf.” 12 C.F.R. §

1026.18(c)(1)(iii).

91. Respondents failed to itemize the price of add-on products on RICs for at least 16

transactions. See Exhibit G.

92. The sale of a 2016 Jeep Grand Cherokee to Joe Benitez demonstrates how

Respondents’ misrepresentations on the RIC and Financing Disclosure converge to confuse the

consumer and mislead the finance company about the cost of the automobile and add-on products.

Respondents sold Mr. Benitez a 2016 Jeep Grand Cherokee for $18,984, plus a VSC for $3,295,

plus some mysterious thing called a “5 pack” for $2,895. These three elements are itemized on the

bill of sale. On the RIC, Respondents did not separately itemize the 5 pack, but rolled it into the

price of the car. And on the Financing Disclosure form, Respondents separately itemized the 5
23
pack and rolled it into the price of the car. If one believes the bill of sale, Mr. Benitez paid $18,984

for the car and bought a 5 pack for $3,295. If one believes the RIC, Mr. Benitez paid $21,879 for

the car, and did not buy the 5 pack. If one believes the Financing Disclosure form, Mr. Benitez

paid $21,879 for the car and another $3,295 for the 5 pack.

G. Respondents failed to provide Spanish-language documents for sales conducted in Spanish.

93. Respondents advertise “se habla español,” and negotiate the sale of second-hand

automobiles in Spanish, but Respondents do not provide consumers with any documents in

Spanish.

94. Respondents negotiated the sale of a 2015 Jeep Cherokee to Ms. Marquez-Fuentes

in Spanish, but all of the documents related to the sale were in English without Spanish translation,

including the RIC, bill of sale, buyer’s order, contingency clause, arbitration agreement, lender

verification, contract cancellation option form, financing disclosure form, credit application, recall

disclosure, gap liability notice, vehicle service contract application, consumer bill of rights, power

of attorney, and down payment receipt.

95. Respondents negotiated the sale of a 2018 Mazda CX-9 to Mr. Betancourt Peralta

in Spanish, but all of the documents related to the sale were in English without Spanish translation,

including the RIC and VSC.

V. Deceptively Intermingled Operations

96. Respondents use their business entities and trade names—both authorized and

unauthorized—interchangeably to misrepresent and obscure the identity of the selling dealer for

their retail sales. Often, the only way to discern which business entity is which is by address or

New York Department of Motor Vehicles (“DMV”) registration number.

97. For example, on March 20, 2020, Ms. Cruz and Mr. Almanzar visited JF2 at 6020

(d/b/a NYC Motorcars at the time) to look at a Nissan Pathfinder they found on cars.com. When

24
JF2 at 6020 tried to charge them added fees, they decided to shop elsewhere, eventually visiting

Automania at 5511 Northern Boulevard, having no idea that the businesses were related. The

salesperson at Automania told them she had a Pathfinder they would like, but it was at another

location. When the salesperson took them to see it, they found themselves back where they started

at JF2 at 6020, looking at the original Pathfinder they had already considered and rejected because

of the surprise fees. Worn down and thinking they were stuck with added fees either way, Ms.

Cruz and Mr. Almanzar gave up and bought the Pathfinder at JF2 at 6020.

98. As bad as the runaround was, the transaction paperwork tells a different, more

complicated, and illegal story. According to Respondents’ records submitted to the DMV, on the

day of the sale to Ms. Cruz and Mr. Almanzar, title to the Pathfinder was held by Best Luxury

Motors, LLC d/b/a NYC Motorcars located at 1231 Hempstead Turnpike in Nassau County (not

to be confused with Best Luxury Motors 2, LLC or JF2 at 6020 d/b/a NYC Motorcars). 18 State law

prohibits a dealer from displaying a vehicle “unless he owns the vehicle or has it on consignment.”

See NYCRR § 78.16(c). It was therefore illegal for Respondents to display or offer the Pathfinder

for sale at 6020 Northern Boulevard. 19

99. But it gets worse. According to DMV records and the bill of sale, Best Luxury

Motors, LLC transferred title for the Pathfinder to Automania 45 minutes before Automania

transferred title to Ms. Cruz and Mr. Almanzar. But, according to the RIC, World Auto sold the

Pathfinder to Ms. Cruz and Mr. Almanzar. None of these three dealers were licensed to sell second-

hand automobiles at the location where the sale took place: 6020 Northern Boulevard.

18
Best Luxury Motors, LLC, of which Khan was sole member, filed Articles of Dissolution on December
22, 2020.
19
JF2 did not have the Pathfinder on consignment because it did not produce the required consignment
letter in response to a subpoena from DCWP. See NYCRR § 78.40.
25
 A. Respondents misrepresent the identity of the selling dealer on RICs.

100. Many of Respondents’ retail sales name different dealers on different documents

for the same transaction. The selling dealer named on the RIC is often different than the selling

dealer named on the bill of sale and/or the book of registry 20 for the same sale.

101. DCWP reviewed records for 155 financed sales by World Auto between June 18,

2016 and June 14, 2020. Even though World Auto’s book of registry shows that World Auto sold

these cars, 35 of the RICs identify NYC Motorcars of Freeport Corp. as the seller, six identify

Automania, two identify NYC Motorcars of Woodside, and two identify LAC. See Exhibit H.

102. NYC Motorcars of Freeport Corp. is not licensed to deal in second-hand

automobiles in New York City; there is no DCWP-licensed entity nor business registered with

DOS under the name or trade name NYC Motorcars of Woodside; and World Auto is not

authorized to do business as Automania or LAC.

103. DCWP reviewed records of 33 financed sales by Automania between March 20,

2020 and March 8, 2021. Although the bills of sale identify Automania as the selling dealer, 24 of

the RICs identify World Auto as the seller, eight identify “Luxury Automotive Club” (JF2 at 6020),

and only one identifies Automania. See Exhibit I. Automania is not authorized to do business as

World Auto or JF2 at 6020.

104. DCWP reviewed records of 14 financed sales by LAC. Although all the bills of sale

identify LAC as the selling dealer, five of the RICs identify World Auto as the selling dealer, and

two identify JF2 at 6020 as the selling dealer. See Exhibit J. LAC is not authorized to do business

as World Auto or JF2 at 6020..

20
“Book of registry” refers to the records every motor vehicle dealer in New York State must maintain in
which the dealer records a complete description of all vehicles acquired for purpose of sale, traded or sold,
including the person to whom the vehicle is sold. See 15 NYCRR § 78.25.
26
 H. Respondents engage in unlicensed activity.

105. NYC Motorcars of Freeport Corp. executed no fewer than 35 RICs for sales at 4309

Northern Boulevard in Queens from November 17, 2018 until November 19, 2020, at which time

a SHAD unrelated to Respondents took over the premises. NYC Motorcars of Freeport Corp. has

never been licensed as a SHAD in New York City.

VI. Recidivism

106. Respondents have previously committed violations of the SHAD laws and rules

that subject them to increased penalties pursuant to NYC Code § 20-275(c).

107. On October 17, 2018, World Auto was issued Summons No. 05432208 for violating

NYC Code § 20-271(b)(1) by failing to post the total selling price on or near each second-hand

automobile offered for sale. World Auto pleaded guilty to the violation.

108. On April 10, 2019, JF2 at 6020 Northern Boulevard was issued Summons No.

05446677 for violating 6 RCNY § 2-105(b) by failing to properly display the price of add-on

products. JF2 at 6020 pleaded guilty to the violation.

109. On May 17, 2019, World Auto was issued Summons No. 05446970 for violating

NYC Code § 20-268.5(a)(4) by failing to maintain physical or electronic copies of each signed

automobile contract cancellation option document. World Auto pleaded guilty to the violation.

110. On November 19, 2019, JF2 at 6020 Northern Boulevard was issued Summons No.

05452811 for violating NYC Code § 20-271(b)(2) by failing to display the price of add-on

products. JF2 at 6020 pleaded guilty to the violation.

111. On December 11, 2019, Automania at 55-11 Northern Boulevard was issued

Summons No. 05446318 for violating NYC Code § 20-268.5(a)(4) for failing to maintain physical

or electronic copies of each signed automobile contract cancellation option document, and for

violating 6 RCNY 2-109(a) by failing to retain a copy of the Consumer Bill of Rights signed by

27
the consumer. Automania pleaded guilty to the violations.

112. On December 29, 2020, JF2 at 6020 Northern Boulevard was issued Summons No.

20Q01112 for violating 6 RCNY § 2-105(c) a second time. JF2 at 6020 was found guilty of the

violation by default.

VIOLATIONS

COUNT ONE
Engaging in deceptive trade practices, in violation of NYC Code § 20-700
(at least 7,608 violations—some violations ongoing)

113. NYC Code § 20-700 prohibits “any deceptive or unconscionable trade practice in

the sale, lease, rental or loan or in the offering for sale, lease, rental, or loan of any consumer goods

or services, or in the collection of consumer debts.” 21

114. NYC Code § 20-701(a) defines a deceptive trade practice as “[a]ny false, falsely

disparaging, or misleading oral or written statement, visual description or other representation of

any kind made in connection with the sale, lease, rental or loan or in connection with the offering

for sale, lease, rental, or loan of consumer goods or services, or in the extension of consumer credit

or in the collection of consumer debts, which has the capacity, tendency or effect of deceiving or

misleading consumers.”

115. NYC Code § 20-701(a) provides that deceptive trade practices include, but are not

limited to, the following:

(1) representations that goods or services have sponsorship,

approval, accessories, characteristics, . . . uses, benefits, or
quantities that they do not have; the supplier has a[n] . . . approval
[or a] status . . . that he or she does not have; . . . or, goods or services

21
On August 26, 2021, the City Council passed Local Law 98 of 2021, which amends the CPL, effective
January 25, 2022. The amended CPL, among other things, increases the penalty amount per violation, from
a range of $50-$350 per violation to $350-$2,500 per violation, with an increase in the amount for
“knowing” violations from $500 per violation to $3,500 per violation. In this case, the Department will seek
the increased penalties provided by the amended CPL only if violations occur after January 24, 2022.
28
 are of a particular standard, quality, grade, style or model, if they are
of another;

(2) the use, in any oral or written representation, of exaggeration,

innuendo or ambiguity as to a material fact or failure to state a
material fact if such use deceives or tends to deceive; . . .

(4) offering goods or services with intent not to sell them as offered;

(5) offering goods or services with intent not to supply reasonable

expectable public demand . . .

(6) making false or misleading representations of fact concerning

the reasons for, existence of, or amounts of price reductions, or price
in comparison to prices of competitors or one's own price at a past
or future time;

(7) stating that a consumer transaction involves consumer rights,

remedies or obligations that it does not involve.

116. Respondents committed at least 1,538 violations of NYC Code § 20-700 by falsely

claiming that the automobiles they offer for sale are NIADA Certified Pre-Owned. Respondents

made such claims on worldauto.com every day from on or before March 14, 2019 to October 21,

2020, on automania.com every day from on or before May 12, 2020 to present, and on

luxuryautomotiveclub.com from September 17, 2020 to present.

117. Respondents committed at least 1,538 violations of NYC Code § 20-700 by falsely

claiming that the automobiles they offer for sale have passed a 125-point inspection. Respondents

made such claims on worldauto.com every day from on or before March 14, 2019 to October 21,

2020, on automania.com every day from on or before May 12, 2020 to present, and on

luxuryautomotiveclub.com from September 17, 2020 to present.

118. Respondents committed at least 1,314 violations of NYC Code § 20-700 by falsely

claiming that the automobiles they offer for sale come with a 10-year/100,000-mile warranty.

Respondents made such claims on worldauto.com every day from on or before October 24, 2019

29
to October 21, 2020, on automania.com every day from on or before May 12, 2020 to present, and

on luxuryautomotiveclub.com from September 17, 2020 to present.

119. Respondents committed at least five violations of NYC Code § 20-700 by

representing that they provide buyers of their automobiles with a complete vehicle history report

but failing to provide vehicle history reports to at least five consumers: Patrick Allala, Selina Cruz,

Antonio Flores, Samuel Perez, and Gabriel Rojas.

120. Respondents committed at least 1,538 violations of NYC Code § 20-700 by offering

second-hand automobiles for sale with the intent not to sell them as offered. Specifically,

Respondents misrepresented the prices of the second-hand automobiles advertised on their

websites as being lower than their actual sale prices. Respondents have falsely advertised prices

on worldauto.com every day from on or before March 14, 2019 to October 21, 2020, on

automania.com every day from on or before May 12, 2020 to present, and on

luxuryautomotiveclub.com from September 17, 2020 to present. See Exhibits B and C.

121. Respondents committed at least 768 violations of NYC Code § 20-700 by using

ambiguity as to material facts or failure to state a material fact in a manner that deceives or tends

to deceive in that Respondents added thousands of dollars to the prominently displayed advertised

price by using fine print hidden on the bottom of its internet advertisements stating prices were

after a $1,995 to $2,995 down payment. Respondents did so on the following websites on each of

the following dates: worldauto.com from at least June 20, 2019 through October 21, 2020,

automania.com from at least May 12, 2020 through November 30, 2020, and

luxuryautomotiveclub.com from at least September 17, 2020 through November 30, 2020.

122. Respondents committed at least 866 violations of NYC Code § 20-700 by falsely

30
advertising that consumers do not have a right, per NYC Code § 20-268.1(c)(1), 22 to purchase an

automobile at the advertised price without financing on the following websites on each of the

following dates: worldautocars.com from at least March 14, 2019 through October 21, 2020,

automaniaonline.com from at least May 12, 2020 through November 30, 2020, and

luxuryautomotiveclub.com from at least September 17, 2020 through November 30, 2020.

123. Respondents committed one violation of NYC Code § 20-700 by charging Antonio

Flores $1,979 for a non-existent theft deterrent system.

124. Respondents committed four violations of NYC Code § 20-700 by misrepresenting

to Araceli Marquez-Fuentes, Darling Betancourt Peralta, Tracy Weeks, and Gabriel Rojas the parts

and services covered by their VSCs, and their VSCs’ terms and conditions.

125. Respondents committed two violations of NYC Code § 20-700 by charging

Antonio Flores and Patrick Allala $2,750 and $3,985, respectively, for non-existent VSCs.

126. Respondents committed 33 violations of NYC Code § 20-700 by misrepresenting

to 33 out-of-state consumers the amount paid by Respondents on their behalf for title and

registration fees. See Exhibit D.

127. Respondents committed one violations of NYC Code § 20-700 by misrepresenting

to consumer Kishauna McLaurin the amount of Virginia sales tax paid by Respondents on her

behalf.

COUNT TWO
Failing to disclose limitations clearly and conspicuously on offers,
in violation of 6 RCNY § 5-09(a)
(at least 1,237 violations—some violations ongoing)

128. Rule 5-09(a) requires that “[s]ellers offering consumer goods or services in print

22
“A second-hand automobile dealer shall not: (1) Require a consumer to purchase any add-on product as
a condition of purchasing a second-hand automobile or obtaining financing from a lender for the purchase
of an automobile.”
31
advertising and promotional literature must disclose clearly and conspicuously all material

exclusions, reservations, limitations, modifications or conditions. A disclosure made in print at

least one-third as large as the largest print used in the advertisement or promotional literature

satisfies this section.”

129. Respondents committed at least 914 violations of 6 RCNY § 5-09(a) by

inconspicuously adding a condition that consumers must print out the advertisement and bring it

to the dealership within 24 hours to purchase an automobile at the advertised price on the following

websites on each of the following dates: worldauto.com from at least March 14, 2019 through

October 21, 2020, and luxuryautomotiveclub.com from at least December 11, 2020 to present.

130. Respondents committed at least 323 violations of 6 RCNY § 5-09(a) by

inconspicuously adding a condition that consumers must print out the advertisement and “present

it to your salesperson at the beginning of the transaction” on automania.com each day from at least

December 11, 2020 to present.

COUNT THREE
Selling second-hand automobiles for more than the price advertised, cited,
quoted, or marked thereon, in violation of 6 RCNY § 2-103(i)
(at least 210 violations)

131. 6 RCNY § 2-103(i) states, “The selling price of an automobile by a licensed second-

hand dealer shall be the price advertised, cited, quoted, or marked thereon . . .. It shall be a violation

of this regulation for any licensee to exact a service charge, house commission or any such like

assessment above the selling price of the car.”

132. Respondents committed at least 208 violations of 6 RCNY § 2-103(i) by selling

204 second-hand automobiles for more than the price advertised on Respondents’ websites. See

Exhibits B and C.

133. Respondents committed one violation of 6 RCNY § 2-103(i) by selling a 2014

32
Nissan Maxima to Samuel Perez for more than the price advertised by Respondents on

cargurus.com.

134. Respondents committed one violation of 6 RCNY § 2-103(i) by selling a 2017

Volkswagen Passat to Antonio Flores and Mayra Plaza for more than the price displayed on the

automobile.

COUNT FOUR
Failing to offer consumers a contract cancellation option,
in violation of NYC Code § 20-268.2
(at least 50 violations)

135. NYC Code § 20-268.2(a) requires that “[p]rior to executing a bill of sale with a

consumer for the purchase of an automobile, a second-hand automobile dealer shall offer such

consumer an automobile contract cancellation option that authorizes such consumer to cancel the

sales contract. NYC Code § 20-268.2(b)(5) requires that the contract cancellation form include “[a]

statement clearly indicating the date and time by which the option to cancel the sales contract may

be exercised.” Such cancellation deadline shall be “no later than the dealer's close of business on

the second business day following the day on which either the bill of sale or the retail installment

contract was signed by such consumer, whichever such signing occurred later.” NYC Code § 20-

268.2(c).

136. Respondents committed 50 violations of NYC Code § 20-268.2 by failing to give

accurate cancellation option forms to consumers for the 50 sales listed in Exhibit E.

COUNT FIVE
Executing RICs conditioned on dealer’s ability to assign RIC to third party,
in violation of NYC Code § 20-268.1(b)
(at least 24 violations)

137. NYC Code § 20-268.1(b) prohibits dealers from including in a “retail installment

contract for the purchase of a second-hand automobile [] a term rendering the contract voidable,

33
subject to modification, or otherwise not binding upon a second-hand automobile dealer because

of such dealer’s inability or unwillingness to sell, assign or otherwise transfer the contract to a

third party after execution of the sales contract.”

138. Respondents committed at least 24 violations of NYC Code § 20-268.1(b) by

executing addendums to 24 RICs that conditioned the respective sales on Respondents’ ability to

assign the RICs to a third party. See Exhibit F.

COUNT SIX
Failing to disclose all required information concerning the cost of
financing second-hand automobiles and add-on products,
in violation of NYC Code § 20-268.1(e)(2).
(at least 15 violations)

139. NYC Code § 20-268.1(e)(2) requires that “[p]rior to the execution of any retail

installment contract, a second-hand automobile dealer that offers financing to a consumer of a

second-hand automobile or assists such consumer in obtaining financing from a lender . . . shall

provide to such consumer, in a form prescribed by the commissioner by rule, a document

containing the following disclosures: (a) The price of each add-on product to be included in such

retail installment contract; (b) The total cost of the automobile and the monthly payments,

including any amounts associated with financing, that the consumer will be required to make to

purchase the automobile (i) with each such add-on product included, (ii) without any add-on

product included, and (iii) with all such add-on products [and] (c) The lowest annual percentage

rate offered to such consumer by the financing companies from whom the dealer has solicited

financing on behalf of the consumer.”

140. The form necessary for complying with NYC Code § 20-268.1(e)(2) is provided in

6 RCNY § 2-106(a) and available on DCWP’s website.

141. Respondents committed seven violations of NYC Code § 20-268.1(e)(2) by

34
executing RICs for the following seven consumers and providing them with financing forms

containing false information: Jessica M. Avelar (2016 Nissan Sentra), Malcolm Myers (2018

Dodge Charger), Roybert A. Rotundo (2016 Audi A6), Kylee Rae Verrill (2016 Honda Accord),

Joe Benitez (2016 Jeep Cherokee), Sanjit Das (2015 Lexus RX), and Robert Spagnoli (2016 Jeep

Grand Cherokee).

142. Respondents committed eight violations of NYC Code § 20-268.1(e)(2) by

executing RICs for the following eight consumers and failing to provide them with financing

disclosure forms: Patrick Allala (2018 Mercedes GLC), Earl Atkinson (2018 Infiniti QX60), Selina

Cruz (2017 Nissan Pathfinder), Antonio Flores (2017 Volkswagen Passat), Araceli Marquez-

Fuentes (2015 Jeep Cherokee), Darling Betancourt Peralta (2018 Mazda CX-9), Gabriel Rojas

(2017 Honda Civic), and Tracy Weeks (2017 Kia Sportage). 23

COUNT SEVEN
Providing false information to a finance company,
in violation of NYC Code § 20-268.1(d)(1).
(at least 101 violations)

143. NYC Code § 20-268.1(d) provides that “In connection with the sale or offer for sale

of a second-hand automobile, a second-hand automobile dealer or employees or agents thereof

shall not: (1) Prepare, participate, assist or direct any person to prepare, participate or assist in the

submission of a false, misleading, or deceptive credit application or contract to a lender or finance

company. . ..”

144. Respondents committed 16 violations of NYC Code § 20-268.1(d) by

misrepresenting automobiles’ cash prices and the prices of add-on products on RICs. Specifically,

Respondents did not itemize these add-on products on their RICs but added them to the cash price

Financing disclosure forms for the sales to Ms. Marquez-Fuentes and Ms. Cruz that were given to
23

DCWP—but not the consumers—contained false information.

35
of the automobiles, thus misrepresenting both the cash price of the automobile and the price—or

even existence—of add-on products. See Exhibit G.

145. Respondents committed one violation of NYC Code § 20-268.1(d) by charging

Antonio Flores $84 for credit card fees for his down payment without itemizing them on the RIC.

146. Respondents committed 84 violations of NYC Code § 20-268.1(d) by

misrepresenting the identity of the selling dealer on 77 RICs. See Exhibits H, I, J.

COUNT EIGHT
Failing to provide consumers with documents written in the language
used to negotiate the sale, in violation of NYC Code § 20-268.3.
(at least 17 violations)

147. NYC Code 20-268.3 provides, “In advance of execution of any contract between a

second-hand automobile dealer and a customer for the sale of a second-hand automobile,

including, but not limited to, a buyer's order, retail installment contract, bill of sale, automobile

contract cancellation option document, or service contract, a second-hand automobile dealer shall

provide to such consumer a copy of such contract, all documents incorporated or referenced in

such contract, and all documents to be signed or initialed by such consumer in connection with

such contract, in the language used by such dealer to negotiate the sale of such second-hand

automobile.”

148. Respondents committed 15 violations of NYC Code § 20-268.1(d) by negotiating

the sale of a 2015 Jeep Cherokee to Ms. Marquez-Fuentes in Spanish without providing the

following documents in Spanish that Respondents required Ms. Marquez-Fuentes to sign or initial

or were incorporated into the sales contract: RIC, bill of sale, buyer’s order, contingency clause,

arbitration agreement, lender verification, contract cancellation option form, financing disclosure

form, credit application, recall disclosure, gap liability notice, vehicle service contract application,

consumer bill of rights, power of attorney, and down payment receipt.

36
 149. Respondents committed two violations of NYC Code § 20-268.1(d) by negotiating

the sale of a 2018 Mazda CX-9 to Mr. Betancourt Peralta in Spanish without providing the

following documents in Spanish that Respondents required Mr. Betancourt Peralta to sign or initial

or were incorporated into the sales contract: RIC and vehicle service agreement.

COUNT NINE
Failing to maintain copies of documents relating to the sale of second-hand
automobiles, in violation of NYC Code § 20-268.5(a).
(at least six violations)

150. NYC Code § 20-268.5(a) requires second-hand automobile dealers to “maintain a

physical or electronic copy of each of the following documents relating to the sale of a second-

hand automobile for six years after the date of execution by the consumer of such documents: (1)

The buyer’s order, bill of sale, any retail installment contract, and any document incorporated by

reference into the bill of sale or retail installment contract; (2) Every document signed or initialed

by the consumer in connection with the sale transaction; (3) Every written disclosure provided to,

and signed or initialed by, the consumer pursuant to this subchapter; (4) Each signed automobile

contract cancellation option document, whether accepted or declined by the consumer; and (5)

Each signed document cancelling a sales contract or declining to cancel a sales contract pursuant

to an automobile contract cancellation option.”

151. Respondents committed one violation of NYC Code § 20-268.5(a) by failing to

maintain a copy of the financing disclosure form for the sale of a 2015 Jeep Grand Cherokee to

Wilber Tobar.

152. Respondents committed five violations of NYC Code § 20-268.5(a) by failing to

maintain copies of RICs executed between Respondents and the following consumers: Robert

Spagnoli (2016 Jeep Grand Cherokee), Cesar Miguel Banegas Peralta (2012 Honda Odyssey),

Jessica Garay (2017 Honda Accord), Tenzin Lodoe (2017 Hyundai Sonata), Harry Taylor (2017

37
Mercedes-Benz C-Class).

COUNT TEN
Conducting licensed business activity under an unauthorized trade name,
in violation of NYC Code § 20-113.
(at least six violations)

153. NYC Code § 20-113 provides that, “A license issued under chapter two shall be

valid only for activities conducted under the name of the person or organization to whom such

license was issued or under the trade name stated in the application therefor; if a licensed activity

is to be conducted under a trade name, the application must state that trade name. No license shall

be issued for more than one trade name, and no licensed activity may be carried out under more

than one such name…. Licensees shall notify the commissioner or the commissioner's designee of

any change of trade name at least ten days before such change becomes effective, and no such

change may take place without the prior written approval of the commissioner or the

commissioner's designee.”

154. Respondents committed six violations of NYC Code § 20-113 by conducting

SHAD business under a name other than the name or trade name of the entity licensed to do

business at the location of the sale. Specifically:

a. World Auto executed RICs under the names Automania, NYC Motorcars of

Woodside, and Luxury Automotive Club. See Exhibit H.

b. Automania executed RICs under the names World Auto and Luxury

Automotive Club. See Exhibit I.

c. LAC executed RICs under the name World Auto. See Exhibit J.

38
 COUNT ELEVEN
Dealing in second-hand automobiles without a license,
in violation of NYC Code § 20-265(a)
(at least 734 days)

155. NYC Code § 20-265(a) prohibits dealing in second-hand articles without a DCWP

license therefor.

156. There is a rebuttable presumption, unless otherwise specified, “that the unlicensed

activity continued every day, without interruption, from the date specified by the Department in

the notice as the first date of unlicensed activity through the hearing date.” 6 RCNY § 1-19(a).

“The first date of unlicensed activity specified by the Department in the notice may be the date of

an inspection at which unlicensed activity is identified or any other date on which unlicensed

activity first occurred, such as the date the business or individual entered into a contract to conduct

business for which a license was required or the first date a business or individual advertised or

offered services for which a license was required.” 6 RCNY § 1-19(b).

157. NYC Motorcars of Freeport dealt in second-hand automobiles without a license at

4309 Northern Boulevard in Queens from November 17, 2018 until November 19, 2020.

RELIEF SOUGHT

WHEREFORE, the Department respectfully requests that OATH issue a Report and

Recommendation pursuant to NYC Charter § 2203(h)(1) recommending the following:

1. revocation of Automania’s license to do business as a SHAD at 5511 Northern

Boulevard, pursuant to NYC Code §§ 20-104(e)(1), 20-275(a) and (d);

2. revocation of JF2 at 6020’s license to do business as a SHAD at 6020 Northern

Boulevard, pursuant to NYC Code §§ 20-104(e)(1), 20-275(a) and (d);

3. revocation of LAC’s license to do business as a SHAD at 6107 Northern Boulevard,

pursuant to NYC Code §§ 20-104(e)(1), 20-275(a) and (d);

39
 4. that Respondents pay the civil penalties set forth in Exhibit K;

5. that Respondents pay the restitution to consumers set forth in Exhibit L, and to any

other consumers identified by DCWP before the completion of the trial;

6. that all Respondents be held jointly and severally liable for all civil penalties and

restitution; and

7. such other and further relief as is deemed just and proper.

Dated: November 1, 2021

New York, New York

For: Peter A. Hatch Commissioner

New York City Dept. of Consumer and
Worker Protection

By:
Bradley McCormick, Esq.
Senior Staff Counsel
42 Broadway, 9th Floor
New York, NY 10004
bmccormick@dcwp.nyc.gov
(212) 436-0325 office
(347) 446-7943 mobile

To: J.F. Motors, LLC d/b/a World Auto

4301-4309 Northern Blvd.
Long Island City, NY 11101
jfmotors@hotmail.com

J.F. Motors, LLC d/b/a World Auto

c/o Faisal Khan
105 Cross Road
North Bellmore, NY 11710

J.F. Motors 2, Inc.

d/b/a Luxury Automotive Club
60-20 Northern Blvd.
Woodside, NY 11377

40
J.F. Motors 2, Inc. d/b/a Automania
5511 Northern Boulevard
Woodside, NY 11377
nyautomania@gmail.com

Best Luxury Motors 2, LLC

d/b/a Luxury Automotive Club
6107 Northern Blvd.
Flushing, NY 11377
luxuryofwoodside@gmail.com

NYC Motorcars of Freeport Corp.

c/o Murray Honig, Esq
88 Middle Neck Rd
Great Neck, NY 11021

NYC Motorcars of Freeport Corp.

415 W Sunrise Hwy
Freeport, NY 11520

Faisal Khan
105 Cross Road
North Bellmore, NY 11710

Richard Simon, Esq.

Attorney for Respondents J.F. Motors, LLC, J.F. Motors 2, Inc.,
Best Luxury Motors 2, LLC
rsimonesq@yahoo.com

41
Exhibit A
 STOCK#:______________VIN:__ __ __ __ __ __ __ __ __ __ __ __ __ __ __ __ __ ODOMETER:_______________YEAR:_______ MAKE:___________ MODEL:_____________ COLOR: ___________
NIADA DEALER NAME:__________________________________________________________________________________________ DATE: ________________________________________________
CPO CERTIFIED VEHICLE INSPECTED BY:__________________________________________________________________________________________ SIGNATURE:____________________________________________
125 POINT INSPECTION CHECKLIST
This certifies that the above vehicle has been inspected, and any necessary repairs that have been made to qualify this vehicle for the NIADA Certified Limited Warranty, are the SOLE responsibility of the Selling Dealer for the term of the
NIADA Certified Limited Warranty. Any person knowingly and willfully falsifying or concealing information in regards to this inspection would be committing a crime, and will be prosecuted to the full extent of the law.
QUALIFICATION STANDARDS MECHANICAL STANDARDS : PRE-ROAD TEST TIRE STANDARDS EXTERIOR CONDITION
Passed Repaired Operational & Functional Checks (cont.) : Passed Repaired Passed Repaired Passed Repaired
1. Vehicle history report pulled & provided by: 35.Trunk/Liftgate release & latches 78. FRONT: Both matching brand & size 109.No evidence of flood, fire or major hail damage
_______________________________ 36.Seat adjusters 79. REAR: Both matching brand & size 110. Grill trim, & roof rack are in place & secure
2. Odometer is actual miles 37.Steering column adjuster 80. Tread depth must be of 5/32” or greater 111. Bumpers are in place & secure
3. Not a buyback vehicle from factory 38.Ignition switch 81. Wheels & tires must be within factory 112. Body panel damage? If so, please list: ________
4. No branded or salvaged title 39. Malfunction indicators & warning lamps recommended sizes ________________________________________
5. No known frame damage per vehicle history report 40. Air bag system 82. Tires are free of bubbles & major cracks ________________________________________
6. No visible damage that would substantially impact 41. Trip computer 83. Wheels are free of major cracks & damage ________________________________________
the safety of the vehicle 42. Overhead console 84. Tires are properly inflated 113. Glass is free of cracks & major chips
7. No visible performance modifications 43. Heated seats 114. Headlights are free of damage & moisture
8. No visible suspension modifications 44. Cool seats BRAKE STANDARDS 115. Headlights are all working
9. No visible exhaust modifications 45. Heating system Passed Repaired 116. Brake lights are free of damage & moisture
10. List stored codes: ________________________ 46. Air conditioning 85. Parking brake & cables are free of seizing & are 117. Brake lights are all working
47. Turn Signals operational 118. All turn signal lights are working
86. Brake rotors & drums are free of rust, scoring,
48. Hazard lamps 119.Any other obvious signs of damage? If so, please
pitting or deep gouges
MAINTENANCE REQUIREMENTS 49. Horn list: _____________________________________
Passed Repaired 50. Brake lamps ________________________________________
11. Current manufacturer required maintenance 51. Headlamps SUSPENSION STANDARDS ________________________________________
performed Passed Repaired
52. High beam 87. Shock absorbers/struts
12. Vehicle has no open safety-related recalls
53. Low beam 88.Coil springs/leaf springs
13. Emission system is functioning & meets state INTERIOR CONDITION
54. Interior lamps 89. Sway bars
required standards
55. All power windows Passed Repaired
90. Control arms
56. Parking brake 120.Headliner intact
MECHANICAL STANDARDS : PRE-ROAD TEST 91. Ball joints
all items are operational & properly functioning 57. Fog lamps 121. No major rips or tears in seating
Underhood Checks: Passed Repaired 58. Windshield wiper system 122. All handles & knobs are intact & present
ROAD TEST
14. Hood release is in working condition 59. Wiper blades in good condition 123. All required seatbelts are intact
Passed Repaired
15. Brake fluid is clean & full 60. Rear wiper in good condition 92. No abnormal wind noise 124. All seatbelts functioning
16. Brake system is free of leaks 61. Rearview mirror 93.Engine is operating properly & no obvious signs 125.List any missing equipment please: __________
17. Power steering fluid is full 62. Sideview mirrors of problems ________________________________________
18. Power steering fluid is free of contamination 63. Rear defroster 94.Engine oil pressure are within normal range ________________________________________
and discoloration 64. Seat belts levels ________________________________________
19. Wiper/Washer fluid is full 65. Tilt steering wheel 95.Temperatures are within normal range levels
20. Charging system working correctly 66. Sunroof 96.Clutch is operating properly (manual
21. Intake & exhaust manifolds are free of cracks 67. Convertible top
transmission) ______________________________________
CUSTOMER SIGNATURE
& leaks 97.Transmission is shifting properly & quietly
68. All manual switches
22. Transmission fluid is at prescribed level 98.Vehicle is free of vibrations &/or unusual noises BY SIGNING THIS FORM I CERTIFY THAT I HAVE RECEIVED:
69. All factory installed options working properly of any kind
23. Transmission fluid is clean & free of contamination
99.Air conditioning & heating working properly on • A COPY OF MY VEHICLE HISTORY REPORT.
24. Head gasket is free of leaks Under vehicle:
all settings
25. Radiator coolant is at the prescribed level 70. Transmission is free of cracks & leaks
100. Gear selector operating • A COPY OF MY 125 POINT INSPECTION CHECKLIST AND
26. Radiator is free of leaks 71. Transmission seal is free of cracks & leaks UNDERSTAND WHAT MY LIMITED WARRANTY IMPLIES.
101. Steering wheel aligned
27. Radiator coolant tested to_________________ 72. Transfer case (when applicable) is free of cracks
102. Anti-lock brake system working properly
(in degrees +/-) & leaks
28. Belts are free of cracks, buldges & frays 73. Rear axle case is free of cracks & leaks
103. Overall stopping performance is good ______________________________________
104. Vehicle alignment within specifications Signature
29. Hoses are free of cracks & leaks 74. Front axle (when applicable) is free of cracks
30. Vacuum lines are free of cracks & leaks & leaks Equipment operation:
75. All structural components are free of ______________________________________
Operational & Functional Checks: 105.Cruise control
impact damage Date
31. Operational key
32. Key fob with remote keyless entry working
76. Exhaust system free from damage & leaks
106.Overdrive
107.Instrument panel/guages
ASK HOW YOU CAN
33. All doors open & close properly
77.Catalytic converter in place
108.Sound and/or entertainment system UPGRADE AND EXTEND
34. Door locks (all switches) YOUR CERTIFIED WARRANTY.
NID-XX 57NIDCPO0516
Exhibit B
 Exhibit B: Automobiles Sold for More Than Their Advertised Prices on
worldautocars.com
Purchase Advertised
Buyer Automobile VIN Sale Date Price Price Difference
J. Gonzalez-Zambrano 2016 Ford Fusion 3FA6P0HD8GR321930 3/16/2019 $16,771 $9,495 $7,276
L. Ofori 2015 Infiniti QX60 5N1AL0MM4FC555867 3/20/2019 $26,894 $18,880 $8,014
S. Douglas 2016 Nissan Rogue 5N1AT2MV4GC834550 3/27/2019 $19,285 $14,290 $4,995
D. Duffus 2018 Toyota Camry JTNB11HK3J3021244 3/30/2019 $21,841 $14,785 $7,056
A. Gutierrez 2016 Toyota Highlander 5TDJKRFH7GS317801 4/1/2019 $32,186 $24,845 $7,341
B. Dionn Dinnall 2017 Nissan Altima 1N4AL3AP9HC291445 4/20/2019 $16,495 $11,480 $5,015
W. Tobar 2015 Jeep Grand Cherokee 1C4RJFBG5FC862655 4/24/2019 $28,676 $19,790 $8,886
K. Ganni 2015 Chrysler 200 1C3CCCAB0FN677006 4/30/2019 $11,639 $7,995 $3,644
V. Mojica 2016 Nissan Pathfinder 5N1AR2MM6GC643394 5/2/2019 $20,936 $14,895 $6,041
W. Espinal 2016 Ford Fusion 3FA6P0H7XGR336911 5/8/2019 $15,344 $10,379 $4,965
T. Gibbs 2015 Infiniti Q50 JN1BV7AR5FM419546 5/8/2019 $22,627 $16,479 $6,148
W. Pinero 2017 Nissan Sentra 3N1AB7AP9HY248111 5/14/2019 $12,000 $7,990 $4,010
B. Kawal-Roberts 2016 Nissan Rogue 5N1AT2MV4GC785205 5/15/2019 $21,036 $19,995 $1,041
J. Borges 2017 Nissan Rogue 5N1AT2MV6HC771341 5/18/2019 $19,719 $13,695 $6,024
A. Gadea 2016 Acura ILX 19UDE2F35GA022436 5/21/2019 $19,492 $12,879 $6,613
K. Perez 2016 Honda Civic 2HGFC2F50GH530363 5/23/2019 $16,142 $10,088 $6,054
M. Myers 2018 Dodge Charger 2C3CDXCT6JH122492 5/24/2019 $26,785 $17,490 $9,295
M. Ruiz 2016 Kia Optima 5XXGU4L38GG053957 6/1/2019 $18,874 $12,499 $6,375
S. Nanda 2016 Ford Fusion 3FA6P0H79GR321963 6/4/2019 $16,478 $10,259 $6,219
J. Duran 2016 Honda Accord 1HGCR2F58GA139154 6/11/2019 $19,955 $13,359 $6,596
M. Paulino 2016 Acura TLX 19UUB2F5XGA007439 6/20/2019 $21,383 $15,995 $5,388
S. Scott-Mohammed 2016 Honda Accord 1HGCT1B84GA000926 6/20/2019 $19,965 $13,595 $6,370
E. Rustemi 2016 Hyundai Sonata 5NPE24AF9GH334275 6/22/2019 $14,448 $9,399 $5,049
N. Jean Pierre 2016 Nissan Altima 1N4AL3AP3GC221521 6/24/2019 $15,335 $9,880 $5,455
J. Jordan 2016 Volkswagen Jetta 3VWL17AJ6GM299542 6/26/2019 $16,915 $9,480 $7,435
X. Jadan 2017 Ford Fusion 3FA6P0H95HR203203 6/27/2019 $17,450 $13,490 $3,960
E. Clarke 2017 Toyota Camry 4T1BF1FK7HU701267 6/29/2019 $19,385 $11,779 $7,606
N. Hylton 2015 Infiniti Q50 JN1BV7AR8FM423932 7/5/2019 $21,179 $15,695 $5,484
M. Plascencia 2015 Infiniti Q50 JN1BV7AR1FM409712 7/6/2019 $24,820 $16,490 $8,330
O. Wallace 2018 Nissan Altima 1N4AL3AP5JC209961 7/11/2019 $17,786 $10,790 $6,996
E. Kyte 2016 Nissan Rogue 5N1AT2MV8GC829853 7/31/2019 $16,800 $12,795 $4,005
D. Torres 2016 Honda Civic 19XFC2F55GE224642 8/1/2019 $16,500 $9,899 $6,601
V. Williams 2016 Infiniti Q50 JN1EV7AR7GM345335 8/2/2019 $27,269 $19,490 $7,779
J. Valderrama-Correa 2016 Nissan Rogue 5N1AT2MV6GC899951 8/3/2019 $19,470 $13,485 $5,985
A. Udo 2016 Jeep Cherokee 1C4PJMDB3GW271012 8/3/2019 $22,771 $14,990 $7,781
R. London 2018 Honda Civic 2HGFC2F55JH526994 8/9/2019 $19,845 $12,849 $6,996
A. Beasley 2015 Infiniti Q50 JN1BV7AR8FM419220 8/13/2019 $23,729 $15,895 $7,834
W. Chery 2016 Honda Civic 2HGFC2F5XGH530841 8/26/2019 $16,173 $10,470 $5,703
A. Quiroz 2016 Honda Civic 19XFC2F7XGE228686 8/31/2019 $17,000 $11,490 $5,510
V. Soo 2016 Toyota RAV4 2T3BFREV0GW433968 9/2/2019 $21,386 $13,875 $7,511
S. Khan 2015 Infiniti Q50 JN1BV7AR2FM392466 9/6/2019 $27,728 $19,849 $7,879
T. Rodriguez 2016 Honda HR-V 3CZRU6H73GM747464 9/11/2019 $19,680 $15,985 $3,695
A. Genao 2016 Honda CR-V 2HKRM4H31GH620144 9/17/2019 $19,992 $13,475 $6,517
O. Ramos 2016 Honda Accord 1HGCR2F3XGA242509 9/30/2019 $18,089 $11,980 $6,109
G. Gonzalez Jr. 2017 Acura ILX 19UDE2F71HA003130 10/1/2019 $20,389 $14,990 $5,399
S. Islam 2016 BMW 5 Series WBA5A7C50GG150840 10/1/2019 $28,425 $19,595 $8,830
N. Rojas 2016 Toyota Corolla 2T1BURHE8GC715108 10/5/2019 $17,209 $11,895 $5,314
M. Taylor 2018 Dodge Grand Caravan 2C4RDGEG1JR254608 10/5/2019 $21,856 $15,490 $6,366
M. Alam 2016 Nissan Rogue 5N1AT2MV4GC838033 10/5/2019 $18,913 $12,495 $6,418
D. Puda 2016 Toyota Highlander 5TDJKRFH0GS296774 10/7/2019 $31,682 $23,795 $7,887
S. Lonecke Jr. 2016 Ford Fusion 3FA6P0HD9GR401950 10/18/2019 $17,608 $10,880 $6,728
M. Montes-Campo 2016 Kia Optima 5XXGV4L22GG061959 10/19/2019 $20,700 $16,990 $3,710
J. Haughton 2019 Hyundai Sonata 5NPE34AF2KH746396 10/19/2019 $22,435 $13,999 $8,436
M. Galdamez 2016 Lexus IS JTHCM1D20G5007478 10/21/2019 $26,070 $19,880 $6,190
N. Chaufournier 2016 Toyota RAV4 JTMRFREV6GJ098857 11/2/2019 $22,281 $14,700 $7,581

1 of 3
 Exhibit B: Automobiles Sold for More Than Their Advertised Prices on
worldautocars.com
Purchase Advertised
Buyer Automobile VIN Sale Date Price Price Difference
R. Davenport 2018 Hyundai Elantra 5NPD84LF6JH335933 11/11/2019 $16,571 $8,990 $7,581
K. Agyeman 2016 BMW 5 Series WBA5A7C54GG643128 11/12/2019 $25,670 $16,889 $8,781
K. Haracz 2018 Dodge Grand Caravan 2C4RDGEG8JR143294 11/25/2019 $20,731 $12,849 $7,882
H. Kaul 2016 Audi A3 WAUE8GFF3G1035653 11/29/2019 $23,841 $15,980 $7,861
R. Fernandez 2016 Toyota RAV4 2T3BFREV5GW526338 12/3/2019 $20,255 $13,489 $6,766
B. Dimaio 2016 Infiniti Q50 JN1FV7ARXGM450231 12/5/2019 $32,472 $24,490 $7,982
L. Contreras 2017 Honda Accord 1HGCR2F36HA121168 12/11/2019 $17,000 $11,990 $5,010
R. Haywood 2016 Acura ILX 19UDE2F80GA012070 1/4/2020 $18,982 $11,895 $7,087
S. Ally 2016 Infiniti Q50 JN1EV7AR8GM345635 1/11/2020 $28,336 $19,979 $8,357
P. Torres 2017 Nissan Altima 1N4AL3AP8HC244505 1/30/2020 $14,800 $8,980 $5,820
C. Abreu-Reyes 2017 Subaru WRX JF1VA1J6XH9829263 2/7/2020 $21,900 $19,800 $2,100
A. Sierra 2016 Nissan Murano 5N1AZ2MH3GN171937 2/17/2020 $25,233 $16,595 $8,638
C. Ferrarie 2017 Hyundai Sonata 5NPE34AF0HH499310 2/20/2020 $19,711 $11,980 $7,731
J. Boyle 2018 Mazda Mazda3 5 Door 3MZBN1L37JM209768 2/25/2020 $16,180 $10,995 $5,185
P. Salas 2017 Chevrolet Traverse 1GNKVGKD8HJ112643 3/10/2020 $20,577 $12,990 $7,587
M. Ramaj 2017 Infiniti Q60 JN1EV7EL1HM550317 3/19/2020 $27,995 $17,995 $10,000
F. Aidoo 2017 Toyota RAV4 2T3RFREV9HW642660 5/12/2020 $20,880 $14,899 $5,981
F. Mazuera 2016 Nissan Pathfinder 5N1AR2MM0GC607961 5/21/2020 $19,500 $13,745 $5,755
T. Wright 2018 Nissan Altima 1N4AL3AP1JC267565 5/23/2020 $21,294 $11,499 $9,795
A. Cruz 2017 Ford Fusion 3FA6P0HD5HR153391 5/25/2020 $17,877 $10,400 $7,477
J. Destin 2017 Honda Civic 19XFC2F52HE224129 5/27/2020 $16,829 $12,949 $3,880
D. Quick 2017 Ford Fusion 3FA6P0K97HR161819 5/27/2020 $20,722 $11,998 $8,724
A. Husak 2017 Hyundai Sonata 5NPE34AF5HH455948 5/30/2020 $19,372 $11,890 $7,482
K. Montano Gonzalez 2017 Audi A6 WAUG8AFC0HN015480 6/3/2020 $26,279 $19,399 $6,880
S. Wong 2017 Kia Sorento 5XYPKDA59HG337962 6/5/2020 $24,934 $19,455 $5,479
W. Chandler 2018 Dodge Grand Caravan 2C4RDGEG1JR345474 6/13/2020 $20,771 $12,995 $7,776
K. Lalama-Mendes 2016 Infiniti Q50 JN1EV7AR6GM343849 6/15/2020 $27,469 $19,999 $7,470
L. Logan 2016 BMW 5 Series WBA5A7C50GG146352 6/17/2020 $25,521 $16,989 $8,532
J. Mercado 2017 Honda Civic 2HGFC3A52HH755270 6/20/2020 $21,450 $16,999 $4,451
E. Lazaro 2017 Toyota Highlander 5TDJZRFH9HS359609 6/20/2020 $27,984 $22,499 $5,485
R. Rivera 2017 Toyota Sienna 5TDKZ3DC0HS814565 6/20/2020 $25,282 $18,500 $6,782
F. Heredia 2017 Honda HR-V 3CZRU6H58HM722270 6/22/2020 $19,549 $14,499 $5,050
M. Galdass 2018 Nissan Altima 1N4AL3AP1JC245582 6/22/2020 $16,995 $11,299 $5,696
M. Hasan 2017 Honda CR-V 5J6RW2HSXHL024974 6/23/2020 $23,055 $18,695 $4,360
L. Vega 2016 Mazda 3 3MZBM1W71GM247412 6/24/2020 $12,900 $10,490 $2,410
J. Cardenes 2016 Jeep Grand Cherokee 1C4RJFBG4GC325650 6/26/2020 $26,992 $19,985 $7,007
J. Mendez 2017 Infiniti Q50 JN1EV7ARXHM831090 6/26/2020 $24,296 $16,959 $7,337
M. Carmel Alexis 2016 Nissan Rogue KNMAT2MV6GP734219 6/26/2020 $20,695 $11,989 $8,706
D. Betancourt Peralta 2018 Mazda CX-9 JM3TCBCY4J0208943 6/27/2020 $25,189 $18,990 $6,199
M. Rahman 20176 Ford Fusion 3FA6P0T91HR188738 6/29/2020 $18,286 $10,999 $7,287
A. Azemi 2019 Dodge Grand Caravan 2C4RDGEGXKR745020 6/30/2020 $23,460 $16,999 $6,461
C. Valdez Rodriguez 2016 Honda Civic 2HGFC1F36GH659135 7/11/2020 $19,295 $12,999 $6,296
S. Brewster 2017 Infiniti QX60 5N1DL0MM1HC523989 7/15/2020 $24,800 $19,990 $4,810
A. Ramsamooj 2017 Honda Civic 2HGFC2F57HH556640 7/15/2020 $18,500 $10,889 $7,611
S. Rulda 2017 Nissan Altima 1N4AL3APXHN344206 7/16/2020 $17,484 $10,499 $6,985
D. Perez 2017 Jeep Cherokee 1C4PJMDB5HW656735 7/16/2020 $23,875 $16,599 $7,276
E. Sims 2017 Nissan Rogue KNMAT2MV7HP569122 7/17/2020 $19,900 $11,900 $8,000
Z. Daud 2018 Toyota RAV4 JTMBFREV3JJ721392 7/17/2020 $22,359 $14,289 $8,070
L. Pryatel-Tucker 2017 Nissan Rogue KNMAT2MVXHP560026 7/22/2020 $22,468 $11,880 $10,588
L. Carrillo 2017 Subaru WRX JF1VA2Y66H9820197 7/24/2020 $33,500 $18,895 $14,605
J. Parra 2016 Kia Sorento 5XYPKDA56GG172550 7/25/2020 $22,999 $14,990 $8,009
T. Ware 2017 Infiniti Q50 JN1EV7AR7HM830317 7/28/2020 $24,967 $17,590 $7,377
E. Perez 2017 Ford Fusion 3FA6P0H76HR345722 7/29/2020 $17,624 $10,299 $7,325
D. Paulino 2016 BMW 4 Series WBA3N9C51GK250109 8/1/2020 $27,692 $20,499 $7,193
Y. Almonte Alvarez 2017 Honda Civic 19XFC2F73HE206773 8/8/2020 $20,669 $13,599 $7,070

2 of 3
 Exhibit B: Automobiles Sold for More Than Their Advertised Prices on
worldautocars.com
Purchase Advertised
Buyer Automobile VIN Sale Date Price Price Difference
M. Thornhill 2018 Nissan Sentra 3N1AB7AP1JY265684 8/22/2020 $18,489 $10,789 $7,700
M. Stefanidis 2016 BMW X1 WBXHT3C32GP887686 8/28/2020 $23,474 $18,799 $4,675
A. Mendoza 2017 Kia Sorento 5XYPHDA58HG323419 9/7/2020 $28,794 $20,299 $8,495
F. Rojas 2018 Dodge Grand Caravan 2C4RDGEG7JR318876 9/8/2020 $22,995 $13,540 $9,455
T. Setteducato 2017 Kia Optima 5XXGT4L33HG177896 9/19/2020 $18,474 $11,999 $6,475
R. Glackin 2016 Acura TLX 19UUB2F58GA012770 9/19/2020 $24,684 $16,699 $7,985
C. Iribuka 2017 Mazda 6 JM1GL1V56H1115403 9/22/2020 $17,595 $14,399 $3,196
A. Al Fakih 2018 Toyota Corolla 5YFBURHE7JP800612 9/23/2020 $19,330 $13,799 $5,531
S. Adhikari 2017 Nissan Rogue JN8AT2MV6HW275480 9/24/2020 $23,750 $14,280 $9,470

3 of 3
Exhibit C
 Exhibit C: Automobiles Sold for More Than Their Advertised Prices on
automaniaonline.com and luxuryautomotiveclub.com

AUTOMANIAONLINE.COM FALSELY ADVERTISED PRICES

Purchase Advertised
Buyer Automobile VIN Sale Date Price Price Difference
J. Tancredi 2018 Kia Optima 5XXGT4L35JG274703 5/16/2020 $17,480 $9,999 $7,481
C. Colon 2016 Honda CR-V 2HKRM4H78GH723404 5/20/2020 $21,980 $14,599 $7,381
P. Jesse 2017 Hyunda Sante Fe Sport 5NMZUDLB4HH036074 5/21/2020 $23,150 $14,998 $8,152
E. Merisier 2016 Infiniti QX60 5N1AL0MM3GC504720 5/21/2020 $26,189 $20,395 $5,794
S. Wing 2017 Infiniti Q50 JN1EV7AR6HM830373 5/21/2020 $24,375 $17,490 $6,885
M. Palaguachi 2016 Nissan Sentra 3N1AB7APXGY263165 5/22/2020 $14,545 $7,998 $6,547
D. Quick 2017 Ford Fusion 3FA6P0K97HR161819 5/27/2020 $20,722 $11,998 $8,724
C. Ochoa 2016 Infiniti QX60 5N1AL0MM3GC532887 6/1/2020 $28,198 $18,599 $9,599
H. Alvares 2018 Toyota Corolla 2T1BURHE7JC118443 6/3/2020 $16,630 $11,499 $5,131
E. Capellan De Leon 2017 Toyota Camry 4T1BF1FK7HU282711 6/4/2020 $20,000 $10,999 $9,001
M. Chaudhary 2017 Toyota Camry 4T1BF1FK1HU292795 6/5/2020 $20,430 $11,870 $8,560
H. Riascos Palacio 2017 Nissan Sentra 3N1AB7APXHY205641 6/8/2020 $12,900 $9,599 $3,301
P. Pike 2016 Infiniti Q50 JN1EV7AR2GM343475 6/9/2020 $24,580 $15,599 $8,981
A. Jean-Gilles 2017 Chevrolet Traverse 1GNKVFED0HJ185091 6/12/2020 $19,000 $12,999 $6,001
N. Castro 2017 Toyota RAV4 JTMRFREV6HD207494 6/13/2020 $20,459 $14,839 $5,620
C. Soria 2017 Ford Explorer 1FM5K8F89HGA30706 6/13/2020 $31,817 $22,439 $9,378
J. Jackson 2017 Honda Civic 2HGFC2F59HH532632 6/23/2020 $19,509 $10,789 $8,720
A. Luna 2017 Hyundai Sonata 5NPE34AF1HH536526 6/27/2020 $19,451 $11,599 $7,852
L. Moore Evans 2017 Nissan Maxima 1N4AA6AP2HC409570 6/27/2020 $24,126 $16,490 $7,636
D. Daniel 2017 Hyunda Elantra 5NPD84LF2HH124948 6/30/2020 $17,095 $12,490 $4,605
T. Mckay 2019 Nissan Sentra 3N1AB7AP9KY208618 7/1/2020 $17,495 $12,689 $4,806
J. Peralta Quilambaqui 2018 Ford Explorer 1FMSKBD83JGB82733 7/1/2020 $29,992 $22,999 $6,993
A. Skiy Harbacewicz 2017 Toyota Corolla 2T1BURHE7HC866264 7/2/2020 $18,978 $11,459 $7,519
J. Romaine Roberts 2017 Acura TLX 19UUB2F59HA001424 7/3/2020 $21,899 $16,998 $4,901
F. Briones Campos 2016 Infiniti Q50 JN1EV7AR6GM346881 7/4/2020 $24,095 $16,859 $7,236
E. Davis 2017 Nissan Altima 1N4AL3APBHC223637 7/4/2020 $16,520 $11,439 $5,081
T. Phuntsok 2017 Toyota RAV4 JTMRFREV5HD209432 7/4/2020 $22,958 $14,999 $7,959
L. Korczakowski 2017 Kia Sorento 5XYPGDA58HG307515 7/6/2020 $21,000 $13,999 $7,001
A. Adeabola 2017 Nissan Maxima 1N4AA6AP6HC421835 7/7/2020 $22,969 $16,489 $6,480
L. Jones 2017 Infiniti QX60 5N1DL0MM4HC529897 7/11/2020 $29,600 $19,799 $9,801
T. Biswas 2016 Honda Accord 1HGCR2F31GA122534 7/13/2020 $18,995 $11,999 $6,996
M. Lema Caisahuano 2017 Jeep Grand Cherokee 1C4RJFBG0HC865045 7/13/2020 $29,179 $20,999 $8,180
M. Perez 2016 Chevrolet Traverse 1GNKVGKD7GJ231833 7/14/2020 $20,492 $14,999 $5,493
D. Pabon 2017 Nissan Altima 1N4AL3APBHC249042 7/15/2020 $17,335 $9,999 $7,336
R. Gniedziejko 2017 Nissan Pathfinder 5N1DR2MM3HC660054 7/20/2020 $22,495 $15,999 $6,496
C. Resnick 2017 Ford Focus 1FADP3H28HL208809 7/20/2020 $14,899 $9,999 $4,900
S. Shafin 2017 Toyota Camry 4T1BF1FK8HU754611 7/20/2020 $19,995 $13,690 $6,305
T. Cox 2017 Volkswagen Jetta 3VW4T7AJ6HM308000 7/21/2020 $19,730 $13,295 $6,435
J. Paulino Venturina 2016 Kia Optima 5XXGT4L34GG013913 7/21/2020 $17,595 $10,990 $6,605
R. Holt 2017 Nissan Maxima 1N4AA6AP2HC420083 7/22/2020 $25,599 $16,999 $8,600
K. Nugent 2017 Hyundai Elantra 5NPD84LF8HH091907 7/22/2020 $19,595 $11,999 $7,596
R. Rivera Turicos 2017 Acura TLX 19UUB1F55HA003214 7/22/2020 $25,195 $16,880 $8,315
M. Lewis 2016 Toyota RAV4 2T3DFREV4GW51 3590 7/31/2020 $24,714 $15,999 $8,715
A. Espinal 2016 MAZDA MAZDA6 JM1GJ1V59G1425212 8/6/2020 $18,544 $10,999 $7,545
S. Deonandan 2019 Toyota Camry 4T1B11HK9KU680053 8/8/2020 $20,989 $15,439 $5,550
J. Kriedter 2017 Nissan Rogue KNMAT2MV0HP572590 8/8/2020 $20,974 $11,739 $9,235
D. Ortiz Guevara 2017 GMC Acadia 1GKKNRLA5HZ243642 8/8/2020 $25,069 $16,999 $8,070
J. Gomez 2017 Honda CR-V 5J6RW2H86HL031320 8/10/2020 $27,800 $19,490 $8,310
L. Lopez 2017 Jeep Grand Cherokee 1C4RJ FBGXHC827631 8/10/2020 $31,745 $22,599 $9,146
L. Morales Mendez 2017 Kia Sorento 5XYPKDA53HG314452 8/11/2020 $26,895 $19,999 $6,896
J. Quichimbo Naula 2017 Chevrolet Traverse 1GNKVFED8HJ175456 8/12/2020 $23,923 $14,489 $9,434
B. Vargas 2017 Honda HR-V 3CZRU6H57HM729128 8/12/2020 $20,534 $15,490 $5,044
M. Cuevas 2014 Toyota Corolla 2T1BURHE7EC020552 8/14/2020 $10,500 $7,999 $2,501

1 of 2
 Exhibit C: Automobiles Sold for More Than Their Advertised Prices on
automaniaonline.com and luxuryautomotiveclub.com
Purchase Advertised
Buyer Automobile VIN Sale Date Price Price Difference
R. Thomas 2016 Kia Optima 5XXGT4L11GG008974 8/15/2020 $19,988 $10,999 $8,989
A. Hosaini 2018 Dodge Grand Caravan 2C4RDGEGBJR299528 8/18/2020 $20,190 $13,699 $6,491
K. Mejia Reyes 2015 MINI Paceman WMWSS7C56FWS45021 8/21/2020 $17,067 $9,999 $7,068
J. Pomare 2017 Honda Accord 1HGCR2F5XHA288201 8/21/2020 $21,866 $12,989 $8,877
O. Carrera 2017 Honda Civic 2HGFC2F52HH537400 8/22/2020 $21,095 $11,389 $9,706
N. Padilla 2017 Honda CR-V 2HKRW2H56HH661001 8/22/2020 $26,439 $18,999 $7,440
E. Delva 2017 Toyota Corolla 2T1BURHE6HC814804 8/24/2020 $17,349 $10,999 $6,350
K. Schwartz 2017 Hyundai Elantra 5NPD84LF2HH181649 8/29/2020 $15,895 $9,989 $5,906
R. Rozagatsjov 2017 Ford Explorer 1FM5K8D82HGD41087 9/5/2020 $31,934 $21,999 $9,935
R. Rozagatsjov 2017 Ford ExpIorer 1FM5KBD82HGD41087 9/5/2020 $31,934 $21,999 $9,935
V. Singh 2017 Ford Focus 1FADP3H23HL330607 9/5/2020 $17,847 $10,490 $7,357
C. Henry 2018 Acura TLX 19UUB1F56JA001199 9/8/2020 $25,995 $18,590 $7,405
C. Banegas Peralta 2012 Honda Odyssey 5FNRL5H95CB063082 9/9/2020 $17,795 $16,599 $1,196
V. Eubanks 2017 Toyota Corolla 2T1BURHE1HC810286 9/14/2020 $19,775 $11,899 $7,876
T. Beverly 2018 Dodge Grand Caravan 2C4RDGEG9JR343181 9/15/2020 $19,859 $14,999 $4,860
C. Givens 2017 Nissan Altima 1N4AL3AP2HN348430 9/15/2020 $18,090 $9,999 $8,091
M. Mattei 2017 Nissan Rogue 5N1AT2MV9HC873295 9/16/2020 $21,690 $14,289 $7,401
L. Hamson 2017 Nissan Maxima 1N4AA6AP4HC437838 9/17/2020 $27,064 $15,999 $11,065
J. Cruz 2017 Nissan Rogue 5N1AT2MV4HC840351 9/18/2020 $24,058 $14,489 $9,569
W. Benjamin 2017 Hyundai Elantra KMHD84LFBHU380030 9/19/2020 $15,395 $9,999 $5,396
J. Charles 2017 Honda Civic 19XFC1F45HE014822 9/20/2020 $22,389 $12,699 $9,690
T. Jayson Hubbard 2017 Nissan Rogue 5N1AT2MV0HC872181 9/24/2020 $21,088 $11,999 $9,089
F. Menendez Martinez 2017 Honda HR-V 3CZRU6H70HM729280 9/24/2020 $23,474 $14,799 $8,675
K. Cabral Galva 2017 Jeep Grand Cherokee 1C4RJFBGXHC864646 9/25/2020 $29,684 $23,999 $5,685
A. Dufresne 2017 Acura ILX 19UDE2F70HA007346 9/25/2020 $25,064 $13,899 $11,165
C. Roque Lopez 2017 Acura MDX 5J8YD4H50HL006360 9/25/2020 $33,802 $24,999 $8,803
S. Sacco 2017 Kia Sorento 5XYPKDA56HG338082 9/25/2020 $29,685 $21,899 $7,786
G. Roman 2017 Nissan Maxima 1N4AA6AP9HC419173 9/26/2020 $26,869 $17,399 $9,470
D. Hernandez 2017 Chevrolet Traverse 1GNKVFED3HJ297173 9/27/2020 $22,988 $15,999 $6,989
D. Francesco 2017 MAZDA MAZDA3 3MZBN1U79HM118206 9/29/2020 $19,834 $10,999 $8,835
T. Weeks 2017 Kia Sportage KNDPNCACXH7229704 3/8/2021 $23,878 $14,999 $8,879

LUXURYAUTOMOTIVECLUB.COM FALSELY ADVERTISED PRICES

Purchase Advertised
Buyer Automobile VIN Sale Date Price Price Difference
L. Altagracia 2016 Acura MDX 5FRYD4H47GB058333 1/6/2021 $26,993 $19,995 $6,998
O. Ba 2017 Mercedes-Benz C-Class WDDWF4KB5HR242973 3/4/2021 $25,050 $17,990 $7,060
P. Allala 2018 Mercedes GLC WDC0G4KB2JV048342 6/19/2021 $34,095 $24,871 $9,224
G. Rojas 2017 Honda Civic 2HGFC2F76HH558848 7/30/2021 $23,780 $15,795 $7,985
E. Atkinson 2018 Infiniti Q60 5N1DL0MM5JC517988 9/16/2021 $39,570 $27,481 $12,089

2 of 2
Exhibit D
 Exhibit D: Out-of-State Buyers Overcharged for Title and Registration Fees

Title and Registration Fees

Buyer Year/Make/Model VIN State Collected Actual difference
J. Aguirre 2016 Honda HR-V 3CZRU6H77GM757236 PA $425.00 $164.00 $261.00
K. Agyeman 2016 BMW 5 Series WBA5A7C54GG643128 NJ $375.00 $156.50 $218.50
P. Allala 2018 Mercedes GLC WDC0G4KB2JV048342 NJ $350.00 $156.50 $193.50
A. Beasley 2015 Infiniti Q50 JN1BV7AR8FM419220 MA $400.00 $135.00 $265.00
L. Bonilla 2017 Nissan Maxima 1N4AA6AP0HC376939 FL $375.00 $107.75 $267.25
J. Borges 2017 Nissan Rogue 5N1AT2MV6HC771341 RI $400.00 $142.50 $257.50
J. Cahill 2017 Nissan Sentra 3N1AB7AP0HY277979 NJ $350.00 $131.50 $218.50
W. Chery 2016 Honda Civic 2HGFC2F5XGH530841 PA $350.00 $164.00 $186.00
E. Clarke 2017 Toyota Camry 4T1BF1FK7HU701267 CT $375.00 $190.00 $185.00
M. Cuevas 2014 Toyota Corolla 2T1BURHE7EC020552 CT $400.00 $190.00 $210.00
B. Dionn Dinnall 2017 Nissan Altima 1N4AL3AP9HC291445 PA $350.00 $164.00 $186.00
V. Eubanks 2017 Kia Sorento 2T1BURHE1HC810286 NJ $350.00 $156.50 $193.50
R. Festa 2016 Mercedes C Class 55SWF4KB0GU157357 NJ $350.00 $156.50 $193.50
S. Fontaine 2015 Dodge Dart 1C3CDFBB7FD251994 CT $400.00 $190.00 $210.00
J. Gonzalez-Zambrano 2016 Ford Fusion 3FA6P0HD8GR321930 NJ $350.00 $156.50 $193.50
A. Marquez-Fuentes 2015 Jeep Cherokee 1C4PJMDS7FW758289 CT $412.00 $190.00 $222.00
O. Martinez 2017 Mercedes AMG WDDWJ6EB5HF449757 CT $350.00 $190.00 $160.00
K. McLaurin 2014 Infiniti Q50 JN1BV7AR5EM700244 VA $312.00 $12.00 $300.00
M. Myers 2018 Dodge Charger 2C3CDXCT6JH122492 PA $375.00 $164.00 $211.00
L. Ofori 2015 Infiniti QX60 5N1AL0MM4FC555867 CT $350.00 $190.00 $160.00
M. Plascencia 2015 Infiniti Q50 JN1BV7AR1FM409712 CT $375.00 $190.00 $185.00
O. Ramos 2016 Honda Accord 1HGCR2F3XGA242509 NJ $400.00 $156.50 $243.50
C. Reid 2016 Acura MDX 5FRYD4H43GB048575 MD $350.00 $307.00 $43.00
E. Reyes 2017 Toyota RAV4 2T3BFREV1HW601831 NJ $350.00 $156.50 $193.50
R. Rivera 2017 Toyota Sienna 5TDKZ3DC0HS814565 NJ $400.00 $156.50 $243.50
G. Rojas 2017 Honda Civic 2HGFC2F76HH558848 NJ $350.00 $131.50 $218.50
M. Ruiz 2016 Kia Optima 5XXGU4L38GG053957 NJ $262.00 $156.50 $105.50
V. Svyryda 2016 Honda Accord 1HGCR2F52GA164468 NJ $375.00 $156.50 $218.50
K. Terry 2012 Buick LaCrosse 1G4GD5E3XCF152397 NJ $325.00 $156.50 $168.50
A. Udo 2016 Jeep Cherokee 1C4PJMDB3GW271012 NJ $400.00 $156.50 $243.50
K. Verrill 2016 Honda Accord 1HGCR2F53GA113495 CT $375.00 $190.00 $185.00
O. Wallace 2018 Nissan Altima 1N4AL3AP5JC209961 NJ $400.00 $131.50 $268.50
T. Weeks 2017 Kia Sportage KNDPNCACXH7229704 NJ $350.00 $156.50 $193.50
Exhibit E
 Exhibit E: Cancellation Option Violations

Cancellation Option Forms Without Cancellation Date

Buyer Automobile VIN Sale Date
S. Adhikari 2017 Nissan Rogue JN8AT2MV6HW275480 9/24/2020
A. Al Fakih 2018 Toyota Corolla 5YFBURHE7JP800612 9/23/2020
L. Altagracia 2016 Acura MDX 5FRYD4H47GB058333 1/6/2021
J. Avelar 2016 Nissan Sentra 3N1AB7APXGL659335 3/27/2019
O. Ba 2017 Mercedes-Benz C-Class WDDWF4KB5HR242973 3/4/2021
J. Benitez 2016 Jeep Cherokee 1C4PJMDS0GW103960 4/24/2019
M. Bowry 2017 INFINITI Q50 JN1EV7AR2HM838616 9/9/2020
K. Cabral Galva 2017 Jeep Grand Cherokee 1C4RJFBGXHC864646 9/25/2020
S. Cruz 2017 Nissan Pathfinder 5N1DR2MM2HC626218 3/20/2020 *
S. Das 2015 Lexus RX 2T2BK1BAXFC305000 8/29/2020
D. Delacruz 2015 Acura TLX 19UUB2F56FA015939 11/5/2018
S. Douglas 2016 Nissan Rogue 5N1AT2MV4GC834550 3/27/2019
A. Dufresne 2017 Acura ILX 19UDE2F70HA007346 9/25/2020
E. Durango 2017 Mazda 3 3MZBN1V74HM120024 12/11/2020
V. Eubanks 2017 Toyota Corolla 2T1BURHE1HC810286 9/14/2020
I. Felix 2015 Toyota RAV4 JTMBFREV0FJ037200 11/10/2018
S. Fontaine 2015 Dodge Dart 1C3CDFBB7FD251994 9/3/2018
P. Garcia Siavichay 2017 Honda CR-V 2HKRW2H59HH644063 9/6/2020
R. Hoomanawanui 2017 Nissan Rogue KNMAT2MV6HP606550 8/25/2020
C. Iribuka 2017 Mazda 6 JM1GL1V56H1115403 9/22/2020
T. Jayson Hubbard 2017 Nissan Rogue 5N1AT2MV0HC872181 9/24/2020
A. Kaplan 2017 Acura MDX 5FRYD4H74HB018870 9/8/2020
L. Lefkowitz 2018 Hyundai Sonata 5NPE34AF9JH594700 8/26/2020
Q. Lin 2010 Lexus RX350 JTJZK1BA4A2407500 11/17/2018
T. Lodoe 2017 Hyundai Sonata 5NPE34AF6HH548915 9/6/2020
A. Marquez -Fuentes 2015 Jeep Cherokee 1C4PJMDS7FW758289 12/11/2018
J. Marsh 2015 Nissan Pathfinder 5N1AR2MM8FC705540 12/8/2018
O. Martinez 2017 Mercedes-Benz Mercedes-AM WDDWJ6EB5HF449757 8/31/2020
A. Mendoza 2017 Kia Sorento 5XYPHDA58HG323419 9/7/2020
F. Menendez Martinez2017 Honda HR-V 3CZRU6H70HM729280 9/24/2020
J. Moncada 2017 Nissan Rogue 5N1AT2MV6HC826404 9/7/2020
M. Myers 2018 Dodge Charger 2C3CDXCT6JH122492 5/24/2019
R. Perez 2018 Honda Accord 1HGCV1F16JA031240 3/4/2021
K. Perez 2016 Honda Civic 2HGFC2F50GH530363 5/23/2019
C. Reid 2016 Acura MDX 5FRYD4H43GB048575 2/23/2019
R. Rotundo 2016 Audi A6 WAUFGAFC9GN004538 5/15/2019
K. Schwartz 2017 Hyundai Elantra 5NPD84LF2HH181649 8/29/2020
M. Stefanidis 2016 BMW X1 WBXHT3C32GP887686 8/28/2020
H. Taylor 2017 Mercedes-Benz C-Class 55SWF4K88HU208685 9/2/2020
W. Tobar 2015 Jeep Grand Cherokee 1C4RJFBG5FC862655 4/24/2019
K. Verrill 2016 Honda Accord 1HGCR2F53GA113495 5/15/2019
N. Vil 2017 Nissan Rogue JN8AT2MV9HW250153 9/7/2020
V. Wong 2017 Nissan Rogue KNMAT2MV0HP593083 9/5/2020

Page 1 of 2
 Exhibit E: Cancellation Option Violations

Consumers Not Given Cancellation Option

Buyer Automobile VIN Sale Date

P. Allala 2018 Mercedes GLC WDC0G4KB2JV048342 6/19/2021
E. Atkinson 2018 Infiniti Q60 5N1DL0MM5JC517988 9/16/2021
D. Betancourt Peralta 2018 Mazda CX-9 JM3TCBCY4J0208943 6/27/2020
S. Cruz 2017 Nissan Pathfinder 5N1DR2MM2HC626218 3/20/2020 *
A. Flores 2017 Volkswagen Passat 1VWBT7A32HC036393 5/26/2021
E. Gomez 2014 Infiniti Q50 JN1BV7AR1EM687363 2/17/2021
G. Rojas 2017 Honda Civic 2HGFC2F76HH558848 7/30/2021
T. Weeks 2017 Kia Sportage KNDPNCACXH7229704 3/8/2021

*Cancellation Option form was both defective and not provided to consumer. Petitioner is charging as
one violation.

Page 2 of 2
Exhibit F
 Exhibit F: Conditional Contracts

Buyer Automobile VIN Sale Date

P. Allala 2018 Mercedes GLC WDC0G4KB2JV048342 6/19/2021
E. Atkinson 2018 Infiniti Q60 5N1DL0MM5JC517988 9/16/2021
J. Avelar 2016 Nissan Sentra 3N1AB7APXGL659335 3/27/2019
J. Benitez 2016 Jeep Cherokee 1C4PJMDS0GW103960 4/24/2019
D. Delacruz 2015 Acura TLX 19UUB2F56FA015939 11/5/2018
S. Douglas 2016 Nissan Rogue 5N1AT2MV4GC834550 3/27/2019
I. Felix 2015 Toyota RAV4 JTMBFREV0FJ037200 11/10/2018
A. Flores 2017 Volkswagen Passat 1VWBT7A32HC036393 5/26/2021
S. Fontaine 2015 Dodge Dart 1C3CDFBB7FD251994 9/3/2018
L. Francis 2015 Chevrolet Traverse 1GNKVFKD7FJ288655 3/3/2018
Q. Lin 2010 Lexus RX350 JTJZK1BA4A2407500 11/17/2018
C. Mahmoud 2015 Infiniti Q50 JN1BV7AR4FM391366 3/19/2018
A. Marquez -Fuentes 2015 Jeep Cherokee 1C4PJMDS7FW758289 12/11/2018
J. Marsh 2015 Nissan Pathfinder 5N1AR2MM8FC705540 12/8/2018
B. McCarthy 2017 Nissan Altima 1N4AL3AP9HC216048 11/24/2018
K. McLaurin 2014 Infiniti Q50 JN1BV7AR5EM700244 3/14/2018
M. Myers 2018 Dodge Charger 2C3CDXCT6JH122492 5/24/2019
K. Perez 2016 Honda Civic 2HGFC2F50GH530363 5/23/2019
C. Reid 2016 Acura MDX 5FRYD4H43GB048575 2/23/2018
R. Rotundo 2016 Audi A6 WAUFGAFC9GN004538 5/15/2019
M. Spagnoli 2016 Jeep Cherokee 1C4PJMDS9GW252349 4/24/2019
W. Tobar 2015 Jeep Grand Cherokee 1C4RJFBG5FC862655 4/24/2019
K. Verrill 2016 Honda Accord 1HGCR2F53GA113495 5/15/2019
Weeks 2017 Kia Sportage KNDPNCACXH7229704 3/8/2021
Exhibit G
 Exhibit G: Failure to Itemize Add-on Products

Buyer Automobile VIN Sale Date

P. Allala 2018 Mercedes GLC WDC0G4KB2JV048342 6/19/2021
E. Atkinson 2018 Infiniti Q60 5N1DL0MM5JC517988 9/16/2021
J. Avelar 2016 Nissan Sentra 3N1AB7APXGL659335 3/27/2019
J. Benitez 2016 Jeep Cherokee 1C4PJMDS0GW103960 4/24/2019
D. Delacruz 2015 Acura TLX 19UUB2F56FA015939 11/5/2018
S. Douglas 2016 Nissan Rogue 5N1AT2MV4GC834550 3/27/2019
I. Felix 2015 Toyota RAV4 JTMBFREV0FJ037200 11/10/2018
A. Flores 2017 Volkswagen Passat 1VWBT7A32HC036393 5/26/2021
S. Fontaine 2015 Dodge Dart 1C3CDFBB7FD251994 9/3/2018
Q. Lin 2010 Lexus RX350 JTJZK1BA4A2407500 11/17/2018
C. Mahmoud 2015 Infiniti Q50 JN1BV7AR4FM391366 3/19/2018
A. Marquez -Fuentes 2015 Jeep Cherokee 1C4PJMDS7FW758289 12/11/2018
J. Marsh 2015 Nissan Pathfinder 5N1AR2MM8FC705540 12/8/2018
M. Myers 2018 Dodge Charger 2C3CDXCT6JH122492 5/24/2019
W. Tobar 2015 Jeep Grand Cherokee 1C4RJFBG5FC862655 4/24/2019
K. Verrill 2016 Honda Accord 1HGCR2F53GA113495 5/15/2019
Exhibit H
 Exhibit H: Financed Sales by World Auto

Buyer Automobile VIN RIC dealer Sale Date

S. Dineros 2015 Toyota Camry 4T1BF1FKXFU953124 World Auto 6/18/2016
A. Kaba 2016 Toyota Camry 4T1BF1FK2GU514016 World Auto 1/13/2017
N. Rivera 2014 Honda CR-V 5J6RM4H76EL059137 World Auto 5/26/2017
A. Mahmud/Darwish 2014 Infiniti QX60 5N1AL0MM9EC535466 World Auto 6/15/2017
D. Lopez 2014 ACURA ILX 19VDE1F53EE009844 World Auto 6/30/2017
S. Perez 2014 Nissan Maxima 1N4AA5AP4EC49886 World Auto 8/28/2017
M. Robinson 2015 TOYOTA RAV4 2T3BFREV4FW273706 World Auto 11/14/2017
M. Henry 2014 Infiniti Q50 JN1BV7AR5EM704813 World Auto 12/16/2017
M. Francis 2015 Chevrolet Traverse 1GNKVFKD7FJ288655 World Auto 3/3/2018
K. Mclaurin 2014 Infiniti Q50 JN1BV7AR5EM700244 World Auto 3/14/2018
C. Mahmoud 2015 Infiniti Q50 JN1BV7AR4FM391366 World Auto 3/19/2018
S. Fontaine 2015 Dodge Dart 1C3CDFBB7FD251994 World Auto 9/3/2018
I. Felix 2015 Toyota RAV4 JTMBFREV0FJ037200 World Auto 11/10/2018
Q. Lin 2010 Lexus RX350 JTJZK1BA4A2407500 NYC Motorcars of Freeport 11/17/2018
J. Marsh 2015 Nissan Pathfinder 5N1AR2MM8FC705540 World Auto 12/8/2018
A. Marquez -Fuentes 2015 Jeep Cherokee 1C4PJMDS7FW758289 World Auto 12/11/2018
C. Reid 2016 Acura MDX 5FRYD4H43GB048575 World Auto 2/23/2019
J. Gonzalez-Zambrano 2016 Ford Fusion 3FA6P0HD8GR321930 World Auto 3/16/2019
J. Pilgrim 2016 Honda Civic 19XFC2F86GE214910 World Auto 3/18/2019
L. Ofori 2015 Infiniti QX60 5N1AL0MM4FC555867 World Auto 3/20/2019
S. Douglas 2016 Nissan Rogue 5N1AT2MV4GC834550 World Auto 3/27/2019
J. Avelar 2016 Nissan Sentra 3N1AB7APXGL659335 World Auto 3/27/2019
D. Duffus 2018 Toyota Camry JTNB11HK3J3021244 World Auto 3/30/2019
A. Gutierrez 2016 Toyota Highlander 5TDJKRFH7GS317801 World Auto 4/1/2019
A. Canon 2014 Nissan Pathfinder 5N1AR2MM2EC693044 World Auto 4/4/2019
S. Gussain 2018 Nissan Rogue 5N1AT2MVXGC774550 World Auto 4/10/2019
B. Dionn Dinnall 2017 Nissan Altima 1N4AL3AP9HC291445 World Auto 4/20/2019
W. Tobar 2015 Jeep Grand Cherokee 1C4RJFBG5FC862655 World Auto 4/24/2019
J. Benitez 2016 Jeep Cherokee 1C4PJMDS0GW103960 World Auto 4/25/2019
C. Gordon 2016 Lexus GX 460 JTJBM7FX9G5135305 NYC Motorcars of Freeport 5/1/2019
V. Mojica 2016 Nissan Pathfinder 5N1AR2MM6GC643394 World Auto 5/2/2019
M. Allen 2015 Infiniti Q50 JN1BV7AR6FM412976 World Auto 5/4/2019
T. Josiah 2015 Infiniti Q50 JN1BV7AR5FM415626 World Auto 5/7/2019
W. Espinal 2016 Ford Fusion 3FA6P0H7XGR336911 World Auto 5/8/2019
T. Gibbs 2015 Infiniti Q50 JN1BV7AR5FM419546 World Auto 5/8/2019
W. Pinero 2017 Nissan Sentra 3N1AB7AP9HY248111 World Auto 5/14/2019
R. Rotundo 2016 Audi A6 WAUFGAFC9GN004538 World Auto 5/15/2019
K. Verrill 2016 Honda Accord 1HGCR2F53GA113495 World Auto 5/15/2019
B. Mercado 2018 Chevrolet Impala 2G1105S34J9112423 World Auto 5/16/2019
T. Pass 2017 Nissan Altima 1N4AL3AP4HC130386 World Auto 5/17/2019
J. Borges 2017 Nissan Rogue 5N1AT2MV6HC771341 World Auto 5/18/2019
N. Trotman 2016 Mercedes-Benz GLE 4JGDA5HB9GA795115 NYC Motorcars of Freeport 5/21/2019
A. Gadea 2016 Acura ILX 19UDE2F35GA022436 World Auto 5/21/2019
C. Davis 2015 Jeep Grand Cherokee 1C4RJFBG1FC166052 World Auto 5/22/2019
F. Basir 2016 Honda Civic 2HGFC2F76GH535505 World Auto 5/22/2019
J. Locascio 2016 BMW X3 5UXWX7C54G0S16321 NYC Motorcars of Freeport 5/23/2019
K. Perez 2016 Honda Civic 2HGFC2F50GH530363 World Auto 5/23/2019
N. Drew-Oyewole 2016 Nissan Rogue 5N1AT2MV8GC833160 World Auto 5/23/2019
N. Analuisa Chimbo 2016 Land Rover Discovery Sport SALCT2BG9GH556483 World Auto 5/23/2019
M. Myers 2018 Dodge Charger 2C3CDXCT6JH122492 World Auto 5/24/2019
M. Vaneus 2015 Infiniti Q50 JN1BV7AR9FM406170 NYC Motorcars of Freeport 5/30/2019
W. James 2015 Nissan Altima 1N4AL3AP0FC599259 World Auto 5/30/2019
D. Fleurant 2015 Infiniti Q50 JN1BV7AR1FM416627 World Auto 5/30/2019

Page 1 of 3
 Exhibit H: Financed Sales by World Auto

Buyer Automobile VIN RIC dealer Sale Date

L. Blackwood 2015 Infiniti Q50 JN1BV7AR3FM417715 World Auto 5/30/2019
M. Ruiz 2016 Kia Optima 5XXGU4L38GG053957 NYC Motorcars of Woodside 6/1/2019
S. Nanda 2016 Ford Fusion 3FA6P0H79GR321963 NYC Motorcars of Woodside 6/4/2019
R. Alban-Lara 2016 Infiniti QX50 JN1BJ0RR5GM261573 World Auto 6/10/2019
J. Duran 2016 Honda Accord 1HGCR2F58GA139154 World Auto 6/11/2019
H. Cortes 2016 Nissan Altima 1N4AL3AP8GC255454 World Auto 6/11/2019
M. Gilbert 2016 Ford Fusion 3FA6P0HD1GR393679 World Auto 6/12/2019
W. Wiltshire 2016 Nissan Rogue KNMAT2MV2GP651337 World Auto 6/12/2019
T. Baird 2015 Acura ILX 19UDE2F76GA025512 World Auto 6/15/2019
S. Scott-Mohammed 2016 Honda Accord 1HGCT1B84GA000926 Automania 6/20/2019
P. Henry 2015 Infiniti QX60 5N1AL0MM3FC535335 NYC Motorcars of Freeport 6/20/2019
M. Paulino 2016 Acura TLX 19UUB2F5XGA007439 World Auto 6/20/2019
E. Rustemi 2016 Hyundai Sonata 5NPE24AF9GH334275 World Auto 6/22/2019
N. Jean Pierre 2016 Nissan Altima 1N4AL3AP3GC221521 NYC Motorcars of Freeport 6/24/2019
J. Rodriguez 2016 Acura TLX 19UUB2F59GA010235 World Auto 6/24/2019
J. Jordan 2016 Volkswagen Jetta 3VWL17AJ6GM299542 World Auto 6/26/2019
C. Chevalier 2017 Ford Fusion 3FA6P0H94HR184417 World Auto 6/26/2019
X. Jadan 2017 Ford Fusion 3FA6P0H95HR203203 Automania 6/27/2019
M. Uddin 2016 Toyota RAV4 2T3RFREV2GW480613 World Auto 6/27/2019
E. Clarke 2017 Toyota Camry 4T1BF1FK7HU701267 World Auto 6/29/2019
H. Uzquiano Robles 2018 Dodge Grand Caravan 2C4RDGEG9JR159505 World Auto 6/29/2019
R. Vernet 2016 Honda Civic LX 2HGFC2F54GH523612 NYC Motorcars of Freeport 7/2/2019
E. Ramkissoon 2016 Mazda Mazda3 3MZBM1W70GM253170 NYC Motorcars of Freeport 7/2/2019
N. Hylton 2015 Infiniti Q50 JN1BV7AR8FM423932 NYC Motorcars of Freeport 7/5/2019
W. Wei 2017 Audi Q7 WA1LAAF74HD054128 NYC Motorcars of Freeport 7/5/2019
W. Dudley 2015 Audi Q7 WA1LGAFE5FD028552 NYC Motorcars of Freeport 7/5/2019
W. Mardner 2016 Nissan Rogue KNMAT2MV4GP729147 World Auto 7/5/2019
M. Plascencia 2015 Infiniti Q50 JN1BV7AR1FM409712 NYC Motorcars of Freeport 7/6/2019
V. Svyryda 2016 Honda Accord 1HGCR2F52GA164468 NYC Motorcars of Freeport 7/6/2019
J. Aguirre 2016 Honda HR-V 3CZRU6H77GM757236 NYC Motorcars of Freeport 7/6/2019
O. Wallace 2018 Nissan Altima 1N4AL3AP5JC209961 Automania 7/11/2019
J. Dolcy 2016 Toyota Highlander 5TDJKRFH0GS293499 NYC Motorcars of Freeport 7/18/2019
O. Sederquist 2016 Acura TLX 19UUB2F55GA008479 NYC Motorcars of Freeport 7/25/2019
E. Kyte 2016 Nissan Rogue 5N1AT2MV8GC829853 World Auto 7/31/2019
D. Torres 2016 Honda Civic 19XFC2F55GE224642 Automania 8/1/2019
V. Williams 2016 Infiniti Q50 JN1EV7AR7GM345335 World Auto 8/2/2019
J. Valderrama-Correa 2016 Nissan Rogue 5N1AT2MV6GC899951 World Auto 8/3/2019
A. Udo 2016 Jeep Cherokee 1C4PJMDB3GW271012 World Auto 8/3/2019
R. London 2018 Honda Civic 2HGFC2F55JH526994 World Auto 8/9/2019
A. Beasley 2015 Infiniti Q50 JN1BV7AR8FM419220 World Auto 8/13/2019
F. Saleh 2016 Cadillac Escalade 1GYS4DKJ9GR375184 NYC Motorcars of Freeport 8/15/2019
D. Delacruz 2015 Acura TLX 19UUB2F56FA015939 World Auto 8/22/2019
A. Hayles 2015 Nissan Altima 1N4AL3AP6FC201679 World Auto 8/22/2019
W. Chery 2016 Honda Civic 2HGFC2F5XGH530841 NYC Motorcars of Freeport 8/26/2019
A. Quiroz 2016 Honda Civic 19XFC2F7XGE228686 Automania 8/31/2019
V. Soo 2016 Toyota RAV4 2T3BFREV0GW433968 World Auto 9/2/2019
S. Khan 2015 Infiniti Q50 JN1BV7AR2FM392466 World Auto 9/6/2019
T. Rodriguez 2016 Honda HR-V 3CZRU6H73GM747464 NYC Motorcars of Freeport 9/11/2019
A. Genao 2016 Honda CR-V 2HKRM4H31GH620144 World Auto 9/17/2019
O. Ramos 2016 Honda Accord 1HGCR2F3XGA242509 World Auto 9/30/2019
G. Gonzalez Jr. 2017 Acura ILX 19UDE2F71HA003130 NYC Motorcars of Freeport 10/1/2019
S. Islam 2016 BMW 5 Series WBA5A7C50GG150840 NYC Motorcars of Freeport 10/1/2019
N. Rojas 2016 Toyota Corolla 2T1BURHE8GC715108 NYC Motorcars of Freeport 10/5/2019

Page 2 of 3
 Exhibit H: Financed Sales by World Auto

Buyer Automobile VIN RIC dealer Sale Date

M. Taylor 2018 Dodge Grand Caravan 2C4RDGEG1JR254608 NYC Motorcars of Freeport 10/5/2019
M. Alam 2016 Nissan Rogue 5N1AT2MV4GC838033 World Auto 10/5/2019
D. Puda 2016 Toyota Highlander 5TDJKRFH0GS296774 NYC Motorcars of Freeport 10/7/2019
S. Lonecke Jr. 2016 Ford Fusion 3FA6P0HD9GR401950 World Auto 10/18/2019
M. Montes-Campo 2016 Kia Optima 5XXGV4L22GG061959 NYC Motorcars of Freeport 10/19/2019
J. Haughton 2019 Hyundai Sonata 5NPE34AF2KH746396 NYC Motorcars of Freeport 10/19/2019
M. Galdamez 2016 Lexus IS JTHCM1D20G5007478 World Auto 10/21/2019
K. Terry 2012 Buick LaCrosse 1G4GD5E3XCF152397 World Auto 10/24/2019
G. Walker 2016 Ford Fusion 3FA6P0H73GR393886 World Auto 10/25/2019
N. Chaufournier 2016 Toyota RAV4 JTMRFREV6GJ098857 World Auto 11/2/2019
R. Davenport 2018 Hyundai Elantra 5NPD84LF6JH335933 World Auto 11/11/2019
R. Davenport 2017 Nissan Sentra 3N1AB7AP4HL648333 NYC Motorcars of Freeport 11/12/2019
K. Agyeman 2016 BMW 5 Series WBA5A7C54GG643128 World Auto 11/12/2019
K. Haracz 2018 Dodge Grand Caravan 2C4RDGEG8JR143294 World Auto 11/25/2019
H. Kaul 2016 Audi A3 WAUE8GFF3G1035653 World Auto 11/29/2019
R. Fernandez 2016 Toyota RAV4 2T3BFREV5GW526338 World Auto 12/3/2019
B. Dimaio 2016 Infiniti Q50 JN1FV7ARXGM450231 NYC Motorcars of Freeport 12/5/2019
L. Contreras 2017 Honda Accord 1HGCR2F36HA121168 World Auto 12/11/2019
R. Festa 2016 Mercedes Benz C Class 55SWF4KB0GU157357 World Auto 12/21/2019
S. Ally 2016 Infiniti Q50 JN1EV7AR8GM345635 World Auto 1/11/2020
P. Torres 2017 Nissan Altima 1N4AL3AP8HC244505 World Auto 1/30/2020
C. Abreu-Reyes 2017 Subaru WRX JF1VA1J6XH9829263 NYC Motorcars of Freeport 2/7/2020
A. Sierra 2016 Nissan Murano 5N1AZ2MH3GN171937 World Auto 2/17/2020
C. Ferrarie 2017 Hyundai Sonata 5NPE34AF0HH499310 World Auto 2/20/2020
L. Bonilla 2017 Nissan Maxima 1N4AA6AP0HC376939 World Auto 2/21/2020
J. Boyle 2018 Mazda Mazda3 5 Door 3MZBN1L37JM209768 Automania 2/25/2020
R. Moreno 2018 Dodge Grand Caravan 2C4RDGEG1JR280951 World Auto 2/28/2020
A. Nunez 2017 Ford Fusion 3FA6P0HD0HR107516 World Auto 3/6/2020
P. Salas 2017 Chevrolet Traverse 1GNKVGKD8HJ112643 NYC Motorcars of Freeport 3/10/2020
M. Ramaj 2017 Infiniti Q60 JN1EV7EL1HM550317 World Auto 3/19/2020
F. Aidoo 2017 Toyota RAV4 2T3RFREV9HW642660 World Auto 5/12/2020
F. Mazuera 2016 Nissan Pathfinder 5N1AR2MM0GC607961 World Auto 5/21/2020
A. Cruz 2017 Ford Fusion 3FA6P0HD5HR153391 NYC Motorcars of Freeport 5/25/2020
A. Husak 2017 Hyundai Sonata 5NPE34AF5HH455948 World Auto 5/30/2020
K. Montano Gonzalez 2017 Audi A6 WAUG8AFC0HN015480 World Auto 6/3/2020
S. Wong 2017 Kia Sorento 5XYPKDA59HG337962 World Auto 6/5/2020
W. Chandler 2018 Dodge Grand Caravan 2C4RDGEG1JR345474 NYC Motorcars of Freeport 6/13/2020
K. Lalama-Mendes 2016 Infiniti Q50 JN1EV7AR6GM343849 World Auto 6/15/2020
L. Logan 2016 BMW 5 Series WBA5A7C50GG146352 World Auto 6/17/2020
B. Ward 2017 Audi A6 WAUG8AFC3HN012122 World Auto 6/19/2020
R. Rivera 2017 Toyota Sienna 5TDKZ3DC0HS814565 Luxury Automotive Club 6/20/2020
D. Betancourt Peralta 2018 Mazda CX-9 JM3TCBCY4J0208943 World Auto 6/27/2020
R. Bien-Aime 2017 Honda Civic 19XFC2F76HE205343 World Auto 7/7/2020
L. Carrillo 2017 Subaru WRX JF1VA2Y66H9820197 Luxury Automotive Club 7/24/2020
R. Torres 2015 BMW 3 Series WBA3B5G55FNS16893 NYC Motorcars of Freeport illegible
A. Belvett 2016 Jeep Cherokee 1C4PJMDS8GW119856 NYC Motorcars of Freeport undated
K. Ganni 2015 Chrysler 200 1C3CCCAB0FN677006 World Auto undated
R. Haywood 2016 Acura ILX 19UDE2F80GA012070 World Auto undated
G. Wade 2016 Hyundai Sonata 5NPE24AF3GH434078 World Auto undated
B. Kawal-Roberts 2016 Nissan Rogue 5N1AT2MV4GC785205 World Auto unknown

Page 3 of 3
Exhibit I
 Exhibit I. Financed Sales by Automania

Buyer Automobile VIN RIC dealer Sale Date

E. Reyes 2017 Toyota RAV4 2T3BFREV1HW601831 Automania 5/21/2020
M. Cuevas 2014 Toyota Corolla 2T1BURHE7EC020552 World Auto 8/14/2020
J. Cahill 2017 Nissan Sentra 3N1AB7AP0HY277979 World Auto 8/30/2020
O. Martinez 2017 Mercedes-Benz Mercedes-AM WDDWJ6EB5HF449757 World Auto 8/31/2020
S. Diaz 2017 Infiniti QX60 5N1DL0MM7HC512589 World Auto 9/3/2020
V. Singh 2017 Ford Focus 1FADP3H23HL330607 JF2 at 6020 9/5/2020
V. Wong 2017 Nissan Rogue KNMAT2MV0HP593083 JF2 at 6020 9/5/2020
R. Rozagatsjov 2017 Ford Explorer 1FM5K8D82HGD41087 World Auto 9/5/2020
A. Mercado 2017 Acura TLX 19UUB1F54HA001499 World Auto 9/5/2020
I. Ramos 2017 Hyundai Elantra KMHD84LF2HU321040 World Auto 9/5/2020
D. Shun 2017 Nissan Altima 1N4AL3AP7HC244902 World Auto 9/5/2020
P. Garcia Siavichay 2017 Honda CR-V 2HKRW2H59HH644063 World Auto 9/6/2020
M. Merida 2017 Nissan Rogue 5N1AT2MV9HC752766 World Auto 9/6/2020
N. Pierre 2017 Nissan Rogue JN8AT2MV7HW015315 JF2 at 6020 9/7/2020
A. Mendoza 2017 Kia Sorento 5XYPHDA58HG323419 World Auto 9/7/2020
G. Rodriguez 2018 Honda CR-V 2HKRW2H87JH611627 World Auto 9/7/2020
J. Moncada 2017 Nissan Rogue 5N1AT2MV6HC826404 World Auto 9/7/2020
N. Vil 2017 Nissan Rogue JN8AT2MV9HW250153 World Auto 9/7/2020
C. Henry 2018 Acura TLX 19UUB1F56JA001199 JF2 at 6020 9/8/2020
A. Kaplan 2017 Acura MDX 5FRYD4H74HB018870 World Auto 9/8/2020
H. Henriquez 2018 Nissan Sentra 3N1AB7AP4JY260687 JF2 at 6020 9/9/2020
M. Bowry 2017 INFINITI Q50 JN1EV7AR2HM838616 World Auto 9/9/2020
G. Kaur 2017 Audi A6 WAUF8AFC2HN065714 World Auto 9/9/2020
V. Eubanks 2017 Toyota Corolla 2T1BURHE1HC810286 World Auto 9/14/2020
C. Iribuka 2017 Mazda 6 JM1GL1V56H1115403 JF2 at 6020 9/22/2020
A. Al Fakih 2018 Toyota Corolla 5YFBURHE7JP800612 World Auto 9/23/2020
F. Menendez Martinez 2017 Honda HR-V 3CZRU6H70HM729280 World Auto 9/24/2020
T. Jayson Hubbard 2017 Nissan Rogue 5N1AT2MV0HC872181 World Auto 9/24/2020
S. Adhikari 2017 Nissan Rogue JN8AT2MV6HW275480 World Auto 9/24/2020
C. Roque Lopez 2017 Acura MDX 5J8YD4H50HL006360 JF2 at 6020 9/25/2020
K. Cabral Galva 2017 Jeep Grand Cherokee 1C4RJFBGXHC864646 World Auto 9/25/2020
S. Sacco 2017 Kia Sorento 5XYPKDA56HG338082 World Auto 9/25/2020
T. Weeks 2017 Kia Sportage KNDPNCACXH7229704 JF2 at 6020 3/8/2021
Exhibit J
 Exhibit J. Financed Sales by LAC

Buyer Automobile VIN RIC dealer Sale Date

R. Hoomanawanui 2017 Nissan Rogue KNMAT2MV6HP606550 LAC 8/25/2020
L. Lefkowitz 2018 Hyundai Sonata 5NPE34AF9JH594700 World Auto 8/26/2020
M. Stefanidis 2016 BMW X1 WBXHT3C32GP887686 World Auto 8/28/2020
K. Schwartz 2017 Hyundai Elantra 5NPD84LF2HH181649 World Auto 8/29/2020
S. Das 2015 Lexus RX 2T2BK1BAXFC305000 World Auto 8/29/2020
A. Dufresne 2017 Acura ILX 19UDE2F70HA007346 World Auto 9/25/2020
E. Durango 2017 Mazda 3 3MZBN1V74HM120024 LAC 12/11/2020
A. Burgos Mendez 2016 Acura MDX 5FRYD4H47GB058333 JF2 at 6020 1/6/2021
Gomez 2014 Infiniti Q50 JN1BV7AR1EM687363 LAC 2/17/2021
O. Ba 2017 Mercedes-Benz C-Class WDDWF4KB5HR242973 LAC 3/4/2021
R. Perez 2018 Honda Accord 1HGCV1F16JA031240 LAC 3/4/2021
P. Allala 2018 Mercedes GLC WDC0G4KB2JV048342 LAC 6/19/2021
G. Rojas 2017 Honda Civic 2HGFC2F76HH558848 LAC 7/30/2021
Atkinson 2018 Infiniti Q60 5N1DL0MM5JC517988 JF2 at 6020 9/16/2021
Exhibit K
Exhibit L
 Exhibit L: Restitution
Antonio Darling
Araceli Marquez- Kishauna Flores & Betancourt
Fuentes McLaurin Samuel Perez Mayra Plaza Patirck Allala Peralta Tracy Weeks Gabriel Rojas Earl Atkinson
Advertised or Promised Price $ 16,995.00 $ 17,580.00 $ 14,400.00 $ 12,000.00 $ 24,871.00 $ 18,990.00 $ 14,999.00 $ 15,795.00 $ 27,881.00
Less: Trade-in Allowance $ (2,800.00)
Legal Add-on Product
CT VA NJ NJ NJ
Sales Tax $ 1,079.18 $ 929.89 $ 1,278.00 $ 1,065.00 $ 1,647.70 $ 1,685.36 $ 993.68 $ 860.92 $ 2,474.44
CT VA NJ NJ NJ
Fees $ 190.00 $ 13.11 $ 262.00 $ 262.00 $ 156.50 $ 262.00 $ 156.50 $ 156.50 $ 262.00
Processing fee $ 75.00 $ 75.00 $ 75.00 $ 75.00 $ 75.00 $ 75.00 $ 75.00 $ 75.00 $ 75.00
Total $ 18,339.18 $ 18,598.00 $ 16,015.00 $ 13,402.00 $ 26,750.20 $ 21,012.36 $ 16,224.18 $ 14,087.42 $ 30,692.44
Down Payment $ 15,000.00 $ 1,000.00 $ 2,000.00 $ 6,884.00 $ 1,500.00 $ 7,000.00 $ 4,200.00 $ 4,300.00 $ 20,000.00
Amount Financed $ 17,598.00 $ 14,015.00 $ 6,518.00 $ 25,250.20 $ 14,012.36 $ 12,024.18 $ 9,787.42 $ 10,692.44
Not relevant for
APR 20.94% 8.10% 20.89% 10.99% 17.09% 13.89% 3.04% 3.99%
restitution because
No. of Months (as on RIC) 72 72 72 75 72 75 72 75
buyer was illegally
Monthly Payment compelled to $431.17 $246.41 $159.51 $466.91 $312.42 $240.73 $148.88 $161.32
Finance Charges finance. $ 13,445.90 $ 3,726.75 $ 4,966.38 $ 9,767.93 $ 8,482.23 $ 6,030.37 $ 932.09 $ 1,406.24
Total Payments $ 31,043.90 $ 17,741.75 $ 11,484.38 $ 35,018.13 $ 22,494.60 $ 18,054.55 $ 10,719.51 $ 12,098.68
Total Sale Price $ 18,339.18 $ 32,043.90 $ 19,741.75 $ 18,368.38 $ 36,518.13 $ 29,494.60 $ 22,254.55 $ 15,019.51 $ 32,098.68
(what buyer should have paid)
1
Total Sale Price from RIC $ 28,049.00 $ 45,132.32 $ 27,464.96 $ 35,332.88 $ 56,319.00 $ 46,268.80 $ 40,738.50 $ 31,069.52 $ 51,533.75
Difference $ 9,709.82 $ 13,088.42 $ 7,723.21 $ 16,964.50 $ 19,800.87 $ 16,774.20 $ 18,483.95 $ 16,050.01 $ 19,435.07
Out-of-Pocket Expenses $ 746.98 $ 53.26 $ 8,926.53 $ 529.25
Restitution $ 9,709.82 $ 13,088.42 $ 7,723.21 $ 17,711.48 $ 19,854.13 $ 25,700.73 $ 18,483.95 $ 16,579.26 $ 19,435.07
Bank of America Capital One Bank of America Westlake Capital One Westlake Capital One Bank of America Westlake
1 Marquez-Fuentes Total Paid (down payment + payments to Bank of America)
For Selina Cruz and Jhonaikir Almanzar, Petitioner requests a full refund of all payments made, or to be made, by them toward the purchase and repair of their 2017 Nissan Pathfinder upon the return of the automobile to
Respondents.