EPA's 126-count civil administrative complaint alleges that Mr. Ed Klugman (company president) failed to meet Federal lead-based paint disclosure requirements in leasing 21 pre-1978 housing units in Phoenix and Glendale, Arizona, including, among other counts, failing to provide the Federally-required lead hazard pamphlet; failing to include the Federally-required lead warning statement in leasing contracts; and failing to provide information on lead-based paint and/or lead-based hazards, or to indicate a lack of such information, when executing the 21 leases.