Respondent is the owner/lessor/agent for at least 25 buildings which are comprised of approximately 317 units, located primarily in Brooklyn, NY. Respondent did not complete any disclosure procedures for at least 8 tenants. Thirty leases were requested and reviewed after the Respondent provided a list of 26 properties, one of which was an empty lot, and one of which is his private residence. The Complaint is based on total non-disclosure for 8 tenants. Complaint was originally referred to EPA by HUD, and documents were received from Respondent in response to a subpoena.