DEFENDANT MANAGES VARIOUS RENTAL UNITS IN THE CHICAGO AREA. MOST OF THE BUILDINGS WERE CONSTRUCTED PRIOR TO 1978, WHICH MEANS THAT DEFENDAT MUST PERFORM VARIOUS DISCLOSURE ACTIVI- TIES AS REQUIRED BY SECTION 1018 AND ITS IMPLEMENTING REGU- LATIONS. THE U.S. EPA ISSUED A SUBPOENA TO DEFENDANT REQUESTING ALL LEASE AND DISCLOSURE DOCUMENTATION SINCE SEPTEMBER, 1996, WHICH WAS THE EFFECTIVE DATE OF THE REGULA- TIONS. ALSO, THE U.S. EPA RECEIVED INFORMATION FROM THE CHICAGO DEPARTMENT OF PUBLIC HEALTH (CDPH) PERTAINING TO THE PRESENCE OF LEAD POISENED CHILDREN AND LEAD-BASED PAINT IN UNITS MANAGED BY HYDE PARK. THE DOCUMENTATION SHOWED THAT HYDE PARK FAILED TO PROPERLY PERFORM DISCLOSURE ACTIVITIES IN 722 LEASING TRANSACTIONS. ALSO, TWENTY-NINE POISENED CHILDREN RESIDE OR HAVE RECENTLY RESIDED IN UNITS MANAGED BY HYDE PARK, AND THESE UNITS HAVE BEEN INSPECTED BY THE CDPH FOR LEAD. FOR SOME OF THESE UNITS, HYDE PARK HAS FAILED TO DISCLOSE THE PRESENCE OF LEAD-BASED PAINT AFTER IT OR THE OWNER OF THE UNIT HAD BEEN NOTIFIED BY THE CITY OF THE EXISTENCE OF LEAD-BASED PAINT IN THE UNIT.