Requesting the Department of Justice (DOJ) initiate a civil judicial enforcement action pursuant to Section 17(a)(l) of TSCA, 15 U.S.C. 2616(a)(l), against the Defendant for violations of the Lead-Based Paint Renovation, Repair, and Painting (RRP) Rule. The RRP Rule was promulgated under Sections 402 and 406 of Title IV of the Toxic Substances Control Act (TSCA), 15 U.S.C. 2682 and 2686, and codified at 40 C.F.R. Part 745, Subpart E. The violations occurred during residential renovation activity conducted in New York City.