RESPONDENT PERFORMED INSPECTIONS AND PREPARED AHERA MANAGEMENT PLANS FOR AT LEAST ONE BUILDING AT SCHOOLS AND AND ASSOCIATED SERVICE CENTER IN THE DAVIS COUNTY SCHOOL DISTRICT LOCATED IN DAVIS COUNTY, UTAH (APPROXIMATELY NINE BUILDINGS, REFERRED TO IN COMPLAINT AS THE LEA. THE 27 COUNTS IN THIS COMPLAINT CALL FOR A PROPOSED CIVIL PENALTY OF $113,000.