This is an Administrative Penalty enforcement action pursuant to TSCA. The Respondents in this action are Robert C. Walton & William R. Turpin DBA Sunview Properties, and Betty J. Blocker Walton, and Jayne M. Turpin. The violations involve failure by Respondents to disclose potential lead based paint and/or lead based paint hazards at pre-1978 residential rental properties in San Diego, California prior to leasing these residential rental properties. Based upon the facts alleged in EPA's Complaint and upon statutory factors, EPA seeks to assess against Respondents a civil administrative penalty of up to $11,000 for each violation of Section 409 of TSCA (notice pleading).