EPA ALLEGES THAT ERMITANO VIOLATED THE DISCLOSURE RULE BY FAILING TO PROVIDE LEAD PAMPHLETS, DISCLOSE KNOW LEAN PAINT/HAZARDS, FURNISH LEAD PAINT RECORDS, AND/OR GIVE LEAD WARNING AND DISCLOSURE STATEMENTS PRIOR TO LEASING SIX MANCHESTER APARTMENTS BETWEEN SEPTEMBER 2004 AND JULY 2006. THE COMPLAINT PROPOSES A PENALTY OF $92,800.