The EPA alleges the Respondent violated section 12(a)(1)(A)(two counts) and 12(a)(2)(L)(one count) of FIFRA,7 U.S.C 136j(a)(1)(A) and (a)(2)(L), by holding an unregistered pesticide for unauthorized bulk sale and distribution, by selling and distributing an unregistered pesticide, and by failing to submit an accurate annual report of its pesticide production for 2003.