by this expedited referral, u.s. epa, region 5 requests that the u.s. attorney's office simultaneously file a complaint and consent decree resolving mr. moghul's violations of the residential lead-based paint hazard reduction act, 42 u.s.c. � 4852d, section 409 of tsca, and 40 c.f.r. part 745 requirements pertaining to disclosure of lead-based paint in residential real estate transactions. the proposed consent decree also resolves mr. moghul's failure to comply with a tsca subpoena which was the subject of a referral to the u.s. attorney's office in april 2003. under the terms of the consent decree, mr. moghul will perform lead paint hazard abatement of all his properties, and pay a civil penalty of $5,000.