THIS COMBINED COMPLAINT AND CONSENT AGREEMENT IS ISSUED TO CAPITAL GROWTH CORPORATION, THE OWNER OF WILLOW GLEN APARTMENTS FOR FAILING TO INCLUDE A STATEMENT DISCLOSING THE PRESENCE OF ANY KNOWN LEAD-BASED PAINT AND OR LEAD BASED PAINT HAZARDS (OR LACK OF KNOWLEDGE OF SUCH PRESENCE), WITHIN LEASE CONTRACTS BEFORE RENTERS/LESSEES AREE OBLIGATED OR ENTER INTO LEASE CONTRACTS.