On April 1, 2018, plaintiff Agustin Martinez, 34, a baker, and plaintiff Marina Martinez Luis, 31, a homemaker, leased a Los Angeles home that was owned by Golden Western LLC. Martinez and Luis moved to the home with their two young children, Mia Martinez and Jacob Martinez, and Agustin Martinez’s father, Jaime Hernandez. Soon thereafter, Chelsy Martinez and Izzac Hernandez were born to Agustin Martinez and Luis. Mia, Jacob, Chelsy and Izzak gradually began demonstrating inattentiveness, impulsivity, aggression and moodiness. Jacob also experienced delayed language development. Agustin Martinez and Luis claimed that the children’s symptoms were consistent with childhood lead poisoning. The mean blood-lead concentration in U.S. children is 0.86 micrograms per deciliter. Mia’s concentration was 2 mcg/dL; Jacob’s concentration was 4 mcg/dL; Chelsy’s concentration was 5 mcg/dL; and Izzac’s concentration was 7 mcg/dL. On Oct. 28, 2021, the U.S. Centers for Disease Control lowered the reference level for lead in blood from 5 mcg/dL to 3.5 mcg/dL. Agustin Martinez, Luis and the children sued Golden Western LLC and its sole managing member, Robinson Haiem, who personally managed the premises and Golden Western’s employees. The lawsuit alleged that the defendants were negligent in their maintenance of the premises. The lawsuit further alleged that the defendants’ negligence created a dangerous condition that constituted a breach of the premises’ implied warranty of habitability, an intentional infliction of emotional distress, a violation of Civil Code §1942.4 and a violation of Business & Professions Code § 17200. Plaintiffs’ counsel contended that the residence was built in the early 1900s, at a time when exterior and interior house paint contained as much as 50 percent lead content. Counsel asserted that an inspection confirmed the presence of deteriorated lead-based paint far in excess of federal and state regulatory limits throughout the property. Plaintiffs’ counsel contended that the onsite manager had presented the Martinez family lease documents to sign and that when the family told the manager that they could not read the English language lease documents, the manager told them that if they did not sign the documents that day, the residence would be leased to another tenant. Counsel asserted that shortly after moving in, the family discovered that the exterior and interior paint at the property was chipped and flaking and that, despite the condition of the paint, the defendants failed to identify, test or abate the lead-based hazard. Counsel asserted that, instead, the defendants told the Martinez family that they could either paint the deteriorated surfaces themselves or move out. Plaintiffs’ counsel contended that after the lawsuit was filed, the defendants sent a mold inspector to the home to test for lead, but the inspector had no certification in lead testing or remediation. Counsel contended that the inspector scraped paint off components in the house, which only increased the lead hazard in the home. Plaintiffs’ counsel further contended that the Martinez family complained about a serious cockroach and vermin infestation at the property, but that the defendants failed to address the situation. Defense counsel contended that once notified of unsafe conditions, the landlord promptly responded to each of the repair requests. Counsel also disputed plaintiffs’ counsel’s claims about the mold inspector and contended that in regard to the family’s allegations associated with lead poisoning, the landlord hired lead experts and undertook efforts to abate the lead conditions, including temporarily relocating the tenants., The plaintiffs family claimed that they were exposed to deteriorating lead-based paint and other lead hazards at the rental home since April 1, 2018. They claimed that Mia, Jacob, Chelsy and Izzac resultantly suffer significant deficits, including diminution of IQ, cognitive deficits, attention-deficit/hyperactivity disorder, executive function deficits, academic underachievement, and speech and language deficits. The family also claimed that they were exposed to cockroaches and rodents, non-functioning heaters, and other substandard housing conditions. They claimed that the housing conditions at the property caused significant anxiety and chronic toxic stress for every family member. The Martinez family sought recovery of damages for their past and future pain and suffering. Defense counsel disputed the nature and extent of the plaintiffs’ damages.