In April 2015, plaintiffs Margarita Ordonez and Alfredo Perez Gonzalez moved into a fourplex near the Staples Center, in downtown Los Angeles, with their daughter, Kaitlyn Perez, a minor, and their parents (Kaitlyn’s grandparents), Teresa Gonzalez-Vasquez and Alfredo Perez Rivera. One year later, Janice Perez, daughter of Ordonez and Perez Gonzalez, was born. In May 2018, a routine venous blood test revealed that Janice, then 22 months old, had a blood lead level of 11 mcg/dL, which is more than double the mean reference value of .86 mcg/dL in United State children, as established by the Centers for Disease Control. Subsequent blood tests revealed slowly declining blood lead levels for Janice of 10, 9, 7, 3.36 and 2.41 mcg/dL. As a result, Janice’s blood lead levels fell well within the definition of lead poisoning under applicable law. Janice’s family claimed that the fourplex’s condition caused them to be exposed to lead, as well as water leaks, cockroaches and mice. They also claimed that the property’s poor condition was never fully resolved. Ordonez, Perez Gonzalez, Janice, Kaitlyn, Gonzalez-Vasquez and Perez Rivera sued their property’s landlords, Shmuel Raigorododsky, Ludmila Raigorodsky and Yeshaya Lowenstein; and the manager of the property, SNS Realty Inc. The family alleged that the defendants actions constituted a breach of the implied warranty of habitability, a tortious breach of the implied warranty of habitability, negligence, a private nuisance, 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 property was built in the early 1900s, at a time when exterior and interior house paint contained significant amounts of lead, and that all paint on residential structures built prior to 1978 are presumed, as a matter of law, to contain lead-based paint. Counsel also contended that the plaintiff family, their neighbor and a property inspection report obtained by the defendants’ prior owner revealed that the exterior of the property had extensive amounts of peeling and deteriorated paint. In addition, counsel contended that testing performed by the Los Angeles County Department of Public Health, the plaintiffs’ lead inspectors, and the lead inspectors engaged by the Los Angeles Housing and Community Investment Department Lead Hazard Remediation Program all confirmed the presence of substantial amounts of deteriorated lead-based paint, lead dust and soil lead in and around the property. As a result, plaintiffs’ counsel argued that the defendants were negligent for failing to provide the family with the U.S. Environmental Protection Agency’s pamphlet, titled "Protect Your Family From Lead in Your Home," as required by 42 U.S.C. § 4852d, and for failing to identify, test for and abate the deteriorated lead-based paint on the exterior and interior of the family’s home. Defense counsel argued that the plaintiffs caused the conditions at the property and that SNS Realty and the individual landlords all complied with the city of Los Angeles, the county of Los Angeles, the Los Angeles County Department of Public Health, and the Los Angeles Department of Building and Safety’s inspection notices and/or citations regarding the property., The plaintiffs claimed that Janice was exposed to the deteriorated lead-based paint and other lead hazards at the rental home for approximately two years, from 2016 to 2018, prior to Janice’s first blood test. Developmental, speech and neuropsychological testing conducted by the plaintiffs’ experts confirmed that Janice suffered from significant deficits, which included a loss of IQ resulting in borderline intellectual functioning, speech and language deficits, and attention-deficit/hyperactivity disorder. The plaintiffs further alleged that a decline in Janice’s head circumference was caused by her lead poisoning. Janice’s pediatrician did not confirm the diagnosis of the plaintiffs’ experts, yet expressed concern over Janice’s head circumference. Janice’s life care plan included future medical care, and assisted living and housing. Janice, her parents, her grandparents and her sister were all exposed to lead, as well as water leaks, cockroaches and mice. They claimed the housing conditions at the property caused significant anxiety and chronic toxic stress for each and every family member. As a result, they each sought recovery of damages for their past and future pain and suffering.