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PETER C. HARVEY ATTORNEY GENERAL OF NEW JERSEY Richard J. Hughes Justice Complex 25 Market Street PO ... - page 29 / 53

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161. Defendants are "persons" within the meaning of N.J.S.A.

58:10-23.11b.

162. Plaintiffs DEP and the Administrator have incurred, and

will continue to incur, costs as a result of the discharge and

unsatisfactory storage or containment of hazardous substances at

the CCPW Sites enumerated in Paragraphs 171, 180, 189. 198 and 202

of Counts II through VI of this Complaint, infra.

163. The costs the Plaintiffs have incurred, and will incur,

for the CCPW Sites are "cleanup and removal costs" within the

meaning of N.J.S.A. 58:10-23.11b.

164. Defendants are the dischargers of hazardous substances at

the CCPW Sites, and are liable, jointly and severally, without

regard to fault, for all cleanup and removal costs as a result of

the discharge of hazardous substances at the CCPW Sites.

N.J.S.A.

58:10-23.11g.c.(1).

165. Defendants, as the generators of hazardous substances

that were discharged at the CCPW Sites, fall within the scope of

the liability imposed on persons "in any way responsible" for the

discharged hazardous substances, and therefore are liable, jointly

and severally, without regard to fault, for all cleanup and removal

costs that the Plaintiffs have incurred, and will incur, as a

result of the discharge of hazardous substances at the CCPW Sites.

N.J.S.A. 58:10-23.11g.c.(1).

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