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PETER C. HARVEY ATTORNEY GENERAL OF NEW JERSEY Richard J. Hughes Justice Complex 25 Market Street PO ... - page 30 / 53

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166. Pursuant to N.J.S.A. 58:10-23.11u.a.(1)(a) and N.J.S.A.

58:10-23.11u.b., plaintiff DEP may bring an action in the Superior

Court for injunctive relief, N.J.S.A. 58:10-23.11u.b., for its

unreimbursed investigation, cleanup and removal costs, including

the reasonable costs of preparing and successfully litigating the

action, N.J.S.A. 58:10-23.11u.b.

167. Pursuant to N.J.S.A. 58:10-23.11u.a.(1)(a) and N.J.S.A.

58:10-23.11u.b., plaintiff DEP may bring an action in the Superior

Court for injunctive relief, N.J.S.A. 58:10-23.11u.b., for any

other unreimbursed costs or damages plaintiff DEP incurs under the

Spill Act, N.J.S.A. 58:10-23.11u.b.(5).

168. Pursuant

to

N.J.S.A.

58:10-23.11q.,

plaintiff

Administrator is authorized to bring an action in the Superior

Court for any unreimbursed costs or damages paid from the Spill

Fund.

PRAYER FOR RELIEF

WHEREFORE, plaintiffs DEP and Administrator pray that this

Court:

a.

Order Defendants to reimburse the Plaintiffs, jointly and

severally, without regard to fault, for all cleanup and

removal costs that the Plaintiffs have incurred as a

result of the discharge of hazardous substances at the

CCPW Sites, with applicable interest;

30

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