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PETER C. HARVEY ATTORNEY GENERAL OF NEW JERSEY Richard J. Hughes Justice Complex 25 Market Street PO ... - page 31 / 53

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b.

Enter declaratory judgment against Defendants, jointly

and severally, without regard to fault, for all cleanup

and removal costs that the Plaintiffs will incur as a

result of the discharge of hazardous substances at the

CCPW Sites;

  • c.

    Enter judgment against Defendants, compelling Defendants to perform, under plaintiff DEP's oversight, any further remediation of hazardous substances discharged at the CCPW Sites;

  • d.

    Award the Plaintiffs their costs and fees in this action;

and,

e.

Award the Plaintiffs

such other relief as this Court

deems appropriate.

COUNT II

Spill Act

169. Plaintiffs DEP and Administrator repeat each allegation

of paragraph numbers

1 through 168,

above,

as

if forth in its

entirety herein.

170. Honeywell is a "person" within the meaning of N.J.S.A.

58:10-23.11b.

171. 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

31

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