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PETER C. HARVEY ATTORNEY GENERAL OF NEW JERSEY Richard J. Hughes Justice Complex 25 Market Street PO ... - page 34 / 53

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oversight, any further remediation of

hazardous

substances discharged at the Honeywell 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 III

Spill Act

178. Plaintiffs DEP and Administrator repeat each allegation

of paragraph numbers 1 through 177, above, as if set forth in its

entirety herein.

179. Occidental is a "person" within the meaning of N.J.S.A.

58:10-23.11b.

180. 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

CCPW Site numbers 41, 46, 49, 50, 51, 54, 58, 59, 60, 61, 103, 113,

116, 126, 131, 149, 167, 168, 176, 193, 209, and 210 (“Occidental

Sites”).

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

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

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

182. Occidental is the discharger of hazardous substances at

the Occidental Sites, and is liable, jointly and severally, without

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