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PETER C. HARVEY ATTORNEY GENERAL OF NEW JERSEY Richard J. Hughes Justice Complex 25 Market Street PO ... - page 36 / 53

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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 Occidental 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

Occidental Sites, with applicable interest;

b.

Enter declaratory judgment against Occidental, 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

Occidental Sites;

  • c.

    Enter judgment against Occidental, jointly and severally, compelling Occidental to perform, under plaintiff DEP's oversight, any further remediation of hazardous substances discharged at the Occidental 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.

36

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