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PETER C. HARVEY ATTORNEY GENERAL OF NEW JERSEY Richard J. Hughes Justice Complex 25 Market Street PO ... - page 39 / 53

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39 / 53

a.

Order PPG 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

PPG Sites, with applicable interest;

Enter declaratory judgment against PPG, jointly

and

severally, without regard to fault, for all cleanup

and

b.

removal costs that the Plaintiffs will incur as a result

of the discharge of hazardous substances at the PPG

jointly

and severally,

under

plaintiff DEP's

Sites;

Enter judgment

against PPG,

compelling PPG

to perform,

c.

oversight, any further remediation

substances discharged at the PPG Sites;

of hazardous

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 V

Liability for Three Times the Cost of Remediation

196. Plaintiffs DEP and Administrator repeat each allegation

of paragraph numbers 1 through 195, above as if set forth in its

entirety herein.

39

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