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PETER C. HARVEY ATTORNEY GENERAL OF NEW JERSEY Richard J. Hughes Justice Complex 25 Market Street PO ... - page 40 / 53

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remediation of the sites listed in paragraphs 87,

89, 91 and 93.

198. Defendant-generator Honeywell failed to

comply with the

Directives by refusing to remediate the sites

listed in the

Directives, which include CCPW Site numbers 7, 15,

17, 19, 67, 68,

69, 70, 91, 92, 93, 94, 97, 98, 99, 100, 101, 119

, 130, 138, 162,

197.

Plaintiff

DEP

issued

Directives

to

Honeywell for

165, 172, 175, 178, 180, 183, 185, 188, 189, 196, 197, 198, 199 and

200.

199. By failing to comply with the Directives, the defendant

Honeywell is jointly and severally liable in an amount equal to

three times the cleanup and removal costs plaintiffs DEP and

Administrator have incurred, and will incur, for the CCPW sites

referenced

in

paragraph

198,

above.

N.J.S.A.

58:10-23.11f.a(1).

WHEREFORE, Plaintiff DEP and Administrator pray that this

Court:

a.

Order

defendant

Honeywell,

jointly

and

severally, to

reimburse plaintiff DEP for three times the

cleanup and

removal costs incurred by plaintiff DEP for

the sites

referenced in paragraph 198, above;

b.

Order

defendant

Honeywell,

jointly

and

severally,

to

reimburse plaintiff DEP for three times the cost of all future

remediation for the sites referenced in paragraph 198, above;

c.

Award

plaintiff

DEP

its

costs

and

fees

in

this

action;

and,

40

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