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PETER C. HARVEY ATTORNEY GENERAL OF NEW JERSEY Richard J. Hughes Justice Complex 25 Market Street PO ... - page 41 / 53

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41 / 53

d. Award

plaintiff

DEP

such

relief

as

the

Court

deems

appropriate.

COUNT VI

Liability for Three Times the Cost of Remediation

200. Plaintiffs DEP and Administrator repeat each allegation

of paragraph numbers 1 through 199, above, as if set forth in its

entirety herein.

201. Plaintiff DEP issued Joint Directives to Honeywell, PPG

and Occidental for remediation of the sites listed in paragraphs

96, 98 and 100.

202. Defendants Honeywell, Occidental and PPG failed to comply

with the Joint Directives by refusing to remediate the sites listed

in the Joint Directives, which include CCPW Site numbers 20, 21,

77, 86, 139, 141, 150, 152, 174, 177, 186, 192, 202, 203, 204,

205,

206 and 207.

203. By

failing

to

comply with

the

Joint

Directives,

the

defendants Honeywell, Occidental and PPG are 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

listed

in

the

Joint

Directives.

N.J.S.A. 58:10-23.11f.a(1).

WHEREFORE,

Plaintiff DEP and Administrator pray that this

Court:

41

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