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
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,
206 and 207.
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
Plaintiff DEP and Administrator pray that this