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PETER C. HARVEY ATTORNEY GENERAL OF NEW JERSEY Richard J. Hughes Justice Complex 25 Market Street PO ... - page 42 / 53

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42 / 53

a.

Order

defendants

Honeywell,

Occidental

and

PPG

to

reimburse plaintiff DEP, jointly and severally, for three

times the cleanup and removal costs incurred by DEP

for the

sites listed in Paragraph 202, above;

b. Order defendants Honeywell, Occidental

and

PPG to

reimburse plaintiff DEP, jointly and severally, for three

times the cost of all future remediation of the Sites listed

204. Pla

intiffs repeat each allegation of Paragraphs 1 through

203, above, a

s if set forth in its entirety herein.

Strict Liability

contamination

at the CCPW Sites constitutes a physical invasion of

public proper

ty and an unreasonable and substantial interference,

COUNT VII

fees

in

this

action;

as

the

Court

deems

its

costs

and

such

relief

are

206. The

use, enjoyment and existence of uncontaminated

in Paragraph 202, above;

plaintiff

DEP

205. Soi

l, ground water, surface water and

wetlands

natural resou

rces of the State held in trust by the State.

natural resou

rces is a right common to the general public.

207. The

soil, ground water, surface water and wetlands

Award

plaintiff

DEP

d. Award

appropriate.

c.

and,

42

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