X hits on this document

PDF document

PETER C. HARVEY ATTORNEY GENERAL OF NEW JERSEY Richard J. Hughes Justice Complex 25 Market Street PO ... - page 45 / 53

127 views

0 shares

0 downloads

0 comments

45 / 53

  • 222.

    The use of CCPW as fill was inappropriate.

  • 223.

    The use of CCPW as fill had minimal or no value to the

community, as it heaves, migrates and is harmful to people and the

environment.

224. Defendants’ causing or allowing their respective CCPW to

be discharged at the CCPW sites makes the Defendants strictly

liable for engaging in an abnormally dangerous activity.

PRAYER FOR RELIEF

WHEREFORE, plaintiffs DEP and Administrator pray that this

Court:

a.

Order the Defendants, jointly and severally, to reimburse

the Plaintiffs for all cleanup and removal costs that the

Plaintiffs have incurred as a result of the

discharge of

hazardous substances at the CCPW Sites;

b.

Enter declaratory judgment against

the

Defendants,

jointly and severally, for all cleanup and removal costs

that the Plaintiffs will incur as a result of the

discharge of hazardous substances at the CCPW Sites;

  • c.

    Enter judgment against the Defendants, jointly and severally, compelling them to perform, under plaintiff DEP’s oversight, any further remediation of hazardous substances discharged at the CCPW Sites;

  • d.

    Award the Plaintiffs their costs and fees in this action; and,

45

Document info
Document views127
Page views127
Page last viewedThu Dec 08 14:47:52 UTC 2016
Pages53
Paragraphs2628
Words10878

Comments