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PETER C. HARVEY ATTORNEY GENERAL OF NEW JERSEY Richard J. Hughes Justice Complex 25 Market Street PO ... - page 5 / 53

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Jersey City, County of Hudson, State of New Jersey as Block 2025.A,

Lot 3.A, and Block 2026.A, Lots 1, 2.A and 3.B (“PPG Facility”).

GENERAL ALLEGATIONS

12.

Plaintiffs

were

not

in

any

way

responsible

for

the

CCPW

discharged in Hudson and Essex Counties, New Jersey.

13.

Despite

use

of

due

diligence,

Plaintiffs

have

been

unable

to ascertain which one or more of the Defendants is responsible for

the chromate chemical production waste contamination at various

Hudson and Essex County CCPW Sites in New Jersey; however, all of

that contamination was caused by one or more of the Defendants.

14.

The

Hudson

and

Essex

County

CCPW

Sites

are

all

located

within 10 miles of the Defendants’ chromate chemical production

facilities.

15.

The

Defendants

were

the

only

generators

of

CCPW

within

a

150 mile radius of Hudson and Essex Counties, New Jersey.

16.

During

the

course

of

their

respective

operations,

the

Defendants generated hundreds of thousands of tons of CCPW in

the

following amounts:

Honeywell and its predecessors

969,500 tons;

Occidental and its predecessors 771,500 tons;

and,

PPG and its

predecessors 330,000 tons.

17.

Each

Defendant

generated

CCPW

waste

at its respective

chromium production facility and arranged for

the

removal

and

disposal of its CCPW from its production plants.

5

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