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PETER C. HARVEY ATTORNEY GENERAL OF NEW JERSEY Richard J. Hughes Justice Complex 25 Market Street PO ... - page 51 / 53

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identification

of

transportation

services

and

other

evidence

identifying the respective generato

r of the waste, at some sites,

impossible.

256. The

CCPW

generated

by

the

Defendants

is

indistinguishable, and all of the CCPW is uniformly harmful to the

public health and the environment.

257. Defendants either assume no remedial responsibility or,

alternatively, blame each other for the contamination at various

Hudson and Essex County CCPW Sites.

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, jointly

and

severally,

against the Defendants 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;

51

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