Professional Documents
Culture Documents
GURBIR S. GREWAL
ATTORNEY GENERAL OF NEW JERSEY
Richard J. Hughes Justice Complex
25 Market Street
P.O. Box 093
Trenton, NJ 08625-0093
Attorney for Plaintiffs
Plaintiffs,
v.
Defendants,
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New Jersey.
2. Since 1979, Monk's Amoco, Inc. has owned and operated a retail
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THE PARTIES
through -19.
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GENERAL ALLEGATIONS
Lot 121 on the Tax Map of the City of Camden (the "Property")
buildings.
11. By deed dated February 27, 1979, Monk's Amoco purchased the
$31,100.
Property.
13. The Property has been in use as a service station and/or auto
for kerosene and heating oil, two 6,000 gallon gasoline USTs,
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18. From April 10, 1984 through April 14, 1984, the Department
Property.
21. On April 16, 1984, DEP issued a Spill Act Directive to Hooper
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25. From July 8 to July 10, 1986, DEP also installed additional
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28. On May 19, 1992 and June 23, 1993, the Department accessed
30. On November 24, 1993, DEP issued a Joint Directive and Notice
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32. In May 1997, the Department checked the monitoring wells for
34. The Department investigated the Site again in April 1999 and
Standards.
35. In May 1999, the Department removed four 2,000 gallon gasoline
to maintain records.
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the Property.
Property.
40. The Department, between 1984 and the present, installed and
41. During the time that Defendant Monk's Amoco Inc. owned the
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other statutes and regulations, the Spill Act and WPCA, and
44. The Department has incurred past cleanup and removal costs
FIRST COUNT
Spill Act
herein.
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47. The costs that Plaintiffs have incurred, and will incur, for
(5).
48. Defendants Monk's Amoco and Hooper Monk are "persons" within
49. Monk's Amoco, as the owner of the USTs from which hazardous
23.11g.c.(1) .
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23.11g.C.(1).
23.11u.b.(5).
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appropriate.
the Property.
herein.
55. Defendants Monk's Amoco and Hooper Monk are "persons" within
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59. Hooper Monk was responsible for the conduct of Monk's Amoco
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failed to do so.
60. The Commissioner has incurred, and will incur, costs and
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action; and
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at the Property.
UNJUST ENRICHMENT
herein.
64. Plaintiffs have used and will continue to use public funds to
the Defendants.
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the Property.
GURBIR S. GREWAL
ATTORNEY GENERAL OF NEW JERSEY
Attorney for Plaintiffs
By.
Ro ert G. Camilla
Deputy Attorney General
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GURBIR S. GREwAL
ATTORNEY GENERAL OF NEW JERSEY
Attorney for Plaintiffs
By:
Robert G. Camilla
Deputy Attorney General
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controversy in this action are and have been the subject of the
following actions:
controversy in this action are not the subject of any other pending
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4:29-1. If, however, any such non-party later becomes known to the
all other parties and with this Court in accordance with R. 4:5-
1(b)(2) .
GURBIR S. GREV~TAL
ATTORNEY GENERAL OF NEW JERSEY
Attorney for Plaintiffs
By.
ert G. Camilla
Deputy Attorney General
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Case Caption: DEPT OF ENV. PROTECT ION VS MONK'S Case Type: ENVIRONMENTAL/ENVIRONMENTAL COVERAGE
AMOCO, INC. LITIGATION
Case Initiation Date: 12/06/2018 Document Type: Complaint
Attorney Name: ROBERT GREGORY LAMILLA Jury Demand: NONE
Firm Name: ATTORNEY GENERAL LAW Hurricane Sandy related? NO
Address: 25 MARKET STREET PO BOX 93 Is this a professional malpractice case? NO
TRENTON NJ 08625 Related cases pending: NO
Phone: If yes, list docket numbers:
Name of Party: PLAINTIFF : Dept of Env. Protection Do you anticipate adding any parties (arising out of same
Name of Defendant’s Primary Insurance Company transaction or occurrence)? NO
(if known): Unknown
I certify that confidential personal identifiers have been redacted from documents now submitted to the
court, and will be redacted from all documents submitted in the future in accordance with Rule 1:38-7(b)