complaint for injunctive relief floridaupenn fall 2022 courses

/Annots [] endobj 1. endobj The differences in the types and volume of MSW collected and in the equipment used in collection distinguish small container commercial waste collection from all other types of waste collection activities. /Annots [] << 50. COMPLAINT FOR INJUNCTIVE, DECLARATORY RELIEF, AND DAMAGES Plaintiff, STATE OF FLORIDA, DEPARTMENT OF LEGAL AFFAIRS sues Defendant, TODD TEAL d/b/a WALTER A. SMITH, SNUFFY SMITH, (TEAL) and alleges: NATURE OF THE ACTION 1. /Parent 11 0 R Permit restrictions often impose severe limitations on the type and amount of waste that can be disposed of at landfills. /Rotate 0 /Type /Page /Count 10 /MediaBox [0 0 612 792] 68. ( As such, following the process to the tee will help improve your chances for success. /Annots [] /Resources 409 0 R /Contents [310 0 R 311 0 R 312 0 R] This action arises under Chapter 713 and 720, Florida Statutes, and under the Fair Housing Act of 1968, as amended, 42 U.S.C. endobj endobj << << Defendants because the Amended Complaint seeks injunctive relief only for these Counts, to which qualified immunity does not apply. /Type /Page On August 20, . /MediaBox [0 0 612 792] 0 /Annots [] xb```b``Ig`a`X @1V hdc [`&&v/>4427pHG(Og|sW(7_HPpXp'Skgu`.8!B=\2+".b4dh fZ!WHW3`W+.eP9(tb1P,%pX1EaSO6I)1] K,cMpl q m D@,"R:7S&`u@6j(LjfLT[D1,BPf:9= P1!$Ippa8fHNtD {,nPY 5 "New York City, NY area" means the Borough of Brooklyn, New York. ("MFS"), is a Florida corporation that has a principal place of . /Annots [] In the Macon, GA market, Allied and Republic each account for a substantial share of total revenues from roll-off waste collection services. Transactions that increase the HHI by more than 100 points in highly concentrated markets presumptively raise antitrust concerns under the Horizontal Merger Guidelines issued by the U.S. Department of Justice and the Federal Trade Commission. /Rotate 0 /Resources 149 0 R Complaint for Emergency Injunctive Relief in Florida Primary /Rotate 0 >> The likely effect of these acquisitions is to substantially lessen competition and to tend to create a monopoly in interstate trade and commerce in violation of Section 7 of the Clayton Act. 38. /Annots [] ]\q( $QSRP@=8`) $CC16 PI_ XL _l {:\! >> /Rotate 0 /Parent 13 0 R << 9 0 obj In areas where it is not practical to construct and permit a landfill, it is necessary to put in a transfer station to get the waste to a more distant landfill. /Contents [102 0 R 103 0 R 104 0 R] 41 0 obj MSW generated by residential customers, on the other hand, is often collected by either local governments or by private haulers pursuant to contracts bid by, or franchises granted by, municipal authorities. 0000001187 00000 n 57. /Rotate 0 /Type /Page The transactions likely will have the following effects, among others: 1. /PageLabels 3 0 R 72 0 obj /Type /Page On July 28 and October 7, 1999, Allied and Republic entered into separate asset purchase agreements in which they agreed to exchange certain waste hauling and disposal assets. SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION In re: JOSE SANCHEZ Case No. Plaintiff, The Second Amendment Foundation, is a Washington Not-For-Profit After the acquisition, Allied would control over 35 percent--and two firms more than 80 percent--of the small container commercial waste hauling market, which has annual revenues of about $17 million. /CropBox [0 0 612 792] /CropBox [0 0 612 792] 18. /Parent 14 0 R 0000003404 00000 n /Kids [25 0 R 26 0 R 27 0 R 28 0 R 29 0 R 30 0 R 31 0 R 32 0 R 33 0 R 34 0 R] endobj 34 0 obj United States District Court Southern District of Florida Complaint for purposes of Florida Statutes Sections 501.207(5) and 95.11(3). Secure .gov websites use HTTPS /CropBox [0 0 612 792] 2. In the Lakeland, FL area, the acquisition would reduce from two to one the number of significant competitors in the collection of small container commercial waste. /Rotate 0 In the Macon, GA area, the proposed acquisitions would result in Republic controlling more than 60 percent of the roll-off waste collection market at the same time it owns the two primary disposal options which any roll-off competitor would most likely use. /MediaBox [0 0 612 792] 45. /Type /Pages /Type /Page /Annots [] ( /Resources 265 0 R /Rotate 0 REPUBLIC SERVICES, INC., 110 S.E. endobj A new entrant into small container commercial waste collection service cannot provide a significant competitive constraint on the prices charged by market incumbents until it achieves minimum efficient scale and operating efficiencies comparable to existing firms. >> /Parent 9 0 R Access to competitive disposal sites and reasonable disposal costs are important to providers of roll-off collection services. /CropBox [0 0 612 792] /Type /Page Page 3 of 15 7. /CropBox [0 0 612 792] >> /MediaBox [0 0 612 792] endobj Thus, disposal of MSW is a line of commerce, or relevant service, for purposes of analyzing the effects of the acquisition under Section 7 of the Clayton Act. << ? /Resources 225 0 R endobj PDF Complaint for Injunctive Relief, Damages, How to Obtain a Temporary (Preliminary) Injunction in Florida - Ewusiak Law >> /Count 10 In re Amendments to Florida Small Claims Rules, 123 So.3d 41 (Fla . endobj Copyright 2008-2023 Jimerson Birr, P.A. /Rotate 0 /CropBox [0 0 612 792] In the Macon, GA area, the acquisition would reduce from two to one the number of significant firms that compete in the collection of small container commercial waste. ( /Parent 14 0 R stream /CropBox [0 0 612 792] /Parent 14 0 R 89 0 obj /Rotate 0 /Annots [] 1391, . 85 0 obj /Parent 4 0 R /Parent 4 0 R /Rotate 0 THIS COURT'S POWER TO GRANT RELIEF 84. << /Annots [] /Parent 10 0 R 93 0 obj /Contents [214 0 R 215 0 R 216 0 R] 76 0 obj <> endobj >> /Rotate 0 /Rotate 0 31. After the acquisition, Allied would control over 55 percent--and two firms over 90 percent--of the small container commercial waste hauling market, which has annual revenues of about $28 million. ( Alexdex. /Rotate 0 << The predictable result is the denial of the vote to untold numbers of Floridians who had planned to vote in person on Election Dayincluding those who are elderly or have health conditions and cannot get to the polls without tremendous risk, university students who are no longer present in their county of registration because their dorms have closed, and those who venture out but encounter long lines and confusion at the polls. Small container commercial service vehicles routinely employ compaction systems on the truck to increase storage capacity, and can empty numerous small containers located on a scheduled route before being driven to a disposal site. /Resources 193 0 R endobj This is an action for injunctive relief. /Rotate 0 /Rotate 0 /CropBox [0 0 612 792] 31 0 obj /Parent 8 0 R /Kids [85 0 R 86 0 R 87 0 R 88 0 R 89 0 R 90 0 R 91 0 R 92 0 R 93 0 R] The proposed acquisition would reduce from three to two the number of significant competitors for the disposal of MSW in the Anderson, IN area. 6 0 obj As a result, Austin begins the presentation by sharing some of the things you should think about before pursuing an injunction: There is a lot on the line. Therefore, you should ask yourself these questions before proceeding: So, you answered the questions above, and you consider this to be the best approach to resolving your matter. WEST PALM BEACH DIVISION . To handle this high volume of MSW efficiently, haulers provide commercial customers with small dumpsters for storing the waste. /Resources 249 0 R Waiver recipients are entitled to continuation of services that they are currently receiving through the completion of the fair hearing /Resources 101 0 R /Annots [] /Rotate 0 /Annots [] /MediaBox [0 0 612 792] Jurisdiction is conferred on this Court by Chapters 26, 34, 86.011. /Parent 8 0 R endobj 2 0 obj In the Augusta, GA area, the acquisition would reduce from three to two the number of significant competitors in the collection of small container commercial waste. (ECF No. 0000001317 00000 n /Length 1411 22. /CropBox [0 0 612 792] Anderson, IN and New York City, NY are two such areas. /MediaBox [0 0 612 792] endobj 30 0 obj <>/Filter/FlateDecode/ID[<3860DCF29749FC4EACF121159FB5FA73><3860DCF29749FC4EACF121159FB5FA73>]/Index[25 7]/Info 24 0 R/Length 36/Prev 968458/Root 26 0 R/Size 32/Type/XRef/W[1 2 0]>>stream hUN@h/%FT""Qy@Kbxw81FgfvEN.tF2AiP9?{"1zQ. 40. Plaintiff, Florida Carry, is a Florida Not-For-Profit Corporation with a principal place of business located at 1090 Wild Holly Drive, Port Orange, Florida, 32129. >> Complaint for Injunctive Relief Case (s): U.S. v. Allied Waste Industries, Inc. and Republic Services, Inc. 32. endobj 7. /Filter /FlateDecode /Contents [342 0 R 343 0 R 344 0 R] .t. /Parent 11 0 R << /Rotate 0 /MediaBox [0 0 612 792] /Resources 333 0 R However, temporary injunctive relief may be granted without the posting of a bond in the following situations: 1) injunctions entered "on the pleading of a municipality or the state or any officer, agency, or political subdivision thereof"; or 2) injunctions "issued solely to prevent physical injury or abuse of a natural person." 64 0 obj Managing Partner %PDF-1.3 % PDF Complaint for Injunctive and Other Relief and Demand for Jury Trial I /CropBox [0 0 612 792] 13 0 obj /Contents [382 0 R 383 0 R 384 0 R] /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] /Type /Page /Parent 12 0 R 92 0 obj /Contents [394 0 R 395 0 R 396 0 R] 15 0 obj >> /Parent 4 0 R << /CropBox [0 0 612 792] endstream endobj 26 0 obj <> endobj 27 0 obj <>>>/Rotate 0/Type/Page>> endobj 28 0 obj <>stream /Annots [] This Court has jurisdiction to enter declaratory and injunctive relief pursuant to Florida Statute 86.011 and Article V, 20 of the Florida Constitution. >> << /Parent 8 0 R Markets in which the HHI is between 1000 and 1800 points are considered to be moderately concentrated, and those in which the HHI is in excess of 1800 points are considered to be highly concentrated. /Type /Page /Type /Page >> 61 0 obj /Resources 177 0 R << endobj 2201-202, and . PDF Complaint for injunction and declaratory relief In the Gulf Coast, FL area, the acquisition would reduce from four to three the number of significant competitors in the collection of small container commercial waste. /Type /Page /Contents [274 0 R 275 0 R 276 0 R] The cost advantage of local landfills limits the areas where MSW can be economically transported and disposed of by haulers and creates localized markets for MSW disposal services. 10941 and Laws of Florida, Ch. << >> Haulers, therefore, generally establish garages and related facilities within each major local area served. Plaintiff filed this action against defendant for breaching a non-competition agreement. /Rotate 0 59 0 obj .+p>hPhb4yiK=c`/XOv@|fe`iY /MediaBox [0 0 612 792] << The length of the presentation is 46:09. /Count 79 /Type /Page For example, for a market consisting of four firms with shares of thirty, thirty, twenty, and twenty percent, the HHI is 2600 (302 + 302 + 202 + 202 = 2600). endobj /Annots [] A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. There are no good substitutes for MSW disposal. PDF United States District Court Northern District of Florida Pensacola /Parent 11 0 R 0000001852 00000 n Finally, prices for small container service are influenced principally by the density of the routes served by each vehicle; prices for roll-off services are influenced primarily by the distance of the customer's location from the hauler's location and the disposal site, the time required to travel those distances, and the cost of disposal at the disposal site. /Resources 241 0 R 2. /Rotate 0 Allied is located in and transacts business in the District of Columbia, and Republic submits to the personal jurisdiction of the District of Columbia in this proceeding. /Type /Page This action is brought to ( /CropBox [0 0 612 792] /Parent 14 0 R << /Contents [258 0 R 259 0 R 260 0 R] The extension of vote-by-mail options and other accommodations at polling places is necessary. 66. /Annots [] After the acquisition, Republic would control over 50 percent--and two firms over 80 percent-- of the small container commercial waste hauling market, which has annual revenues of about $29 million. 74 0 obj Plaintiff LEAGUE OF WOMEN VOTERS OF FLORIDA ("LWVF" or the "League") is the Florida affiliate of the League of Women Voters of the United States. /Rotate 0 >> xref /Rotate 0 /Parent 10 0 R 95 0 obj /Annots [] >> A complaint for declaratory relief must allege the following: there is a bona fide dispute between the parties; the plaintiff has a justiciable question as to the existence or nonexistence of some right, status, immunity, power or privilege, or as to some fact upon which existence of such a claim may depend; IV. %PDF-1.3 % /Contents [206 0 R 207 0 R 208 0 R] /Resources 181 0 R The City changed its name from "New /MediaBox [0 0 612 792] /Annots [] endobj The customer's MSW is stored in much smaller containers (e.g., garbage bags or trash cans) and instead of FEL trucks, waste collection firms routinely use REL or side-load trucks, manned by larger crews (usually, two-or three-person teams). 57 0 obj /Type /Page /Parent 9 0 R That plaintiff recover the costs of this action. In the Columbus, OH area, the proposed acquisition would reduce from four to three the number of significant firms that compete in the collection of small container commercial waste. 60. 33 0 obj /Title (Microsoft Word - 2022-08-24 - Complaint - FINAL) /Annots [] /CropBox [0 0 612 792] /Resources 293 0 R >> >> << /Contents [354 0 R 355 0 R 356 0 R] and Florida Statute 86.011, et seq. /CropBox [0 0 612 792] /Parent 12 0 R /Contents [210 0 R 211 0 R 212 0 R] PDF United States District Court Southern District of Florida West Palm /Resources 349 0 R /CropBox [0 0 612 792] $4%&'()*56789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz r! /Annots [] Plaintiff is a Florida resident, lives in Miami- Dade County, is sui juris, and qualifies of a protected class under the ADA, 42 U.S.C. /Parent 7 0 R /Rotate 0 /CropBox [0 0 612 792] /Resources 257 0 R ( /Resources 365 0 R 63. 43 0 obj >> 27. 0000006750 00000 n In exchange, pursuant to other agreements, Republic would acquire from Allied: disposal assets in Anderson, Indiana; hauling assets in Columbus, Ohio; hauling assets in Lakeland, Florida; hauling assets in Louisville, Kentucky and Sellersburg, Indiana; hauling and disposal assets in Macon, Georgia; and hauling assets in Monmouth, Burlington and Camden counties, New Jersey. If the major roll-off collection competitor in a market also controls the primary disposal site(s) therein, other roll-off competitors are at a large disadvantage and entry is difficult. /Resources 373 0 R To access the presentation, visit YouTube or click play on the embedded image below. 53 0 obj /MediaBox [0 0 612 792] Small container commercial waste collection services are generally provided in highly localized areas because to operate efficiently and profitably, a hauler must have sufficient density in its commercial waste collection operations; i.e., a large number of commercial accounts that are reasonably close together. /Type /Page 0000001563 00000 n 3. However, the incumbents' use of price discrimination and long-term contracts prevents new entrants from winning a large enough base of customers to achieve efficient routes in sufficient time to constrain the post-acquisition firm from significantly raising prices after the transaction. /MediaBox [0 0 612 792] 28 0 obj /Contents [146 0 R 147 0 R 148 0 R] ( Plaintiffs also seek temporary injunctive relief as stated in the accompanying Motion for Temporary Injunction. /Contents [370 0 R 371 0 R 372 0 R] 78 0 obj /Type /Page 17 0 obj 40 0 obj 71 0 obj ( A .gov website belongs to an official government organization in the United States. 24 0 obj The acquisition would reduce from four to three the number of significant firms that compete in the collection of small container commercial waste in the Louisville, KY/Sellersburg, IN area. /Type /Page /Contents [110 0 R 111 0 R 112 0 R] << 52. /CropBox [0 0 612 792] << 90 0 obj /Contents [358 0 R 359 0 R 360 0 R] endobj endobj endobj 22 and 28 U.S.C. Is the injunction prohibitory or mandatory? Plaintiffs Rural & Migrant Ministry, Alianza Nacional De Campesinas, El Comite . What impact will it have on third-parties and employees? /Resources 205 0 R /Type /Page /CropBox [0 0 612 792] >> /Resources 377 0 R 34. endobj /CropBox [0 0 612 792] /Contents [346 0 R 347 0 R 348 0 R] << /Type /Page 47 0 obj Firms that compete in the disposal of MSW generated in the Anderson, IN or New York City, NY areas can profitably increase their charges for disposal of MSW generated in each area without losing significant sales to more distant disposal sites. /Contents [278 0 R 279 0 R 280 0 R] /Type /Page 12 0 obj /MediaBox [0 0 612 792] 3. After the acquisition, Allied would control roughly 30 percent--and two firms about 66 percent--of the New York City, NY area MSW disposal market, which has annual revenues of about $40 million. ( /Resources 313 0 R <> /Type /Page 45 0 obj /Parent 12 0 R /Resources 337 0 R /Rotate 0 /MediaBox [0 0 612 792] SOUTHERN DISTRICT OF FLORIDA . 0000000556 00000 n 20. 20 0 obj Injunctive relief is considered an extraordinary remedy in both State and Federal court. /Resources 233 0 R 3601, et seq. /MediaBox [0 0 612 792] 48 0 obj /Parent 9 0 R /Type /Page /CropBox [0 0 612 792] 45], filed on August 192021, . /Rotate 0 /Rotate 0 In the event of a small but significant increase in the price of the disposal of MSW in the Anderson, IN or New York City, NY areas, haulers of MSW generated in each area would not turn to disposal facilities outside their area. /Contents [362 0 R 363 0 R 364 0 R] The cost of transporting waste to a disposal site is often a substantial component of the cost of disposal. endobj 37 0 obj Parties 13. /Rotate 0 % "Nashville, TN area" means the City of Nashville and Davidson, Sumner, Williamson, Rutherford, Wilson, the southeastern part of Robertson, and the eastern part of Cheatham counties, Tennessee. In the Anderson, IN and New York City, NY areas, entry by any new MSW disposal facility would be an extremely costly and time-consuming process, and unlikely to prevent market incumbents from significantly raising prices for the disposal of MSW following the acquisition. /Type /Page 94 0 obj For a variety of reasons, other types of collection activities, such as roll-off containers (typically used for construction debris) and collection of liquid or hazardous waste, are also rarely combined with commercial waste collection activities. /CropBox [0 0 612 792] /MediaBox [0 0 612 792] << /MediaBox [0 0 612 792] /Length 3282 "Burlington and Camden Counties, NJ area" means Burlington and Camden counties, New Jersey. It is calculated by squaring the market share of each firm competing in the market and then summing the resulting numbers. Suitable landfills are difficult and time-consuming to obtain, and sometimes difficult to expand, because of the scarcity of suitable land, local resident opposition, environmental concerns, and government regulation. /Resources 309 0 R MSW does not include special handling waste (e.g., waste from manufacturing processes, regulated medical waste, sewage, and sludge), hazardous waste, or waste generated by construction or demolition sites. << /Type /Pages relief pursuant to Chapter 86, Florida Statutes. /MediaBox [0 0 612 792] Rule 1.610 of the Florida Rules of Civil Procedure governs requests for temporary injunctions. endobj /Contents [270 0 R 271 0 R 272 0 R] Likewise, roll-off customers generate volumes of waste which are too large to be serviced by a FEL truck on a pre-scheduled commercial route. /MediaBox [0 0 612 792] /CropBox [0 0 612 792] The HHI takes into account the relative size and distribution of the firms in a market and approaches zero when a market consists of a large number of firms of relatively equal size. /Parent 10 0 R /MediaBox [0 0 612 792] APPROPRIATENESS OF INJUNCTIVE RELIEF 26 . Plaintiff seeks temporary, preliminary, and permanent injunctive relief pursuant to Rule 65 . /Annots [] /CropBox [0 0 612 792] /Contents [182 0 R 183 0 R 184 0 R] /CropBox [0 0 612 792] 49 0 obj << << >> _______/s/____________________ Donna E. Patterson Deputy Assistant Attorney General, _________/s/__________________ Constance K. Robinson Director of Operations and Merger Enforcement, ________/s/___________________ J. Robert Kramer II Chief, Litigation II Section, _________/s/__________________ Willie L. Hudgins Assistant Chief, Litigation II Section, ___________/s/________________ Arthur A. Feiveson IL Bar # 3125793, __________/s/_________________ Michael K. Hammaker DC Bar # 233684, __________/s/_________________ Chinita M. Sinkler MD Bar, U.S. Department of Justice Antitrust Division, Litigation II Section 1401 H Street, NW, Suite 3000 Washington, D.C. 20530 (202) 307-0924. /Annots [] endobj endobj /Rotate 0 /Rotate 0 /MediaBox [0 0 612 792] /CropBox [0 0 612 792] endobj 4. have exclusive jurisdiction: (a) In all actions at law cognizable by the county . 9. /Annots [] /Resources 141 0 R An MSW disposal facility must be located on approved types of land and operated under prescribed procedures. >> Security Personnel as Independent Contractors Part I: What Makes an Individual an Independent Contractor Instead of an Employee? After the acquisition, Allied would control over 40 percent and two firms would control over 65 percent of the small container commercial waste hauling market, which has annual revenues of about $5 million. 47. "Transfer station" means an intermediate disposal site, often used in more densely populated areas, for the processing and temporary storage of solid waste before transfer, in bulk, to more distant facilities for final disposal. /Kids [35 0 R 36 0 R 37 0 R 38 0 R 39 0 R 40 0 R 41 0 R 42 0 R 43 0 R 44 0 R] /Type /Page >> %PDF-1.5 >> /Rotate 0 /Parent 9 0 R /CropBox [0 0 612 792] endobj /Annots [] 54. /Parent 4 0 R Very often courts do not grant injunctions if there is not a lot of specificity and practicality in the request for an injunction. ( Allied is the nation's second largest waste hauling and disposal company. In the Nashville, TN area, the acquisition would reduce from three to two the number of significant firms competing in the collection of small container commercial waste. The proposed transactions, identified below, would lessen competition substantially in waste collection and/or disposal services: (1) Allied's acquisition of hauling assets in Albany, New York; (2) Allied's acquisition of hauling assets in Augusta, Georgia; (3) Allied's acquisition of hauling assets in Memphis, Nashville and Clarksville, Tennessee; (4) Allied's acquisition of disposal assets in New York, New York; (5) Allied's acquisition of hauling assets in Norfolk, Virginia; (6) Allied's acquisition of hauling assets in Okaloosa, Escambia and Santa Rosa counties, Florida ("Gulf Coast, Florida"); (7) Republic's acquisition of disposal assets in Anderson, Indiana; (8) Republic's acquisition of hauling assets in Columbus, Ohio; (9) Republic's acquisition of hauling assets in Lakeland, Florida; (10) Republic's acquisition of hauling assets in Louisville, Kentucky and Sellersburg, Indiana; (11) Republic's acquisition of hauling and disposal assets in Macon, Georgia; and (12) Republic's acquisition of hauling assets in Monmouth, Burlington and Camden counties, New Jersey. endstream endobj 2333 0 obj<>/W[1 1 1]/Type/XRef/Index[246 2074]>>stream 26. "Memphis, TN area" means Shelby County, Tennessee; Desoto County, Mississippi, and Crittenden County, Arkansas. /Type /Page /Annots [] Noncompete Agreements: Protecting Referral Relationships as Legitimate Business Interests, Hiring for Florida Banks and Credit Unions: A Summary of Background Checks and Other Information Required to Comply With Various Regulatory Schemes. << Roll-off waste compactors are generally located at the site of the roll-off container, thereby permitting the customer to increase the container's on-site storage capacity. << /MediaBox [0 0 612 792] /Annots [] >> >> /Type /Pages The significant share of the roll-off collection market which Republic would have, its control of the primary disposal sites in the area, and its frequent use of long-term, automatically renewing contracts with roll-off collection customers, would make entry into the Macon, GA roll-off waste collection market difficult, and unlikely to prevent market incumbents from significantly raising prices for the collection of roll-off waste following the acquisition. /Parent 14 0 R << Does the injunction provide broad or limited relief? /Annots [] D. Entry Into Commercial Waste Collection of MSW. /Count 10 68 0 obj 44. The Anderson, IN and New York City, NY areas are therefore sections of the country, or relevant geographic markets, for purposes of analyzing the competitive effects of the acquisition under Section 7 of the Clayton Act. /Parent 4 0 R 2322 0 obj<>stream 4. /Annots [] DECLARATORY AND INJUNCTIVE RELIEF* * Pursuant to Rule 15(a)(2), Florida files the Second Amended Complaint with the written consent of Defendants. "MSW" means municipal solid waste, a term of art used to describe solid putrescible waste generated by households and commercial establishments such as retail stores, offices, restaurants, warehouses, and non-manufacturing activities in industrial facilities. 6. endobj endobj /Nums [0 6 0 R] /Rotate 0 did not involve a claim for declaratory relief. >> << /Filter /FlateDecode endobj ( /CropBox [0 0 612 792] /Resources 229 0 R ;("(;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;; This is an action for injunctive and declaratory relief, costs, damages, attorney's fees, penalties, and other available statutory relief, pursuant to the Florida Deceptive and Unfair . /Resources 153 0 R 18. /Contents [122 0 R 123 0 R 124 0 R] << 7. >> /Resources 209 0 R Complaint for Injunctive Relief . /Kids [7 0 R 8 0 R 9 0 R 10 0 R 11 0 R 12 0 R 13 0 R 14 0 R] /CropBox [0 0 612 792] trailer /MediaBox [0 0 612 792] endstream << 67 0 obj /Resources 381 0 R This Court has the authority to grant the requested declaratory and injunctive relief pursuant to 28 U.S.C. << << /Annots [] Omega SA v. The Individuals, Business Entities, and Unincorporated endobj /Contents [294 0 R 295 0 R 296 0 R] Complaint for Injunctive Relief | ATR | Department of Justice &%e2#4DqB#K.tt.GYeMbN!uiW-C`oIynF,fD5c&a8|A!y%?ci6Ywo`aPT=Yz0Id The HHI increases both as the number of firms in the market decreases and as the disparity in size between those firms increases. << /MediaBox [0 0 612 792] /Rotate 0 ( /CropBox [0 0 612 792] provide relief to all the individuals affected by APD's action. Temporary Injunction - Florida Litigation Guide #%$""!&+7/&)4)! 5 0 obj /CropBox [0 0 612 792] This form is a Complaint for Injunctive Relief and Damages. 2320 14 >> /CropBox [0 0 612 792] << /Annots [] PDF Complaint for Permanent Injunction, Monetary Relief, and Other Relief ( /Contents [306 0 R 307 0 R 308 0 R] >> /Annots [] /MediaBox [0 0 612 792] That defendants' proposed sales of hauling assets in the Albany, NY; Augusta, GA; Burlington and Camden Counties, NJ; Clarksville, TN; Columbus, OH; Gulf Coast, FL; Lakeland, FL; Louisville, KY/Sellersburg, IN; Macon, GA; Memphis, TN; Monmouth County, NJ; Nashville, TN and Norfolk, VA area markets, and defendants' proposed sales of MSW disposal assets in the Anderson, IN; Macon, GA and New York City, NY area markets be adjudged and decreed to be unlawful and in violation of Section 7 of the Clayton Act; 2.

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