complaint for injunctive relief florida

complaint for injunctive relief florida

/Type /Page /Count 10 /Parent 13 0 R /Resources 225 0 R endobj 21. In order to obtain comparable operating efficiency, a new firm must achieve route density comparable to existing firms. /MediaBox [0 0 612 792] /Length 3282 /Annots [] 0000001994 00000 n 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. For the Court's convenience, Florida has attached a redline, as Exhibit A, showing changes from the First Amended Complaint. /Annots [] ( endobj "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. /MediaBox [0 0 612 792] /CropBox [0 0 612 792] endobj /MediaBox [0 0 612 792] 0000001641 00000 n 40 0 obj 53 0 obj /Resources 217 0 R 47 0 obj /Annots [] 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. .+p>hPhb4yiK=c`/XOv@|fe`iY /Annots [] 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. /Type /Page ("MFS"), is a Florida corporation that has a principal place of . /Parent 9 0 R While small container commercial waste collection typically involves a FEL truck making regular stops on pre-scheduled routes to empty numerous containers at multiple customer locations, roll-off waste collection is often performed on an "on-call" basis for customers whose waste is not part of any route. A party seeking an injunction under general Florida case law must demonstrate: 1) irreparable harm; 2) a clear legal right; 3) an inadequate . /MediaBox [0 0 612 792] /Rotate 0 2320 0 obj<> endobj >> /CropBox [0 0 612 792] /Contents [102 0 R 103 0 R 104 0 R] 6 0 obj /MediaBox [0 0 612 792] /Resources 197 0 R ( In the Norfolk, VA area, the acquisition would reduce from three to two the number of significant firms competing in the collection of small container commercial waste. "Memphis, TN area" means Shelby County, Tennessee; Desoto County, Mississippi, and Crittenden County, Arkansas. And yet the State of Florida (the State) has failed to take reasonable emergency measures necessary for voter participation in the face of this crisis. /Resources 101 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. /Annots [] >> 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. /MediaBox [0 0 612 792] 8 0 obj "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. The President of the United States and the Governor of Florida have each declared a state of emergency. /MediaBox [0 0 612 792] /CropBox [0 0 612 792] 26. <> /Nums [0 6 0 R] /Parent 11 0 R For a number of reasons, landfills may not be located close to where the waste is generated. /MediaBox [0 0 612 792] >> /PageLabels 3 0 R << >> construction debris) and volume, roll-off waste is deposited by the customer/generator into a disposal container (usually 20 to 40 cubic yards in size) which is larger than those routinely used in small container commercial collection (usually one to 10 cubic yards in size). 25 0 obj <> endobj 0000000016 00000 n The Court has jurisdiction over this action and over the parties pursuant to 15 U.S.C. << Copyright 2008-2023 Jimerson Birr, P.A. 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. /Annots [] /MediaBox [0 0 612 792] The Macon, GA area is a section of the country, or relevant geographic market, for purposes of analyzing the effects of the acquisitions under Section 7 of the ClaytonAct. /Parent 12 0 R /Type /Page /Resources 305 0 R There are no good substitutes for MSW disposal. /Parent 12 0 R Venue is proper in the Circuit Court of the Seventh Judicial Circuit, in and for /CropBox [0 0 612 792] /CropBox [0 0 612 792] How long will the injunction be effective? /Rotate 0 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. _______/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. << /Type /Page >> <>>> The front-end load containers used by small container commercial collection customers cannot be serviced by roll-off trucks. 77 0 obj /Annots [] << 17 0 obj 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 $28 million. /Annots [] /Contents [250 0 R 251 0 R 252 0 R] ( H*23430P AsKN$r{(s >> /Type /Page 12. 16 0 obj /CropBox [0 0 612 792] >> endobj /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] /Contents [238 0 R 239 0 R 240 0 R] /Annots [] 57. xYYoH~7"b` recB$hHjRbK6DQ]]WUMb8`}^^l,q8x1O,7~`[)gD,uq+sU+PP)>f90VY-^AEKS2t}g4 X!xH rTmvF4(,W`{kF$tC %PDF-1.3 % endobj /MediaBox [0 0 612 792] >> /MediaBox [0 0 612 792] /Parent 8 0 R /Annots [] Virtually all of the MSW generated in each of these areas is disposed of in transfer stations in each of their local areas. /Resources 121 0 R 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. judgment, and preliminary and permanent injunctive relief and damages. /CropBox [0 0 612 792] /Resources 209 0 R /CropBox [0 0 612 792] /CropBox [0 0 612 792] Unless the twelve acquisitions are enjoined, consumers of waste collection and disposal services will likely pay higher prices and receive fewer services as a consequence of the elimination of the vigorous competition between defendants Allied and Republic. ( 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. ( << 64 0 obj See also Chapter 224.08, Special Acts of Florida, 1943. SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION In re: JOSE SANCHEZ Case No. >> Official websites use .gov << >> endobj << << That plaintiff receive such other and further relief as the case requires and the Court deems proper; and. >> /Parent 13 0 R /Contents [154 0 R 155 0 R 156 0 R] /CropBox [0 0 612 792] ( /Resources 237 0 R advance, Plaintiffs seek immediate declaratory and injunctive relief that directs Defendants to permit a designated representative of each affected candidate and political party into the recount room, as Florida law requires. /CropBox [0 0 612 792] /Contents [322 0 R 323 0 R 324 0 R] endobj /Contents [226 0 R 227 0 R 228 0 R] #%$""!&+7/&)4)! 1114 Trademark Infringement . endobj This form is a Complaint for Injunctive Relief and Damages. /Parent 14 0 R 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. /Rotate 0 /Type /Page Roll-off waste collection customers typically generate bulkier items of waste and/or substantially larger volumes of waste than residential or small container commercial waste customers from sources such as construction sites or industrial plants. Plaintiffs Rural & Migrant Ministry, Alianza Nacional De Campesinas, El Comite . /Type /Page >> /Annots [] /Rotate 0 /Filter /FlateDecode /Parent 7 0 R /Annots [] << /Annots [] 0000003868 00000 n /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] There could be a negative impact on the plaintiffs public image. Is there any vagueness, or is everything extremely clear? /Parent 13 0 R /Type /Page 6. /CropBox [0 0 612 792] 6th Street Ft. Lauderdale, FL 33301 Defendants. /CropBox [0 0 612 792] /Parent 7 0 R /Rotate 0 << /Metadata 2 0 R Plaintiff, The Second Amendment Foundation, is a Washington Not-For-Profit /CropBox [0 0 612 792] /CropBox [0 0 612 792] /Annots [] >> /Type /Page Defendants Allied and Republic collect municipal solid waste from residential, commercial, and industrial customers, and they own and operate transfer stations, landfills, and incinerators, which process and dispose of municipal solid waste. 68 0 obj /MediaBox [0 0 612 792] /CropBox [0 0 612 792] /CropBox [0 0 612 792] This Court has supplemental jurisdiction over the State of Florida's state claims pursuant to COMPLAINT -3-q;;m: @ii$$1$$ &JIIJAI JKQI !.1 i&%iiM tv . /Contents [310 0 R 311 0 R 312 0 R] >> In re Amendments to Florida Small Claims Rules, 123 So.3d 41 (Fla . 81 0 obj /Annots [] ( /CropBox [0 0 612 792] /Rotate 0 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. /CropBox [0 0 612 792] << 0 %%EOF /CropBox [0 0 612 792] /Annots [] /Resources 405 0 R 10941 and Laws of Florida, Ch. >> In addition, Wilson traveled at least twice to Florida for work-related trips in 2019, including once to Miami and Tampa in or around the spring of 2019 and once to Orlando in or around November or December 2019. 12 0 obj >> /Type /Page /Contents [126 0 R 127 0 R 128 0 R] 48 0 obj /Parent 11 0 R /Contents [406 0 R 407 0 R 408 0 R] /Resources 329 0 R /Parent 7 0 R /Rotate 0 /Contents [394 0 R 395 0 R 396 0 R] 76 0 obj /MediaBox [0 0 612 792] MSW landfills can only accept waste up to their permitted daily capacity and have a finite life span. /Rotate 0 0000002235 00000 n /Type /Page >> >> 27. /Type /Page /Type /Page /Parent 10 0 R This is a lawsuit for declaratory and injunctive relief under 86.011, Fla. Stat. << /Type /Page endobj /Resources 117 0 R 4. /MediaBox [0 0 612 792] /Contents [346 0 R 347 0 R 348 0 R] /Resources 153 0 R 47. /Contents [318 0 R 319 0 R 320 0 R] The United States Army Corps of Engineers ("Corps" or "Army Corps") has unlawfully approved a massive dredging project for Port Everglades in Fort Lauderdale, Florida. /Contents [338 0 R 339 0 R 340 0 R] /Parent 14 0 R clearly appears from specific facts shown by affidavit or by verified complaint that immediate or

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