19 0 obj /Author (JacqmeinV) >> /MediaBox [0 0 612 792] The roll-off container, when filled, is picked up by roll-off trucks, which are uniquely well suited for roll-off waste collection, and driven to a nearby disposal site, where the container's contents are disposed. /Rotate 0 << /CropBox [0 0 612 792] The proposed acquisition would reduce from three to two the number of significant competitors for the disposal of MSW in the Anderson, IN area. /Parent 14 0 R << /MediaBox [0 0 612 792] /Parent 14 0 R Preference Primary election in Florida. "HHI" means the Herfindahl-Hirschman Index, a commonly accepted measure of market concentration. /Annots [] 18 0 obj This action is brought to 41. /MediaBox [0 0 612 792] This is an action for injunctive relief. 27. /Parent 7 0 R /Parent 9 0 R /MediaBox [0 0 612 792] JURISDICTION AND VENUE 1. In the Albany, NY area, the proposed acquisition would reduce from four to three the number of significant competitors in the collection of small container commercial waste. /Type /Page /Resources 229 0 R endobj ( /Contents [286 0 R 287 0 R 288 0 R] 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. /Contents [338 0 R 339 0 R 340 0 R] %&'()*456789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz w !1AQaq"2B #3Rbr >> Plaintiffs Rural & Migrant Ministry, Alianza Nacional De Campesinas, El Comite . After the acquisition, Republic would own two of the three transfer stations, which together would control in excess of 65 percent of the MSW disposal market, which has annual revenues in excess of $3 million. /CropBox [0 0 612 792] << not /Parent 14 0 R /Annots [] 17 0 obj /Contents [194 0 R 195 0 R 196 0 R] /Contents [322 0 R 323 0 R 324 0 R] MSW landfills can only accept waste up to their permitted daily capacity and have a finite life span. << 14. >> 4. /MediaBox [0 0 612 792] >>
Complaint for Injunctive Relief | ATR | Department of Justice /Resources 277 0 R ( startxref
/Rotate 0 >> Last updated on November 21, 2022. /S /D /Parent 10 0 R In the Clarksville, TN area, the acquisition would reduce from five to four the number of significant firms competing in the collection of small container commercial waste. /Count 10 /Annots [] 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. 38. >> endobj /Rotate 0 endobj << The length of the presentation is 46:09. /CropBox [0 0 612 792] /Type /Page 0000000879 00000 n
/Contents [174 0 R 175 0 R 176 0 R] 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 $28 million. /Parent 10 0 R /Annots []
PDF In the Supreme Court of Florida Case No.: Sc11- Third District Case No << ( /Parent 12 0 R ( 2 0 obj /CropBox [0 0 612 792] /Annots [] In re Amendments to Florida Small Claims Rules, 123 So.3d 41 (Fla . 21 0 obj Charles B. Jimerson /Type /Page /Parent 11 0 R /Type /Page
PDF Complaint for Injunctive and Other Equitable Relief 0000003135 00000 n
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(PC) Carroll v. Vallejo Police Department, et al., No. 1:2023cv00004 for the Middle Distrct of Florida, hereby files this complaint for permanent injunction and alleges as follows: 1. << /Rotate 0 >> /CropBox [0 0 612 792] Plaintiff, PRISON LEGAL NEWS ("PLN"), a project of the Human Rights Defense . Is there any vagueness, or is everything extremely clear? Therefore, you should ask yourself these questions before proceeding: So, you answered the questions above, and you consider this to be the best approach to resolving your matter. /MediaBox [0 0 612 792] ;,hn
\ic6rZFi+|:GsL$KGqzed8;M+"N7i~4Dr?_1hHa:`R[B%Qm*?u9Lh=?y%x8;e$AD+xx /Parent 9 0 R /MediaBox [0 0 612 792] /CropBox [0 0 612 792] $4%&'()*56789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz r! /Parent 13 0 R Thus, roll-off waste collection service is a line of commerce, or relevant service, for purposes of analyzing the effects of the acquisitions under Section 7 of the Clayton Act. Garcia controll ed the MJ Companies prior to their going into receivership. The next step is careful preparation before the temporary injunction hearing. /Parent 9 0 R /MediaBox [0 0 612 792] Garcia is a resident of North Lauderdale, Fl orida. /Rotate 0 Small container commercial waste collection differs in many important respects from the collection of residential or other types of waste. ( Injunctive relief is considered an extraordinary remedy in both State and Federal court. 66. 0000000016 00000 n
/Rotate 0 >> /Rotate 0 Universities have sent students home, people are remaining in quarantine, poll workers are dropping out, and Supervisors of Elections have closed or moved 112 polling places in 22 counties, in many cases less than a week before the election. Contains legal complaint for injunctive releif and civil penalties against BCX facility Site, Jacksonville, Duval County, Florida, June 7, 2004. 35. 12102(1)-(2), the regulations implementing the . /MediaBox [0 0 612 792] clearly appears from specific facts shown by affidavit or by verified complaint that immediate or >> Small Container Commercial Waste Collection Service. 32. Suing for an injunction in Florida is all about preserving the status quo. /Resources 357 0 R /Resources 109 0 R /Rotate 0 >> 2. 49 0 obj Complaint for Injunctive Relief . The proposed acquisition would reduce from four to three the number of significant firms that compete in small container commercial waste collection service in the Memphis, TN area. /Annots [] /MediaBox [0 0 612 792] 3. Due to the high costs of transporting MSW, and the substantial travel time to other disposal facilities based on distance, natural barriers, and congested roadways, haulers of MSW from the Anderson, IN and New York City, NY areas, respectively, are limited to transfer station disposal sites located in each of their local areas. /MediaBox [0 0 612 792]
PDF COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF - NSB Anglers Yacht ( Very often courts do not grant injunctions if there is not a lot of specificity and practicality in the request for an injunction. /Metadata 2 0 R 30. 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. endobj <>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>>
PDF COMPLAINT FOR INJUNCTIVE RELIEF AND SANCTIONS PARTIES - The Wall Street /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] endobj << endobj /Annots [] /Type /Pages 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. /Annots [] >>
PDF Complaint for Permanent Injunction, Monetary Relief, and Other Relief <>
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K,cMpl q m D@,"R:7S&`u@6j(LjfLT[D1,BPf:9= P1!$Ippa8fHNtD {,nPY 5 SOUTHERN DISTRICT OF FLORIDA . "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. /CropBox [0 0 612 792] %PDF-1.4
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On July 28 and October 7, 1999, in twelve (12) separate purchase agreements, defendants agreed to exchange assets of various subsidiary companies ('the acquisitions"). /Type /Page Pursuant to the purchase agreements, Allied would acquire from Superior: hauling assets in Albany, New York; hauling assets in Augusta, Georgia; hauling assets in Memphis, Nashville and Clarksville, Tennessee; disposal assets in New York, New York; hauling assets in Norfolk, Virginia; and hauling assets in Okaloosa, Escambia and Santa Rosa counties, Florida. %PDF-1.5
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endobj 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. 46 0 obj /Rotate 0 >> 0
48 0 obj /CropBox [0 0 612 792] /Contents [154 0 R 155 0 R 156 0 R] Z( >> /Parent 12 0 R /Contents [330 0 R 331 0 R 332 0 R]
PDF Complaint for Injunctive Relief Representatives 6 0 obj /Annots [] >> 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. endobj 3601, et seq.
In the United States District Court for The Southern District of New York The differences in size, type, and volumes of roll-off waste and the equipment used to collect it distinguish roll-off waste collection from all other waste collection services. 13. There could be a negative impact on the plaintiffs public image. /MediaBox [0 0 612 792] Complaint for Declaratory and Temporary and Permanent Injunctive Relief (the "Complaint"), which is incorporated herein by this reference.1 As shown in the Complaint, the HRO is null and void for failure to comply with Florida Statutes, the Jacksonville Ordinance Code, and the Rules of the Council of the City of Jacksonville. In such areas, many of the problems associated with the permitting and construction of a landfill could make it difficult to permit and construct a transfer station. /Annots [] /Resources 313 0 R That plaintiff recover the costs of this action.
/Parent 14 0 R /Type /Page >> /CropBox [0 0 612 792] /Annots [] /Parent 10 0 R >> Typical commercial waste collection customers include office and apartment buildings and retail establishments (e.g. /Contents [258 0 R 259 0 R 260 0 R] >> /CropBox [0 0 612 792] /Contents [106 0 R 107 0 R 108 0 R] 0000001641 00000 n
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. 58 0 obj >> /Rotate 0 Venue is therefore proper in this district under Section 12 of the Clayton Act, 15 U.S.C. /Annots [] 76 13
/MediaBox [0 0 612 792] 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. /Annots [] /MediaBox [0 0 612 792] /Contents [166 0 R 167 0 R 168 0 R] 79 0 obj A .gov website belongs to an official government organization in the United States. 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. "Columbus, OH area" means the City of Columbus and Franklin and Delaware counties, Ohio. /Annots [] /Annots [] 6. /Type /Page ? The United States of America, acting under the direction of the Attorney General of the United States, brings this civil antitrust action to enjoin the acquisition of certain waste hauling and disposal assets by Defendants Allied Waste Industries, Inc. ("Allied") and Republic Services, Inc. ("Republic") and to obtain equitable relief and other relief as appropriate. << >> /Kids [55 0 R 56 0 R 57 0 R 58 0 R 59 0 R 60 0 R 61 0 R 62 0 R 63 0 R 64 0 R] The global coronavirus pandemic threatens to disrupt the Presidential Preference Primary (PPP) election in Florida, scheduled for tomorrow, March 17, 2020, and cause large-scale voter disenfranchisement falling hardest on communities of color and other historically vulnerable populations. << It is economically impractical for a roll-off waste collection firm to serve metropolitan areas from a distant base. Accordingly, injunctive relief ordering the extension of vote-by-mail options and other accommodations at polling places is necessary to protect the fundamental right to vote. This is a civil action brought by the United States of America to enjoin defendant . /Contents [218 0 R 219 0 R 220 0 R] /Type /Page /Contents [342 0 R 343 0 R 344 0 R] /Type /Page
PDF COMPLAINT FOR PERMANENT INJUNCTION - United States Department of Justice /CropBox [0 0 612 792] /Contents [386 0 R 387 0 R 388 0 R] /MediaBox [0 0 612 792] /Annots [] << /Contents [230 0 R 231 0 R 232 0 R] There may be disclosure of confidential information such as trade secrets. 61 0 obj /MediaBox [0 0 612 792] /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. /MediaBox [0 0 612 792] /Contents [150 0 R 151 0 R 152 0 R] 53(b), to secure preliminary and permanent injunctive relief, rescission of contracts, restitution, disgorgement, and other . 4. << << /Annots [] JURISDICTION AND VENUE 13. %%EOF
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.t. 5 0 obj /Contents [118 0 R 119 0 R 120 0 R] /Annots [] 6108, to obtain temporary, preliminary, and permanent injunctive relief, rescission or reformation of contracts, restitution, the refund of monies paid, disgorgement of ill-gotten . /Length 1411 86 0 obj Judgment for Permanent Injunctive Relief against MJ Taxes on October 1, 2021. ( >> >> <<
Omega SA v. The Individuals, Business Entities, and Unincorporated /CropBox [0 0 612 792] >> /Resources 341 0 R /Resources 233 0 R %%EOF
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PDF United States District Court Northern District of Florida Pensacola 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. Rather, these are some additional factors to consider while determining the feasibility of this action: Will the court be able to enforce the injunction, or will it require intensive court supervision? /Parent 9 0 R /Type /Page /Rotate 0 /Annots []
PDF Motion for Summary Judgment - Liberty Counsel Each of these areas is a section of the country, or relevant geographic market, for purposes of analyzing the effects of the acquisitions under Section 7 of the Clayton Act. /MediaBox [0 0 612 792] 9 0 obj %PDF-1.5
ASSOCIATION OF FLORIDA, MIGRANT CLINICIANS NETWORK, PINEROS Y . "Macon, GA area" means the City of Macon and Bibb, Peach and parts of Houston, Jones and Monroe counties, Georgia. Venue is proper in the Circuit Court of the Seventh Judicial Circuit, in and for /MediaBox [0 0 612 792] 10. 84 0 obj 0000003868 00000 n
/Contents [130 0 R 131 0 R 132 0 R] 46. The cost of transporting waste to a disposal site is often a substantial component of the cost of disposal. /CropBox [0 0 612 792] 45 0 obj /Count 10 did not involve a claim for declaratory relief. 26. << /Rotate 0 83.40 et seq. endobj ( 89 0 obj 52. /Resources 381 0 R /CropBox [0 0 612 792]
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. /CropBox [0 0 612 792]
Deciding Whether to Sue for Injunction, and What is the Process to /Parent 9 0 R endobj /Annots [] Filing 1 COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. /Count 10 /Contents [378 0 R 379 0 R 380 0 R] /Resources 113 0 R /Type /Page /MediaBox [0 0 612 792] This is an action for permanent injunctive relief, declaratory relief, and Therefore, the video continues on this topic by explaining: A suit for injunction is an extraordinary remedy for businesses and individuals alike. See also Chapter 224.08, Special Acts of Florida, 1943. /Annots [] /PageLabels 3 0 R /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] "Burlington and Camden Counties, NJ area" means Burlington and Camden counties, New Jersey. >> endobj /Annots [] WEST PALM BEACH DIVISION . /Rotate 0 << /Annots [] In this presentation, Jimerson Birr AssociateAustin B. Calhouncovers Florida law on injunctive relief as a remedy, the process for seeking and obtaining injunctive relief through the judicial system, pre-litigation considerations, and enforcement of an injunction order once entered. 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.