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. << /Annots [] 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. endobj << . /Contents [206 0 R 207 0 R 208 0 R] Annotations: Subsection (b) of the rule extends the Small Claims Rules to all claims for money or property, even when expressed or coupled with a claim for equitable relief. In its 1998 fiscal year, Republic reported total revenues of approximately $1.8 billion. >> endobj 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. /Rotate 0 7. << endobj /Rotate 0 /Type /Page /Contents [154 0 R 155 0 R 156 0 R] This action is filed by the United States of America under Section 15 of the Clayton Act, 15 U.S.C. /Contents [262 0 R 263 0 R 264 0 R] 23. 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. 15. /Parent 8 0 R 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. /Annots [] /Resources 381 0 R /Parent 12 0 R << >>
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endobj /Annots [] /CropBox [0 0 612 792] /CropBox [0 0 612 792] /Contents [266 0 R 267 0 R 268 0 R] /CropBox [0 0 612 792] Republic is a Delaware corporation with its principal office in Ft. Lauderdale, Florida. /Contents [130 0 R 131 0 R 132 0 R] After the acquisition, Allied would control over 40 percent--and two firms would control over 80 percent--of the small container commercial waste hauling market, which has annual revenues of about $8 million. 2018 to May 6, 2021. ( ;,hn
\ic6rZFi+|:GsL$KGqzed8;M+"N7i~4Dr?_1hHa:`R[B%Qm*?u9Lh=?y%x8;e$AD+xx 56. /Resources 105 0 R /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] 77 0 obj >> /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. /Rotate 0 4. x+ |
Access to competitive disposal sites and reasonable disposal costs are important to providers of roll-off collection services. /Type /Page >> Plaintiff seeks temporary, preliminary, and permanent injunctive relief pursuant to Rule 65 . >> /MediaBox [0 0 612 792] 62 0 obj /Annots [] 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. /Annots [] 4 0 obj 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). /Parent 13 0 R 10 0 obj 0000002929 00000 n
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Local roll-off waste collection firms in the Macon, GA area can profitably increase charges to local customers without losing significant sales to more distant competitors. /Parent 4 0 R /MediaBox [0 0 612 792] /Type /Page << endobj >> In each of these markets, Allied and Republic each account for a substantial share of total revenues from commercial waste collection services. 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. 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. << endobj /CropBox [0 0 612 792] << 0000001852 00000 n
/Type /Page On September 8, 2021, the Court, by consent, entered a preliminary injunction against Garcia. The operator continues along the route, collecting MSW from each of the commercial accounts until the vehicle is full. After the acquisition, Republic would control over 85 percent of the small container commercial waste hauling market, which has annual revenues of about $5 million. Significant new entry into the disposal of MSW in the Anderson, IN and New York City, NY areas would be difficult and time-consuming. /MediaBox [0 0 612 792] To handle this high volume of MSW efficiently, haulers provide commercial customers with small dumpsters for storing the waste. /Resources 361 0 R >> endobj This Court has the authority to grant the requested declaratory and injunctive relief pursuant to 28 U.S.C. Local public opposition often makes it more difficult and costly, and increases the time and uncertainty of successfully permitting a facility. /Rotate 0 endobj /Contents [294 0 R 295 0 R 296 0 R] /Type /Pages 37 0 obj /MediaBox [0 0 612 792] /Resources 125 0 R Judgment for Permanent Injunctive Relief against MJ Taxes on October 1, 2021. 20. 89 0 obj 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. /MediaBox [0 0 612 792] /Contents [298 0 R 299 0 R 300 0 R] 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? >> endobj /Rotate 0 /Parent 13 0 R /Type /Page /Parent 8 0 R ( /Resources 285 0 R /CropBox [0 0 612 792] 0000003868 00000 n
Permit restrictions often impose severe limitations on the type and amount of waste that can be disposed of at landfills. /Rotate 0 /Kids [75 0 R 76 0 R 77 0 R 78 0 R 79 0 R 80 0 R 81 0 R 82 0 R 83 0 R 84 0 R] 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. /Parent 8 0 R endobj /Parent 12 0 R endobj /Type /Page Section 13(b) of the FTC Act, 15 U.S.C. /CropBox [0 0 612 792] In the Anderson, IN area, almost all of the MSW generated is disposed of in one of three transfer stations. /Contents [270 0 R 271 0 R 272 0 R] <<21a9e19eaa9d774d8bfb9315a3d3f5db>]>>
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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. /CropBox [0 0 612 792] >> As such, following the process to the tee will help improve your chances for success. /Parent 14 0 R 21-81099-CIV-CANNON/Reinhart . << 22 and 28 U.S.C. /Type /Page /Type /Page /Annots [] 15 0 obj 6 0 obj >> >> /Annots [] /MediaBox [0 0 612 792] /Count 10 Allied and Republic directly compete in the disposal of waste in a number of markets nationwide, including the Anderson, IN; New York City, NY; and Macon, Georgia areas. /Resources 197 0 R /Annots [] After the acquisition, Allied would control roughly 69 percent--and two firms over 90 percent--of the small container commercial waste hauling market, which has annual revenues exceeding $25 million. /MediaBox [0 0 612 792] That plaintiff recover the costs of this action. /CropBox [0 0 612 792] 23 0 obj DECLARATORY AND INJUNCTIVE RELIEF* * Pursuant to Rule 15(a)(2), Florida files the Second Amended Complaint with the written consent of Defendants. /MediaBox [0 0 612 792] /CropBox [0 0 612 792] /Parent 9 0 R /Type /Page 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. /Parent 13 0 R << /Resources 97 0 R endobj /MediaBox [0 0 612 792] endstream
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/Rotate 0 ( /Rotate 0 Should you request a temporary injunction or push quickly for final permanent injunction. Allied and Republic are two of only a few providers of waste collection or disposal services in each of the identified areas. >> /Type /Page /Type /Page endobj /CropBox [0 0 612 792] /Rotate 0 endobj /Contents [122 0 R 123 0 R 124 0 R] endobj /Annots [] 88 0 obj<>stream
/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] /Annots [] >> 22 0 obj Copyright 2008-2023 Jimerson Birr, P.A. 53(b), empowers this Court to grant injunctive and such other relief as the Court may deem appropriate to halt 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). 42 0 obj /Type /Page 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. /Type /Page 18. /Parent 11 0 R /Contents [326 0 R 327 0 R 328 0 R] >> Anyone who fails to dispose of MSW in an approved facility can be subject to severe civil and criminal penalties. 49 0 obj ( /Type /Page << /Resources 345 0 R << See also Chapter 224.08, Special Acts of Florida, 1943. 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. /Parent 4 0 R 48. /CropBox [0 0 612 792] /Contents [254 0 R 255 0 R 256 0 R] /Parent 14 0 R /CropBox [0 0 612 792] ( /Parent 11 0 R /Count 10 0000002992 00000 n
/CropBox [0 0 612 792] /Contents [198 0 R 199 0 R 200 0 R] Suing for an injunction in Florida is all about preserving the status quo. /Rotate 0 /Resources 133 0 R /Resources 377 0 R Does the courts have ability to enforce what you are requesting? The transactions likely will have the following effects, among others: 1. /Type /Page Contains legal complaint for injunctive releif and civil penalties against BCX facility Site, Jacksonville, Duval County, Florida, June 7, 2004. endobj /Annots [] 52. >> /Parent 12 0 R /Rotate 0 %PDF-1.3
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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. /Type /Page /MediaBox [0 0 612 792] endobj 52 0 obj 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] << That plaintiff receive such other and further relief as the case requires and the Court deems proper; and. endobj 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. 57. endstream
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endobj /Parent 11 0 R In such instances, the waste is brought to a nearby transfer station where it is compacted and combined with other waste and then transported to a more distant permanent disposal site. /Type /Page Waiver recipients are entitled to continuation of services that they are currently receiving through the completion of the fair hearing /CropBox [0 0 612 792] /Rotate 0 /Nums [0 6 0 R] /Contents [282 0 R 283 0 R 284 0 R] endobj /Rotate 0 /Length 1411 The acquisition would reduce from three to two the number of significant firms that compete in the collection of small container commercial waste in the Burlington and Camden Counties, NJ area. 0000001149 00000 n
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/Parent 13 0 R /Rotate 0 /Contents [278 0 R 279 0 R 280 0 R] >> 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. C. Reduction in Competition As a Consequence of the Acquisition. %&'()*456789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz w !1AQaq"2B #3Rbr IV. << >> 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 ( 0000001275 00000 n
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. /Annots [] Security Personnel as Independent Contractors Part I: What Makes an Individual an Independent Contractor Instead of an Employee? 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. 2320 14
Private waste haulers typically contract directly with customers for the collection of waste generated by commercial accounts. /Type /Page << /Type /Page /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] endobj /Annots [] An official website of the United States government. 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. >> _l {:\! /MediaBox [0 0 612 792] "0A149;>>>%.DIC; C 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. /Rotate 0 8. trailer
/Contents [234 0 R 235 0 R 236 0 R] 3. << << endobj There are immediate expenditures necessary. /Contents [182 0 R 183 0 R 184 0 R] /Rotate 0 >> /Type /Page /Parent 13 0 R /MediaBox [0 0 612 792] endobj 56 0 obj /Type /Page /Rotate 0 endobj /Type /Page Venue is therefore proper in this district under Section 12 of the Clayton Act, 15 U.S.C. /CropBox [0 0 612 792] 22408. << /Parent 14 0 R 26. /Contents [250 0 R 251 0 R 252 0 R] /Rotate 0 /MediaBox [0 0 612 792] /Resources 317 0 R << /Type /Pages /Rotate 0 /CropBox [0 0 612 792] /CropBox [0 0 612 792] /Contents [290 0 R 291 0 R 292 0 R] /MediaBox [0 0 612 792] 34 0 obj << /MediaBox [0 0 612 792] /Type /Page /CropBox [0 0 612 792] /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. >> >> >> << /Contents [142 0 R 143 0 R 144 0 R] 36. << /CropBox [0 0 612 792] 72 0 obj 54 0 obj 30 0 obj
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/Resources 221 0 R The cost of transporting waste to a disposal site is often a substantial component of the cost of disposal. /Count 10 /CropBox [0 0 612 792] /ModDate (D:20220824143048-04'00') /MediaBox [0 0 612 792] Parties 13. endobj 0
/CropBox [0 0 612 792] /MediaBox [0 0 612 792] 19. /Contents [334 0 R 335 0 R 336 0 R] /Contents [386 0 R 387 0 R 388 0 R] /Contents [126 0 R 127 0 R 128 0 R] 69 0 obj 71 0 obj endobj /Contents [390 0 R 391 0 R 392 0 R] JURISDICTION AND VENUE 2. /Type /Page endobj >> 54. /Contents [366 0 R 367 0 R 368 0 R] /Annots [] >> /Resources 253 0 R 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. << << /Contents [94 0 R 95 0 R 96 0 R] ( This form is a Complaint for Injunctive Relief and Damages. These differences mean that small container commercial waste collection firms can profitably increase their charges for small container commercial waste collection services without losing significant sales or revenues to firms engaged in the provision of other types of waste collection services. /Contents [350 0 R 351 0 R 352 0 R] Obtaining a permit to construct a new disposal facility or to expand an existing one is a costly and time-consuming process, which typically takes many years to conclude. /Resources 165 0 R 1114 Trademark Infringement . "HHI" means the Herfindahl-Hirschman Index, a commonly accepted measure of market concentration. /Parent 10 0 R /Parent 14 0 R 33 0 obj 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 M`5`i`F{qZ stream
/Rotate 0 Roll-off vehicles have no compaction system on board and are designed to carry only one large container at a time to a disposal site. trailer
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/Type /Page 41. /CropBox [0 0 612 792] /Annots [] /Type /Metadata In these markets, Allied and Republic each account for a substantial share of MSW disposal capacity. 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. /Rotate 0 /Annots [] 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. It is calculated by squaring the market share of each firm competing in the market and then summing the resulting numbers. /Parent 9 0 R After the acquisition, Allied would control over 50 percent--and two firms over 90 percent--of the small container commercial waste hauling market, which has annual revenues of about $31 million. /CropBox [0 0 612 792] 59. /CropBox [0 0 612 792] 2 0 obj /Contents [242 0 R 243 0 R 244 0 R] << 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. /Parent 7 0 R /Resources 185 0 R - All Rights Reserved, Community Advocacy & Social Responsibility, Traditional Contract Principles Impacting Enforcement of Noncompete Agreements in Florida. /Type /Page "Anderson, IN area" means the City of Anderson and Madison County, Indiana. /Contents [162 0 R 163 0 R 164 0 R] .t. 12102(1)-(2), the regulations implementing the . /Resources 309 0 R >> endobj 58 0 obj There may be disclosure of confidential information such as trade secrets. &%e2#4DqB#K.tt.GYeMbN!uiW-C`oIynF,fD5c&a8|A!y%?ci6Ywo`aPT=Yz0Id /CropBox [0 0 612 792] /Rotate 0 /Annots [] 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. ( 31 0 obj /CropBox [0 0 612 792] endobj 93 0 obj 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. An MSW disposal facility must be located on approved types of land and operated under prescribed procedures. /CropBox [0 0 612 792] << 64. ( This action is brought to Haulers organize their commercial accounts into routes, and collect and transport the MSW generated by these accounts in vehicles uniquely well suited for small container waste collection -- primarily front-end loader ("FEL") trucks. 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. hbbd``b`@q=`v0012,I00"0
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/MediaBox [0 0 612 792] /CropBox [0 0 612 792] << Therefore, its important to not consider it a tool for righting a wrong. /Resources 257 0 R endobj 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.
/Rotate 0 /Parent 12 0 R /Annots [] << Rule 1.610 of the Florida Rules of Civil Procedure governs requests for temporary injunctions. 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. /Parent 4 0 R /Resources 181 0 R 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. << ( In 1999, Allied reported total revenues of approximately $6 billion. >> In addition to differences in container size, other factors distinguish roll-off waste collection from small container commercial and other types of waste collection. /CropBox [0 0 612 792] /CropBox [0 0 612 792] /Type /Page endobj 60. /Resources 193 0 R In contrast to a commercial collection route, a residential waste collection route is significantly more labor intensive. >> >> endobj /Rotate 0 /Resources 177 0 R endobj /Rotate 0 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. 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. /Parent 8 0 R /Resources 161 0 R >> Republic would thus be in a position to raise the disposal costs at the landfill and transfer stations which it would own to any new or existing roll-off collection competitor in the Macon, GA area. /CropBox [0 0 612 792] %PDF-1.3
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/Contents [286 0 R 287 0 R 288 0 R] In 1998, for example, these three transfer stations disposed of over 85 percent of the MSW generated in the Anderson, IN area. >> /Contents [106 0 R 107 0 R 108 0 R] Does the injunction provide broad or limited relief? >> /Contents [102 0 R 103 0 R 104 0 R] 4 0 obj
/Type /Page /MediaBox [0 0 612 792] the Florida Deceptive and Unfair Trade Practices Act, Chapter 501, Part II, Florida Statutes ("FDUTPA"), which authorizes the State of Florida to seek, and the Court to order, permanent injunctive relief, recission or reformation of contracts, consumer restitution, the refund of monies 53(b), to secure preliminary and permanent injunctive relief, rescission of contracts, restitution, disgorgement, and other . "Clarksville, TN area" means the City of Clarksville and Montgomery, Dickson, the northwestern part of Cheatham, and the western part of Robertson counties, Tennessee. EOs6~W\F3[_y7~r+W3nU>9YRpM/u"%1yK Ivp, Microsoft Word - 2022-08-24 - Complaint - FINAL. /Resources 277 0 R /CropBox [0 0 612 792] 83 0 obj 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. .+p>hPhb4yiK=c`/XOv@|fe`iY
/Parent 11 0 R 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. 47. 27. /MediaBox [0 0 612 792] /CropBox [0 0 612 792] /Type /Page Secure .gov websites use HTTPS 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. PLAINTIFF'S COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF . /Rotate 0 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. provide relief to all the individuals affected by APD's action. did not involve a claim for declaratory relief. 38. 12. 0000001317 00000 n
58. This document is available in two formats: this web page (for browsing content) and. >> 12. /Contents [398 0 R 399 0 R 400 0 R] 47 0 obj << endobj /Annots [] endobj >> The acquisitions by Allied and Republic would remove a significant competitor in small container commercial waste collection service, roll-off waste collection service, and/or the disposal of MSW, in already highly concentrated and difficult-to-enter markets. Is there any vagueness, or is everything extremely clear? Garcia controll ed the MJ Companies prior to their going into receivership. endobj /Contents [394 0 R 395 0 R 396 0 R] There could be a negative impact on the plaintiffs public image. 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. Florida has reported 149 confirmed cases of COVID-19 and four deaths to date, with every expectation that these numbers will rise. xYYoH~7"b` recB$hHjRbK6DQ]]WUMb8`}^^l,q8x1O,7~`[)gD,uq+sU+PP)>f90VY-^AEKS2t}g4 X!xH rTmvF4(,W`{kF$tC endobj /Resources 201 0 R /MediaBox [0 0 612 792] ( 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. <>>>
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