endobj Complaint for Injunctive Relief . 78 0 obj 0000001641 00000 n << /Type /Page << That defendants be permanently enjoined from carrying out the acquisitions of those assets in the separate purchase agreements dated July 28 and October 7, 1999, or from entering into or carrying out any agreement, understanding or plan, the effect of which would be to exchange those assets between the defendants; 3. /Rotate 0 endobj /Rotate 0 judgment, and preliminary and permanent injunctive relief and damages. The front-end load containers used by small container commercial collection customers cannot be serviced by roll-off trucks. /Type /Page /Rotate 0 COMPLAINT FOR INJUNCTIVE RELIEF AND SANCTIONS Plaintiff, Donald F. Walton, United States Trustee for . Entry would also be made more difficult by Republic's use of long-term, automatically renewing contracts for roll-off service. REPUBLIC SERVICES, INC., 110 S.E. 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. This is a lawsuit for declaratory and injunctive relief under 86.011, Fla. Stat. /Parent 13 0 R >> /Parent 11 0 R >> << /Parent 8 0 R /Rotate 0 /Parent 7 0 R ( >> /Contents [114 0 R 115 0 R 116 0 R] PDF Complaint for Injunctive Relief Representatives Local public opposition often makes it more difficult and costly, and increases the time and uncertainty of successfully permitting a facility. /Parent 14 0 R On February 10, 2023, the Court screened the 27 First Amended Complaint and dismissed it for failure to state a claim, with leave to amend within 28 thirty days. 75 0 obj /Count 10 /Contents [202 0 R 203 0 R 204 0 R] PDF Verified Complaint for Declaratory and Injunctive Relief 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. /Resources 189 0 R 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. /CropBox [0 0 612 792] Page 3 of 15 7. << /Rotate 0 6 0 obj 4. have exclusive jurisdiction: (a) In all actions at law cognizable by the county . "Gulf Coast, FL area" means Escambia, Santa Rosa, and Okaloosa counties, Florida. 19. /MediaBox [0 0 612 792] /Annots [] ( >> /MediaBox [0 0 612 792] /Type /Page /Contents [238 0 R 239 0 R 240 0 R] /Contents [134 0 R 135 0 R 136 0 R] /Annots [] 12. /Rotate 0 MSW is generally transported by collection trucks to landfills and transfer stations, and the availability of disposal sites close to a hauler's routes is a major element that determines a hauler's competitiveness and profitability. /Resources 145 0 R PLAINTIFF'S COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF . 2320 14 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. /Contents [106 0 R 107 0 R 108 0 R] /Resources 173 0 R _______/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. /MediaBox [0 0 612 792] /Annots [] /Type /Page 57 0 obj /Resources 141 0 R After the acquisition, Republic would control about 31 percent--and two firms over 80 percent--of the small container commercial waste hauling market, which has annual revenues exceeding $24 million. /Type /Page /Parent 8 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. /Parent 10 0 R >> After the acquisition, Republic would control about 40 percent--and three firms over 75 percent--of the small container commercial waste hauling market, which has annual revenues of about $18 million. 82 0 obj endobj This action arises under Chapter 713 and 720, Florida Statutes, and under the Fair Housing Act of 1968, as amended, 42 U.S.C. /Annots [] >> Waste collection firms, or "haulers," collect MSW from residential, commercial and industrial establishments, and transport the waste to a disposal site, such as a transfer station, sanitary landfill or incinerator, for processing and disposal. /CropBox [0 0 612 792] Judgment for Permanent Injunctive Relief against MJ Taxes on October 1, 2021. /Contents [314 0 R 315 0 R 316 0 R] Omega SA v. The Individuals, Business Entities, and Unincorporated ( Venue is therefore proper in this district under Section 12 of the Clayton Act, 15 U.S.C. %%EOF To access the presentation, visit YouTube or click play on the embedded image below. . endobj JacqmeinV /CropBox [0 0 612 792] These differences mean that roll-off waste collection firms can profitably increase their charges for roll-off waste collection services without losing significant sales or revenues to firms engaged in the provision of other types of waste collection services. /Parent 14 0 R /Type /Page 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. 31 0 obj /Type /Page /Parent 13 0 R %PDF-1.5 % /Contents [122 0 R 123 0 R 124 0 R] In their waste collection and waste disposal businesses, defendants make sales and purchases in interstate commerce, ship waste in the flow of interstate commerce, and engage in activities substantially affecting interstate commerce. endobj /Annots [] /CropBox [0 0 612 792] /MediaBox [0 0 612 792] /CropBox [0 0 612 792] 18. 43. /Length 1411 /Parent 9 0 R /Contents [198 0 R 199 0 R 200 0 R] 50 0 obj On July 28 and October 7, 1999, in twelve (12) separate purchase agreements, defendants agreed to exchange assets of various subsidiary companies ('the acquisitions"). 53(b), empowers this Court to grant injunctive and such other relief as the Court may deem appropriate to halt >> CASE NO. 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. 49. 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. /CropBox [0 0 612 792] Although, where available, MSW can be transported to distant landfills through transfer stations using large transfer trailer trucks, the use of transfer stations adds fixed transportation and processing costs. /Rotate 0 /CropBox [0 0 612 792] "Lakeland, FL area" means Polk County, Florida. Deciding Whether to Sue for Injunction, and What is the Process to Haulers, therefore, generally establish garages and related facilities within each major local area served. /Annots [] /MediaBox [0 0 612 792] endstream /Parent 12 0 R /Resources 265 0 R 83.40 et seq. 39 0 obj Firms that compete in the disposal of MSW can profitably increase their charges to haulers of MSW without losing significant sales to any other firms. /MediaBox [0 0 612 792] /Annots [] endobj /Rotate 0 endobj Private waste haulers typically contract directly with customers for the collection of waste generated by commercial accounts. /Annots [] "Columbus, OH area" means the City of Columbus and Franklin and Delaware counties, Ohio. Alexdex. /CropBox [0 0 612 792] 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. In 1998, for example, these three transfer stations disposed of over 85 percent of the MSW generated in the Anderson, IN area. /CropBox [0 0 612 792] xref >> /Annots [] 26 0 obj endobj /Parent 7 0 R endobj /Count 10 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; /Rotate 0 27 0 obj << << /Type /Page /Resources 101 0 R endobj /Parent 9 0 R 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. 0000002235 00000 n /Annots [] << >> 62. ( See Laws of Florida, Ch. Florida has reported 149 confirmed cases of COVID-19 and four deaths to date, with every expectation that these numbers will rise. /Rotate 0 /Resources 341 0 R << /Parent 11 0 R /CropBox [0 0 612 792] 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. 88 0 obj<>stream /Type /Page /Type /Page Filing fees $ 402.00 receipt number AFLSDC-16386893, filed by OMEGA SA.. (Attachments: #1 . /Creator (PScript5.dll Version 5.2.2) << This action is brought to 22408. << 1. JFIF C 15 0 obj The length of the presentation is 46:09. /Parent 7 0 R /CropBox [0 0 612 792] << 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. "Anderson, IN area" means the City of Anderson and Madison County, Indiana. /Annots [] 2. 0000006750 00000 n >> /Parent 9 0 R In addition, be sure you have competent, knowledgeable and experienced counsel in your corner. /Annots [] /MediaBox [0 0 612 792] >> >> /Resources 149 0 R /Annots [] Republic is engaged in providing waste collection and disposal services throughout the United States. There may be disclosure of confidential information such as trade secrets. 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 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. endobj /Parent 8 0 R 22 and 28 U.S.C. >> 2 0 obj /Rotate 0 endobj /MediaBox [0 0 612 792] /Parent 14 0 R /Type /Page /Contents [378 0 R 379 0 R 380 0 R] /Parent 10 0 R /CropBox [0 0 612 792] %&'()*456789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz w !1AQaq"2B #3Rbr << /Contents [170 0 R 171 0 R 172 0 R] >> /Type /Page This is an action for injunctive relief. /MediaBox [0 0 612 792] In each of these markets, Allied and Republic each account for a substantial share of total revenues from commercial waste collection services. Last updated on November 21, 2022. endobj ;("(;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;; 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. /Rotate 0 << 8 0 obj /Rotate 0 0 /MediaBox [0 0 612 792] 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. 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. 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. /CropBox [0 0 612 792] /Resources 97 0 R /CropBox [0 0 612 792] /Parent 11 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] << Absent injunctive relief by this Court, Defendants are likely to continue to injure consumers, reap unjust enrichment, and harm the public interest. 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. << /MediaBox [0 0 612 792] ( >> /Type /Page endobj >> Waiver recipients are entitled to continuation of services that they are currently receiving through the completion of the fair hearing /Parent 9 0 R 2 0 obj /Count 10 A party seeking an injunction under general Florida case law must demonstrate: 1) irreparable harm; 2) a clear legal right; 3) an inadequate . << /CropBox [0 0 612 792] endobj 65. /Parent 12 0 R << /Type /Pages /Type /Pages /Contents [358 0 R 359 0 R 360 0 R] /Resources 401 0 R Complaint for Injunctive Relief Case (s): U.S. v. Allied Waste Industries, Inc. and Republic Services, Inc. trailer << 8. The United States is entitled to injunctive relief under 26 U.S.C. >> ( (PC) Carroll v. Vallejo Police Department, et al., No. 1:2023cv00004 PDF Complaint for Permanent Injunction and Other Equitable Relief /Contents [342 0 R 343 0 R 344 0 R] >> . /Parent 9 0 R /CropBox [0 0 612 792] /Contents [366 0 R 367 0 R 368 0 R] /CropBox [0 0 612 792] 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. /Rotate 0 /Contents [394 0 R 395 0 R 396 0 R] /CropBox [0 0 612 792] /Author (JacqmeinV) <<21a9e19eaa9d774d8bfb9315a3d3f5db>]>> PDF Complaint for Permanent Injunction, Monetary Relief, and Other Relief /Contents [162 0 R 163 0 R 164 0 R] ( /Resources 201 0 R 1114 Trademark Infringement . << PDF COMPLAINT FOR INJUNCTIVE RELIEF - archive.org /Contents [390 0 R 391 0 R 392 0 R] Allied and Republic directly compete in roll-off waste collection service in a number of markets nationwide, including the Macon, GA area. /MediaBox [0 0 612 792] 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. /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] /Contents [374 0 R 375 0 R 376 0 R] /CropBox [0 0 612 792] hb```f`` $V30 1;oO_Ia`sF!gbl!O| ` << /Rotate 0 /Parent 8 0 R >> /Type /Pages PDF COMPLAINT FOR PERMANENT INJUNCTION - United States Department of Justice 0000000556 00000 n Roll-off waste haulers, therefore, generally establish garages and related facilities within each major local area served. Is there any vagueness, or is everything extremely clear? 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 Monmouth County, NJ area. /Contents [102 0 R 103 0 R 104 0 R] 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. /Rotate 0 /Rotate 0 /S /D /Contents [118 0 R 119 0 R 120 0 R] /CropBox [0 0 612 792] >> endobj /MediaBox [0 0 612 792] /Rotate 0 endobj /MediaBox [0 0 612 792] /Annots [] stream hear the plaintiff's claim for declaratory and injunctive relief because the plaintiff alleged an amount in controversy in excess of $15,000; which obviously, is due to the fact that . endobj /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] endobj 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. Asda Car Park Charges, Division 2 Control Points With Mounted Guns, Can Babies Eat Truffle Oil, Highway Map Of Mississippi And Alabama, Articles C
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complaint for injunctive relief florida

April 8, 2023 in recurring itch in the same spot on leg

? 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. THIS COURT'S POWER TO GRANT RELIEF 84. "Norfolk, VA area" means the cities of Chesapeake, Suffolk, Virginia Beach, Norfolk, Poquoson, Newport News and Portsmouth, and York, Surry, James City, Southampton, and Isle of Wight counties, Virginia. /Count 10 Garcia is a resident of North Lauderdale, Fl orida. 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. /Annots [] 25, to prevent and restrain the violation by defendants of Section 7 of the Clayton Act, 15 U.S.C. 25 0 obj <> endobj Complaint for Injunctive Relief . 78 0 obj 0000001641 00000 n << /Type /Page << That defendants be permanently enjoined from carrying out the acquisitions of those assets in the separate purchase agreements dated July 28 and October 7, 1999, or from entering into or carrying out any agreement, understanding or plan, the effect of which would be to exchange those assets between the defendants; 3. /Rotate 0 endobj /Rotate 0 judgment, and preliminary and permanent injunctive relief and damages. The front-end load containers used by small container commercial collection customers cannot be serviced by roll-off trucks. /Type /Page /Rotate 0 COMPLAINT FOR INJUNCTIVE RELIEF AND SANCTIONS Plaintiff, Donald F. Walton, United States Trustee for . Entry would also be made more difficult by Republic's use of long-term, automatically renewing contracts for roll-off service. REPUBLIC SERVICES, INC., 110 S.E. 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. This is a lawsuit for declaratory and injunctive relief under 86.011, Fla. Stat. /Parent 13 0 R >> /Parent 11 0 R >> << /Parent 8 0 R /Rotate 0 /Parent 7 0 R ( >> /Contents [114 0 R 115 0 R 116 0 R] PDF Complaint for Injunctive Relief Representatives Local public opposition often makes it more difficult and costly, and increases the time and uncertainty of successfully permitting a facility. /Parent 14 0 R On February 10, 2023, the Court screened the 27 First Amended Complaint and dismissed it for failure to state a claim, with leave to amend within 28 thirty days. 75 0 obj /Count 10 /Contents [202 0 R 203 0 R 204 0 R] PDF Verified Complaint for Declaratory and Injunctive Relief 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. /Resources 189 0 R 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. /CropBox [0 0 612 792] Page 3 of 15 7. << /Rotate 0 6 0 obj 4. have exclusive jurisdiction: (a) In all actions at law cognizable by the county . "Gulf Coast, FL area" means Escambia, Santa Rosa, and Okaloosa counties, Florida. 19. /MediaBox [0 0 612 792] /Annots [] ( >> /MediaBox [0 0 612 792] /Type /Page /Contents [238 0 R 239 0 R 240 0 R] /Contents [134 0 R 135 0 R 136 0 R] /Annots [] 12. /Rotate 0 MSW is generally transported by collection trucks to landfills and transfer stations, and the availability of disposal sites close to a hauler's routes is a major element that determines a hauler's competitiveness and profitability. /Resources 145 0 R PLAINTIFF'S COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF . 2320 14 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. /Contents [106 0 R 107 0 R 108 0 R] /Resources 173 0 R _______/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. /MediaBox [0 0 612 792] /Annots [] /Type /Page 57 0 obj /Resources 141 0 R After the acquisition, Republic would control about 31 percent--and two firms over 80 percent--of the small container commercial waste hauling market, which has annual revenues exceeding $24 million. /Type /Page /Parent 8 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. /Parent 10 0 R >> After the acquisition, Republic would control about 40 percent--and three firms over 75 percent--of the small container commercial waste hauling market, which has annual revenues of about $18 million. 82 0 obj endobj This action arises under Chapter 713 and 720, Florida Statutes, and under the Fair Housing Act of 1968, as amended, 42 U.S.C. /Annots [] >> Waste collection firms, or "haulers," collect MSW from residential, commercial and industrial establishments, and transport the waste to a disposal site, such as a transfer station, sanitary landfill or incinerator, for processing and disposal. /CropBox [0 0 612 792] Judgment for Permanent Injunctive Relief against MJ Taxes on October 1, 2021. /Contents [314 0 R 315 0 R 316 0 R] Omega SA v. The Individuals, Business Entities, and Unincorporated ( Venue is therefore proper in this district under Section 12 of the Clayton Act, 15 U.S.C. %%EOF To access the presentation, visit YouTube or click play on the embedded image below. . endobj JacqmeinV /CropBox [0 0 612 792] These differences mean that roll-off waste collection firms can profitably increase their charges for roll-off waste collection services without losing significant sales or revenues to firms engaged in the provision of other types of waste collection services. /Parent 14 0 R /Type /Page 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. 31 0 obj /Type /Page /Parent 13 0 R %PDF-1.5 % /Contents [122 0 R 123 0 R 124 0 R] In their waste collection and waste disposal businesses, defendants make sales and purchases in interstate commerce, ship waste in the flow of interstate commerce, and engage in activities substantially affecting interstate commerce. endobj /Annots [] /CropBox [0 0 612 792] /MediaBox [0 0 612 792] /CropBox [0 0 612 792] 18. 43. /Length 1411 /Parent 9 0 R /Contents [198 0 R 199 0 R 200 0 R] 50 0 obj On July 28 and October 7, 1999, in twelve (12) separate purchase agreements, defendants agreed to exchange assets of various subsidiary companies ('the acquisitions"). 53(b), empowers this Court to grant injunctive and such other relief as the Court may deem appropriate to halt >> CASE NO. 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. 49. 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. /CropBox [0 0 612 792] Although, where available, MSW can be transported to distant landfills through transfer stations using large transfer trailer trucks, the use of transfer stations adds fixed transportation and processing costs. /Rotate 0 /CropBox [0 0 612 792] "Lakeland, FL area" means Polk County, Florida. Deciding Whether to Sue for Injunction, and What is the Process to Haulers, therefore, generally establish garages and related facilities within each major local area served. /Annots [] /MediaBox [0 0 612 792] endstream /Parent 12 0 R /Resources 265 0 R 83.40 et seq. 39 0 obj Firms that compete in the disposal of MSW can profitably increase their charges to haulers of MSW without losing significant sales to any other firms. /MediaBox [0 0 612 792] /Annots [] endobj /Rotate 0 endobj Private waste haulers typically contract directly with customers for the collection of waste generated by commercial accounts. /Annots [] "Columbus, OH area" means the City of Columbus and Franklin and Delaware counties, Ohio. Alexdex. /CropBox [0 0 612 792] 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. In 1998, for example, these three transfer stations disposed of over 85 percent of the MSW generated in the Anderson, IN area. /CropBox [0 0 612 792] xref >> /Annots [] 26 0 obj endobj /Parent 7 0 R endobj /Count 10 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; /Rotate 0 27 0 obj << << /Type /Page /Resources 101 0 R endobj /Parent 9 0 R 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. 0000002235 00000 n /Annots [] << >> 62. ( See Laws of Florida, Ch. Florida has reported 149 confirmed cases of COVID-19 and four deaths to date, with every expectation that these numbers will rise. /Rotate 0 /Resources 341 0 R << /Parent 11 0 R /CropBox [0 0 612 792] 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. 88 0 obj<>stream /Type /Page /Type /Page Filing fees $ 402.00 receipt number AFLSDC-16386893, filed by OMEGA SA.. (Attachments: #1 . /Creator (PScript5.dll Version 5.2.2) << This action is brought to 22408. << 1. JFIF C 15 0 obj The length of the presentation is 46:09. /Parent 7 0 R /CropBox [0 0 612 792] << 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. "Anderson, IN area" means the City of Anderson and Madison County, Indiana. /Annots [] 2. 0000006750 00000 n >> /Parent 9 0 R In addition, be sure you have competent, knowledgeable and experienced counsel in your corner. /Annots [] /MediaBox [0 0 612 792] >> >> /Resources 149 0 R /Annots [] Republic is engaged in providing waste collection and disposal services throughout the United States. There may be disclosure of confidential information such as trade secrets. 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 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. endobj /Parent 8 0 R 22 and 28 U.S.C. >> 2 0 obj /Rotate 0 endobj /MediaBox [0 0 612 792] /Parent 14 0 R /Type /Page /Contents [378 0 R 379 0 R 380 0 R] /Parent 10 0 R /CropBox [0 0 612 792] %&'()*456789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz w !1AQaq"2B #3Rbr << /Contents [170 0 R 171 0 R 172 0 R] >> /Type /Page This is an action for injunctive relief. /MediaBox [0 0 612 792] In each of these markets, Allied and Republic each account for a substantial share of total revenues from commercial waste collection services. Last updated on November 21, 2022. endobj ;("(;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;; 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. /Rotate 0 << 8 0 obj /Rotate 0 0 /MediaBox [0 0 612 792] 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. 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. 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. /CropBox [0 0 612 792] /Resources 97 0 R /CropBox [0 0 612 792] /Parent 11 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] << Absent injunctive relief by this Court, Defendants are likely to continue to injure consumers, reap unjust enrichment, and harm the public interest. 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. << /MediaBox [0 0 612 792] ( >> /Type /Page endobj >> Waiver recipients are entitled to continuation of services that they are currently receiving through the completion of the fair hearing /Parent 9 0 R 2 0 obj /Count 10 A party seeking an injunction under general Florida case law must demonstrate: 1) irreparable harm; 2) a clear legal right; 3) an inadequate . << /CropBox [0 0 612 792] endobj 65. /Parent 12 0 R << /Type /Pages /Type /Pages /Contents [358 0 R 359 0 R 360 0 R] /Resources 401 0 R Complaint for Injunctive Relief Case (s): U.S. v. Allied Waste Industries, Inc. and Republic Services, Inc. trailer << 8. The United States is entitled to injunctive relief under 26 U.S.C. >> ( (PC) Carroll v. Vallejo Police Department, et al., No. 1:2023cv00004 PDF Complaint for Permanent Injunction and Other Equitable Relief /Contents [342 0 R 343 0 R 344 0 R] >> . /Parent 9 0 R /CropBox [0 0 612 792] /Contents [366 0 R 367 0 R 368 0 R] /CropBox [0 0 612 792] 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. /Rotate 0 /Contents [394 0 R 395 0 R 396 0 R] /CropBox [0 0 612 792] /Author (JacqmeinV) <<21a9e19eaa9d774d8bfb9315a3d3f5db>]>> PDF Complaint for Permanent Injunction, Monetary Relief, and Other Relief /Contents [162 0 R 163 0 R 164 0 R] ( /Resources 201 0 R 1114 Trademark Infringement . << PDF COMPLAINT FOR INJUNCTIVE RELIEF - archive.org /Contents [390 0 R 391 0 R 392 0 R] Allied and Republic directly compete in roll-off waste collection service in a number of markets nationwide, including the Macon, GA area. /MediaBox [0 0 612 792] 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. /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] /Contents [374 0 R 375 0 R 376 0 R] /CropBox [0 0 612 792] hb```f`` $V30 1;oO_Ia`sF!gbl!O| ` << /Rotate 0 /Parent 8 0 R >> /Type /Pages PDF COMPLAINT FOR PERMANENT INJUNCTION - United States Department of Justice 0000000556 00000 n Roll-off waste haulers, therefore, generally establish garages and related facilities within each major local area served. Is there any vagueness, or is everything extremely clear? 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 Monmouth County, NJ area. /Contents [102 0 R 103 0 R 104 0 R] 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. /Rotate 0 /Rotate 0 /S /D /Contents [118 0 R 119 0 R 120 0 R] /CropBox [0 0 612 792] >> endobj /MediaBox [0 0 612 792] /Rotate 0 endobj /MediaBox [0 0 612 792] /Annots [] stream hear the plaintiff's claim for declaratory and injunctive relief because the plaintiff alleged an amount in controversy in excess of $15,000; which obviously, is due to the fact that . endobj /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] endobj 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.

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complaint for injunctive relief florida