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/Resources 205 0 R >> /Contents [294 0 R 295 0 R 296 0 R] /Parent 12 0 R 35 0 obj 1 0 obj 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. (2001). Permit restrictions often impose severe limitations on the type and amount of waste that can be disposed of at landfills. 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. 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. Complaint for Injunctive Relief and Civil Penalties | US EPA <>>> /Rotate 0 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. endobj 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. 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. Complaint for Injunctive Relief Case (s): U.S. v. Allied Waste Industries, Inc. and Republic Services, Inc. WEST PALM BEACH DIVISION . 0000003135 00000 n 50. IV. 18. /CropBox [0 0 612 792] /CropBox [0 0 612 792] 43. << /Parent 7 0 R /MediaBox [0 0 612 792] << /Contents [130 0 R 131 0 R 132 0 R] >> /Annots [] 0000003645 00000 n Virtually all of the MSW generated in each of these areas is disposed of in transfer stations in each of their local areas. >> /Annots [] endobj 56. 23 0 obj <> endobj 28 0 obj <>/Filter/FlateDecode/ID[<2A277BAC2070266E6BF2C2060AD46B2B>]/Index[23 11]/Info 22 0 R/Length 49/Prev 24323/Root 24 0 R/Size 34/Type/XRef/W[1 2 1]>>stream 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. 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 [] /CropBox [0 0 612 792] /Resources 189 0 R /Contents [314 0 R 315 0 R 316 0 R] /Rotate 0 14 0 obj 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. 4. endobj PDF IN THE CIRCUIT COURT OF THE - Florida Attorney General /CropBox [0 0 612 792] /CropBox [0 0 612 792] /Contents [326 0 R 327 0 R 328 0 R] Date: Wednesday, June 21, 2000 Document Type: Complaint This document is available in two formats: this web page (for browsing content) and PDF (comparable to original document formatting). /Annots [] 15 0 obj /Parent 4 0 R 3 0 obj 48. 3. 12 0 obj PDF Complaint for Permanent Injunction, Monetary Relief, and Other Relief >> PDF Complaint for Permanent Injunction and Other Equitable Relief 52. /Contents [122 0 R 123 0 R 124 0 R] /MediaBox [0 0 612 792] /CropBox [0 0 612 792] 67 0 obj /Annots [] /MediaBox [0 0 612 792] << x1 04) F&`/MFWxC. 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. endobj 4. have exclusive jurisdiction: (a) In all actions at law cognizable by the county . /Type /Page 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. 4. 54 0 obj 1 1 On February 7, 2023 and February 16, 2023, Plaintiff filed motions for preliminary 2 injunctive relief. The operator then drives the FEL truck to a disposal facility, such as a transfer station, landfill or incinerator, and empties the contents of the vehicle. /Contents [298 0 R 299 0 R 300 0 R] ( 12. /Annots [] /Filter /FlateDecode /Type /Page /CropBox [0 0 612 792] /Nums [0 6 0 R] /Parent 11 0 R >> /MediaBox [0 0 612 792] COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF Introduction 1. /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] /Resources 109 0 R "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. %PDF-1.3 % /Rotate 0 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. Secure .gov websites use HTTPS 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. What impact will it have on third-parties and employees? >> 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. endstream endobj 2333 0 obj<>/W[1 1 1]/Type/XRef/Index[246 2074]>>stream and Florida Statute 86.011, et seq. 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. 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. 1114 Trademark Infringement . /Rotate 0 /Type /Pages /CropBox [0 0 612 792] endobj >> /Contents [342 0 R 343 0 R 344 0 R] Anderson, IN and New York City, NY are two such areas. >> endobj >> MSW has physical characteristics that readily distinguish it from other liquid or solid waste. 38 0 obj Plaintiff filed this action against defendant for breaching a non-competition agreement. >> Rule 1.610 of the Florida Rules of Civil Procedure governs requests for temporary injunctions. 4 0 obj endobj /Contents [218 0 R 219 0 R 220 0 R] competition generally in small container commercial waste collection service 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 will be lessened substantially; actual and potential competition between Allied and Republic in small container commercial waste collection service 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 will be eliminated; prices charged by small container commercial waste collection firms 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 will likely increase; competition generally in disposal of MSW in the Anderson, IN and New York City, NY area markets will be lessened substantially; actual and potential competition between Allied and Republic in disposal of MSW in the Anderson, IN and New York City, NY area markets will be eliminated; prices for disposal of MSW in the Anderson, IN and New York City, NY area markets likely will increase; competition generally in roll-off waste collection service in the Macon, GA area market will be lessened substantially; actual and potential competition between Allied and Republic in roll- off waste collection service in the Macon, GA area market will be eliminated; and. trailer << << /Parent 9 0 R /CropBox [0 0 612 792] 0000000817 00000 n /Rotate 0 << /Type /Pages 6th Street Ft. Lauderdale, FL 33301 Defendants. >> : 01-42230-BKC-AJC . >> << /Parent 11 0 R "Lakeland, FL area" means Polk County, Florida. /Contents [202 0 R 203 0 R 204 0 R] Z( endobj endobj /MediaBox [0 0 612 792] /Type /Pages << /Rotate 0 /Type /Page /Resources 229 0 R /MediaBox [0 0 612 792] /Parent 7 0 R >> /CropBox [0 0 612 792] 29. /Annots [] /Parent 10 0 R endobj /MediaBox [0 0 612 792] << 11. /Rotate 0 endobj /Kids [45 0 R 46 0 R 47 0 R 48 0 R 49 0 R 50 0 R 51 0 R 52 0 R 53 0 R 54 0 R] /Contents [394 0 R 395 0 R 396 0 R] /MediaBox [0 0 612 792] /Type /Page >> << 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. /Parent 12 0 R endobj Amended Complaint "Motion") [ECF(the No. 39 0 obj 19 0 obj /MediaBox [0 0 612 792] Venue is proper in the Circuit Court of the Seventh Judicial Circuit, in and for 10941 and Laws of Florida, Ch. /Type /Page h|VrH}Weo2)RXBr|:=%ts?mlteQG :C:+rl86#m0GcfFmMb`4&;|Xy|^Q(&Y Jf#mb!nDlpfIi QB*Mg< Does the courts have ability to enforce what you are requesting? "New York City, NY area" means the Borough of Brooklyn, New York. "Macon, GA area" means the City of Macon and Bibb, Peach and parts of Houston, Jones and Monroe counties, Georgia. 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. Should you request a temporary injunction or push quickly for final permanent injunction. >> 52 0 obj COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF . 2 0 obj /Annots [] /Rotate 0 /MediaBox [0 0 612 792] endobj >> stream /Annots [] /Count 10 /Resources 97 0 R Florida has reported 149 confirmed cases of COVID-19 and four deaths to date, with every expectation that these numbers will rise. /MediaBox [0 0 612 792] /Annots [] hUN@h/%FT""Qy@Kbxw81FgfvEN.tF2AiP9?{"1zQ. /Type /Catalog Deciding Whether to Sue for Injunction, and What is the Process to /Resources 389 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. /Resources 345 0 R 2320 14 A .gov website belongs to an official government organization in the United States. << ( >> /Type /Page 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. 74 0 obj /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] /Annots [] 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. /Resources 285 0 R 90 0 obj /Parent 12 0 R After the acquisition, Allied would control over 50 percent--and two firms more than 90 percent-- of the small container commercial waste hauling market, which has annual revenues of about $10 million. << >> /Parent 14 0 R /MediaBox [0 0 612 792] << /CropBox [0 0 612 792] /MediaBox [0 0 612 792] % 68. Omega SA v. The Individuals, Business Entities, and Unincorporated endobj endobj /Contents [262 0 R 263 0 R 264 0 R] Complaint for Injunctive Relief and Damages for Breach of /Annots [] 14. ("MFS"), is a Florida corporation that has a principal place of . ( << ( /Type /Page >> /CropBox [0 0 612 792] endobj 0 13. /Resources 253 0 R 44. 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. /Contents [162 0 R 163 0 R 164 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. If you are interested in speaking to a Jimerson Birr lawyer or want general information about the firm, our practice areas, lawyers, publications, or events, please contact us via email or telephone for assistance at (904) 389-0050. /Rotate 0 /Resources 337 0 R /Type /Page 21. /Resources 125 0 R /Resources 333 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. Allied and Republic are two of only a few providers of waste collection or disposal services in each of the identified areas. %PDF-1.3 % /MediaBox [0 0 612 792] /Rotate 0 59 0 obj A party seeking an injunction under general Florida case law must demonstrate: 1) irreparable harm; 2) a clear legal right; 3) an inadequate . 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 $25 million. Typical commercial waste collection customers include office and apartment buildings and retail establishments (e.g. xb```b``Ig`a`X @1V hdc [`&&v/>4427pHG(Og|sW(7_HPpXp'Skgu`.8!B=\2+".b4dh fZ!WHW3`W+.eP9(tb1P,%pX1EaSO6I)1] K,cMpl q m D@,"R:7S&`u@6j(LjfLT[D1,BPf:9= P1!$Ippa8fHNtD {,nPY 5 72 0 obj 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. Share sensitive information only on official, secure websites. /Resources 321 0 R /MediaBox [0 0 612 792] .t. /Contents [254 0 R 255 0 R 256 0 R] /Rotate 0 47. In the New York City, NY area, the acquisition would reduce from five to four the number of significant firms competing to dispose of commercial MSW. /Rotate 0 /Rotate 0 0000001852 00000 n 16 0 obj /Rotate 0 /Resources 101 0 R /Type /Page /Rotate 0 /Resources 381 0 R >> .+p>hPhb4yiK=c`/XOv@|fe`iY /Contents [142 0 R 143 0 R 144 0 R] endobj /Contents [398 0 R 399 0 R 400 0 R] /MediaBox [0 0 612 792] /Type /Page 11 0 obj endobj Suing for an injunction in Florida is all about preserving the status quo. /ModDate (D:20220824143048-04'00') endobj /Type /Page /Resources 161 0 R /Type /Page 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. clearly appears from specific facts shown by affidavit or by verified complaint that immediate or /Contents [278 0 R 279 0 R 280 0 R] << /MediaBox [0 0 612 792] x+ | 53(b), to secure preliminary and permanent injunctive relief, rescission of contracts, restitution, disgorgement, and other . << << ( endobj /Type /Page 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. /Type /Page /Creator (PScript5.dll Version 5.2.2) /Parent 13 0 R /Annots [] 9 0 obj << /Contents [350 0 R 351 0 R 352 0 R] 22 and 28 U.S.C. endobj << 42. /Rotate 0 . 42 0 obj >> /Type /Page 64. 36. 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. /CropBox [0 0 612 792] /Rotate 0 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. /Rotate 0 45. << /Resources 233 0 R ( /Resources 397 0 R 56 0 obj PDF Complaint for Injunctive Relief Representatives /Contents [378 0 R 379 0 R 380 0 R] << /Contents [322 0 R 323 0 R 324 0 R] stream 60 0 obj >> /Rotate 0 /MediaBox [0 0 612 792] /Resources 185 0 R /CropBox [0 0 612 792] /Type /Page The extension ofvote-by-mail options and other accommodations at polling places is necessary. /CropBox [0 0 612 792] endobj /MediaBox [0 0 612 792] 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). Garcia controll ed the MJ Companies prior to their going into receivership. /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 ( /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] /MediaBox [0 0 612 792] 47 0 obj >> /Contents [174 0 R 175 0 R 176 0 R] % 2322 0 obj<>stream endstream endobj 29 0 obj <>stream See Laws of Florida, Ch. /Type /Page /Annots [] >> /Annots [] 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. 46 0 obj 38. state of Florida in 1925 and yet again in 1943, under the legislative powers granted to the Florida legislature under the 1885 Constitution of the State of Florida. /Rotate 0 In each of these markets, the resulting substantial increase in concentration, loss of competition, and absence of reasonable prospect of significant new entry or expansion by market incumbents, ensures that consumers will pay substantially higher prices for collection of small container commercial waste, the collection of roll-off waste, or the disposal of MSW. Jurisdiction is conferred on this Court by Chapters 26, 34, 86.011. << 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. Is there any vagueness, or is everything extremely clear? For a number of reasons, landfills may not be located close to where the waste is generated. PDF United States District Court Northern District of Florida Pensacola << /Filter /FlateDecode 1. /Resources 165 0 R PDF Complaint for Injunctive and Other Relief and Demand for Jury Trial I /Type /Page /Parent 11 0 R This is an action for injunctive relief. /Annots [] /Parent 10 0 R >> /Rotate 0 There are immediate expenditures necessary. /Type /Page A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. << 4. >> Does the temporary injunction preserve the Status Quo or does it make a change? /Parent 9 0 R >> >> /MediaBox [0 0 612 792] Rather, its about dealing with the future, not something that happened in the past. How long will the injunction be effective? 7 0 obj It is calculated by squaring the market share of each firm competing in the market and then summing the resulting numbers. 93 0 obj PLAINTIFF'S COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF . 51 0 obj 0000000592 00000 n /Rotate 0 /MediaBox [0 0 612 792] /Resources 261 0 R /Annots [] An official website of the United States government. >> /Annots [] PDF Complaint for Injunctive Relief, Damages, %PDF-1.5 % PDF IN THE CIRCUIT COURT OF THE SECOND JUDICIAL - Florida Carry, Inc. 40 0 obj On September 8, 2021, the Court, by consent, entered a preliminary injunction against Garcia. 0000001469 00000 n 26. << /Contents [154 0 R 155 0 R 156 0 R] provide relief to all the individuals affected by APD's action. This Court has the authority to grant the requested declaratory and injunctive relief pursuant to 28 U.S.C. /Parent 11 0 R Section 13(b) of the FTC Act, 15 U.S.C. endobj 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. >> 75 0 obj /Type /Pages >> 5.) 13 0 obj 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. In the Macon, GA area, the acquisition would also combine the two largest firms that compete in roll-off waste collection service. There may be disclosure of confidential information such as trade secrets. 63. /Kids [15 0 R 16 0 R 17 0 R 18 0 R 19 0 R 20 0 R 21 0 R 22 0 R 23 0 R 24 0 R] ( /CropBox [0 0 612 792] /CropBox [0 0 612 792] /Parent 9 0 R 32 0 obj /Count 10 An MSW disposal facility must be located on approved types of land and operated under prescribed procedures. 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. The length of the presentation is 46:09. 66 0 obj /MediaBox [0 0 612 792] 28. /CropBox [0 0 612 792] /Count 10 << This action is brought to /CropBox [0 0 612 792] << /Metadata 2 0 R endobj << 70 0 obj /Resources 181 0 R /Resources 277 0 R endobj As such, following the process to the tee will help improve your chances for success. /Resources 305 0 R /Parent 10 0 R 78 0 obj Local small container commercial waste collection firms 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 areas can profitably increase charges to local customers without losing significant sales to more distant competitors. /Type /Pages /CropBox [0 0 612 792] /Annots [] PDF COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF - NSB Anglers Yacht /Rotate 0 << /Type /Page Because of the differences in the collection process, residential customers and commercial customers usually are organized into separate routes. 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. /Length 10 /CropBox [0 0 612 792] Managing Partner endobj /Type /Page JacqmeinV /Contents [366 0 R 367 0 R 368 0 R] PDF Florida Small Claims Rules Annotated 2020 - The Florida Bar hb```f`` $V30 1;oO_Ia`sF!gbl!O| ` /Rotate 0 /Type /Page /Annots [] /CropBox [0 0 612 792] /Resources 177 0 R << /Contents [318 0 R 319 0 R 320 0 R] Plaintiff seeks temporary, preliminary, and permanent injunctive relief pursuant to Rule 65 . /Type /Page /Annots [] /Contents [302 0 R 303 0 R 304 0 R] /Type /Page >> /Rotate 0 JURISDICTION AND VENUE 2. /MediaBox [0 0 612 792] /Type /Page endobj 87 0 obj 57. (ECF No. In re Amendments to Florida Small Claims Rules, 123 So.3d 41 (Fla . /Type /Page ;,hn \ic6rZFi+|:GsL$KGqzed8;M+"N7i~4Dr?_1hHa:`R[B%Qm*?u9Lh=?y%x8;e$AD+xx >> << prescribed by these rules and by section 51.011, Florida Statutes, the statutory provision shall govern. /Resources 129 0 R >> /Resources 225 0 R << /MediaBox [0 0 612 792] /Resources 241 0 R /CropBox [0 0 612 792] endobj In 1998, for example, these three transfer stations disposed of over 85 percent of the MSW generated in the Anderson, IN area. 80 0 obj << 3 0 obj Since May 7, 2021, Wilson has been the GC of a private investment firm based in Boca Raton, Florida. /Rotate 0 COMPLAINT FOR INJUNCTIVE RELIEF AND SANCTIONS Plaintiff, Donald F. Walton, United States Trustee for . /Contents [170 0 R 171 0 R 172 0 R] /Resources 309 0 R endobj /Contents [286 0 R 287 0 R 288 0 R] 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. /Rotate 0 >> /CropBox [0 0 612 792] /Parent 10 0 R << /Annots [] ( /MediaBox [0 0 612 792] >> /Annots [] /Rotate 0 /Parent 11 0 R endobj /Contents [186 0 R 187 0 R 188 0 R] << 57 0 obj 68 0 obj hb```"FN%n010pKsg``Z ^^@Y"bL38/4F `} endstream endobj 24 0 obj <> endobj 25 0 obj <>/ProcSet[/PDF/Text]>>/Rotate 0/Type/Page>> endobj 26 0 obj <>stream /CropBox [0 0 612 792] /CropBox [0 0 612 792] endobj 20 0 obj /MediaBox [0 0 612 792] Complaint for Injunctive Relief | ATR | Department of Justice /Type /Pages /Rotate 0 0000001536 00000 n 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. ( The Court has jurisdiction over this action and over the parties pursuant to 15 U.S.C. /Annots [] 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. /Type /Page 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. /Parent 10 0 R << /Contents [358 0 R 359 0 R 360 0 R] PDF United States District Court Middle District of Florida Tampa Division 77 0 obj Therefore, the video continues on this topic by explaining: A suit for injunction is an extraordinary remedy for businesses and individuals alike.