/Type /Pages /Parent 10 0 R /Producer <4163726F6261742044697374696C6C65722032322E30202857696E646F7773293B206D6F646966696564207573696E67206954657874AE20372E312E3620A9323030302D323031392069546578742047726F7570204E56202841646D696E697374726174697665204F6666696365206F662074686520556E697465642053746174657320436F757274733B206C6963656E7365642076657273696F6E29> 64 0 obj 49 0 obj 7. /Contents [310 0 R 311 0 R 312 0 R] /MediaBox [0 0 612 792] << In 1999, Allied reported total revenues of approximately $6 billion. 20. 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. 0000006750 00000 n /Contents [162 0 R 163 0 R 164 0 R] /Contents [214 0 R 215 0 R 216 0 R] /Rotate 0 for the Middle Distrct of Florida, hereby files this complaint for permanent injunction and alleges as follows: 1. /MediaBox [0 0 612 792] /Type /Page 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. stream /Parent 4 0 R 1. /MediaBox [0 0 612 792] 25. <>>> /Contents [354 0 R 355 0 R 356 0 R] endobj 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. "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. << xref 15. } !1AQa"q2#BR$3br 53(b), to secure preliminary and permanent injunctive relief, rescission of contracts, restitution, disgorgement, and other . /Annots [] After the acquisition, Allied would be a monopolist controlling over 98 percent of the small container Commercial waste hauling market, which has annual revenues of about $5 million. 22 and 28 U.S.C. /Contents [142 0 R 143 0 R 144 0 R] >> /Parent 12 0 R /Annots [] >> endobj 30 0 obj /Parent 7 0 R This action is brought to << /MediaBox [0 0 612 792] /Contents [98 0 R 99 0 R 100 0 R] /Type /Page /MediaBox [0 0 612 792] 0 << /Parent 12 0 R /MediaBox [0 0 612 792] /Rotate 0 /Annots [] /Contents [398 0 R 399 0 R 400 0 R] >> Plaintiff seeks temporary, preliminary, and permanent injunctive relief pursuant to Rule 65 . /Resources 297 0 R Does the courts have ability to enforce what you are requesting? 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 $10 million. See Merger Guidelines 1.51. ( While small container commercial waste collection typically involves a FEL truck making regular stops on pre-scheduled routes to empty numerous containers at multiple customer locations, roll-off waste collection is often performed on an "on-call" basis for customers whose waste is not part of any route. >> 38 0 obj 12 0 obj Injunctive relief is considered an extraordinary remedy in both State and Federal court. /Rotate 0 /Annots [] endobj endobj 0 Parties 13. /MediaBox [0 0 612 792] /CropBox [0 0 612 792] /Filter /FlateDecode In the Macon, GA area, the acquisition would reduce from two to one the number of significant firms that compete in the collection of small container commercial waste. 0000001187 00000 n endobj The acquisition would reduce from three to two the number of significant firms that compete in the collection of small container commercial waste in the Burlington and Camden Counties, NJ area. /Contents [378 0 R 379 0 R 380 0 R] /Annots [] /Type /Page << /Parent 11 0 R >> 40. 2320 0 obj<> endobj << xYYoH~7"b` recB$hHjRbK6DQ]]WUMb8`}^^l,q8x1O,7~`[)gD,uq+sU+PP)>f90VY-^AEKS2t}g4 X!xH rTmvF4(,W`{kF$tC /Type /Page /Rotate 0 ]Wx C1>*yvL#uR$=I$$WJQg%=ElRS3DE27y1 G. /Rotate 0 /Type /Page h|VrH}Weo2)RXBr|:=%ts?mlteQG :C:+rl86#m0GcfFmMb`4&;|Xy|^Q(&Y Jf#mb!nDlpfIi QB*Mg< /Parent 12 0 R >> endobj endobj /Contents [246 0 R 247 0 R 248 0 R] This form is a Complaint for Injunctive Relief and Damages. endobj 6. endobj hbbd``b`@q=`v0012,I00"0 endstream endobj startxref 0 %%EOF 33 0 obj <>stream There are immediate expenditures necessary. /Contents [394 0 R 395 0 R 396 0 R] /Resources 349 0 R >> /Parent 4 0 R endobj >> /Parent 8 0 R endobj << Federal, state and local safety, environmental, zoning, and permit laws and regulations dictate critical aspects of storage, handling, transportation, processing and disposal of MSW. 27. This Court has supplemental jurisdiction over the State of Florida's state claims pursuant to COMPLAINT -3-q;;m: @ii$$1$$ &JIIJAI JKQI !.1 i&%iiM tv . Plaintiff LEAGUE OF WOMEN VOTERS OF FLORIDA ("LWVF" or the "League") is the Florida affiliate of the League of Women Voters of the United States. 7402(a) to prevent such conduct. 17 0 obj advance, Plaintiffs seek immediate declaratory and injunctive relief that directs Defendants to permit a designated representative of each affected candidate and political party into the recount room, as Florida law requires. /CropBox [0 0 612 792] 4. << Waiver recipients are entitled to continuation of services that they are currently receiving through the completion of the fair hearing endobj >> /Contents [174 0 R 175 0 R 176 0 R] 3 0 obj /Annots [] /CropBox [0 0 612 792] 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. endobj IV. /Annots [] /Annots [] ( Republic is a Delaware corporation with its principal office in Ft. Lauderdale, Florida. x1 04) F&`/MFWxC. INTRODUCTION . 22 0 obj endobj "Augusta, GA area" means the City of Augusta, Richmond and Columbia counties, Georgia, and Aiken County, South Carolina. endstream endobj 26 0 obj <> endobj 27 0 obj <>>>/Rotate 0/Type/Page>> endobj 28 0 obj <>stream >> Typical commercial waste collection customers include office and apartment buildings and retail establishments (e.g. 41 0 obj ( %PDF-1.3 % Jurisdiction is conferred on this Court by Chapters 26, 34, 86.011. /Annots [] 2322 0 obj<>stream How long will the injunction be effective? 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. /Annots [] /Annots [] /Parent 7 0 R 42. 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 endobj /Parent 8 0 R endobj /CropBox [0 0 612 792] /Rotate 0 /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. << /Parent 12 0 R endobj /Rotate 0 << /CropBox [0 0 612 792] /Type /Page Complaint for Emergency Injunctive Relief in Florida Primary The global coronavirus pandemic threatens to disrupt the Presidential Preference Primary election in Florida. THIS COURT'S POWER TO GRANT RELIEF 84. 84 0 obj /CropBox [0 0 612 792] .t. 33. endobj /Contents [266 0 R 267 0 R 268 0 R] /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. endobj ( GsYzQh50ee' This Court has jurisdiction to enter declaratory and injunctive relief pursuant to Florida Statute 86.011 and Article V, 20 of the Florida Constitution. "New York City, NY area" means the Borough of Brooklyn, New York. endobj 31 0 obj <>stream /Contents [226 0 R 227 0 R 228 0 R] >> endobj 69. 34. endobj /Rotate 0 /Type /Page /Parent 13 0 R /Rotate 0 /Type /Page /MediaBox [0 0 612 792] Does the injunction provide broad or limited relief? /Resources 149 0 R 50. 91 0 obj 66 0 obj /Parent 9 0 R /MediaBox [0 0 612 792] >> /Count 10 53(b), empowers this Court to grant injunctive and such other relief as the Court may deem appropriate to halt /Parent 7 0 R Plaintiff, The Second Amendment Foundation, is a Washington Not-For-Profit 6 0 obj /Resources 161 0 R endobj endobj /Resources 193 0 R >> /Resources 201 0 R endobj /CropBox [0 0 612 792] endobj ( 46. 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] The significant share of the roll-off collection market which Republic would have, its control of the primary disposal sites in the area, and its frequent use of long-term, automatically renewing contracts with roll-off collection customers, would make entry into the Macon, GA roll-off waste collection market difficult, and unlikely to prevent market incumbents from significantly raising prices for the collection of roll-off waste following the acquisition. << /Resources 181 0 R /Annots [] /Type /Page Garcia controll ed the MJ Companies prior to their going into receivership. endobj 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. 0000001852 00000 n 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. In the Anderson, IN area, almost all of the MSW generated is disposed of in one of three transfer stations. /Rotate 0 0000003135 00000 n /Annots [] Roll-off waste haulers, therefore, generally establish garages and related facilities within each major local area served. /Parent 11 0 R << 1 0 obj >> << Plaintiff complains and alleges as follows: 1. 10941 and Laws of Florida, Ch. /Resources 153 0 R 54. 67 0 obj /Resources 177 0 R 37 0 obj /Contents [210 0 R 211 0 R 212 0 R] 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. 26. /Resources 245 0 R 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. Filing 1 COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. /Rotate 0 Defendants because the Amended Complaint seeks injunctive relief only for these Counts, to which qualified immunity does not apply. 77 0 obj /MediaBox [0 0 612 792] "HHI" means the Herfindahl-Hirschman Index, a commonly accepted measure of market concentration. /Annots [] >> 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. << /Contents [366 0 R 367 0 R 368 0 R] /Resources 285 0 R /Rotate 0 69 0 obj /MediaBox [0 0 612 792] /Contents [350 0 R 351 0 R 352 0 R] /Contents [158 0 R 159 0 R 160 0 R] 45 0 obj ( /Type /Page . /Parent 12 0 R 10 0 obj /CropBox [0 0 612 792] Security Personnel as Independent Contractors Part Ii: What Liability Is Incurred to the Company From Accidents Involving Independent Contractors? 18. /Resources 257 0 R 8 0 obj /Parent 13 0 R /Count 10 /MediaBox [0 0 612 792] /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 endobj /Rotate 0 /Parent 11 0 R The United States is entitled to injunctive relief under 26 U.S.C. endobj Preference Primary election in Florida. << /Count 10 /Resources 197 0 R In its 1998 fiscal year, Republic reported total revenues of approximately $1.8 billion. endstream endobj 29 0 obj <>stream 43. /Contents [250 0 R 251 0 R 252 0 R] (Compl . >> In the Macon, GA area, the acquisition would also combine the two largest firms that compete in roll-off waste collection service. Managing Partner Unless the twelve acquisitions are enjoined, consumers of waste collection and disposal services will likely pay higher prices and receive fewer services as a consequence of the elimination of the vigorous competition between defendants Allied and Republic. Section 13(b) of the FTC Act, 15 U.S.C. /Subtype /XML The President of the United States and the Governor of Florida have each declared a state of emergency. /Type /Page >> << 0000001994 00000 n Judgment for Permanent Injunctive Relief against MJ Taxes on October 1, 2021. endobj /MediaBox [0 0 612 792] ;,hn \ic6rZFi+|:GsL$KGqzed8;M+"N7i~4Dr?_1hHa:`R[B%Qm*?u9Lh=?y%x8;e$AD+xx /Type /Page After the acquisition, Republic would control over 50 percent--and two firms about 90 percent--of the small container commercial waste hauling market, which has annual revenues exceeding $22 million. /Contents [178 0 R 179 0 R 180 0 R] Is there any vagueness, or is everything extremely clear? /Annots [] /Annots [] << As such, following the process to the tee will help improve your chances for success. endobj /Type /Page /Type /Page endstream Microsoft Word - 2022-08-24 - Complaint - FINAL >> /Rotate 0 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. /Parent 9 0 R 14. /Parent 7 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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