/Resources 397 0 R /Resources 325 0 R /Annots [] "Gulf Coast, FL area" means Escambia, Santa Rosa, and Okaloosa counties, Florida. That plaintiff recover the costs of this action. /CropBox [0 0 612 792] 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. << /Type /Page >> Plaintiff also contends that the harm suffered as a result of defendant's conduct is irreparable in nature and cannot be measured solely in terms of monetary damages. 7. 58 0 obj 0000003868 00000 n endobj /CropBox [0 0 612 792] 33 0 obj 10941 and Laws of Florida, Ch. 2322 0 obj<>stream 16 0 obj Amended Complaint "Motion") [ECF(the No. 0000002992 00000 n 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. 95 0 obj /Parent 14 0 R /Count 10 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. /Parent 7 0 R /Resources 109 0 R << : 01-42230-BKC-AJC . /Resources 313 0 R endobj << A party seeking an injunction under general Florida case law must demonstrate: 1) irreparable harm; 2) a clear legal right; 3) an inadequate . 40. >> Anyone who fails to dispose of MSW in an approved facility can be subject to severe civil and criminal penalties. /Parent 10 0 R endobj /Type /Page endobj ( 0000003645 00000 n /Resources 249 0 R 5 0 obj 54 0 obj >> /Type /Page /Contents [330 0 R 331 0 R 332 0 R] 22. /Resources 121 0 R /Type /Metadata /Contents [150 0 R 151 0 R 152 0 R] 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. How long will the injunction be effective? /MediaBox [0 0 612 792] endstream endobj startxref 0000001317 00000 n << Plaintiffs also seek temporary injunctive relief as stated in the accompanying Motion for Temporary Injunction. 91 0 obj The next step is careful preparation before the temporary injunction hearing. The President of the United States and the Governor of Florida have each declared a state of emergency. /Contents [274 0 R 275 0 R 276 0 R] 65 0 obj WEST PALM BEACH DIVISION . In such areas, many of the problems associated with the permitting and construction of a landfill could make it difficult to permit and construct a transfer station. ( 63. /MediaBox [0 0 612 792] 7402(a) to prevent such conduct. /Parent 9 0 R 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. 55 0 obj /Parent 14 0 R /Parent 13 0 R 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. /Parent 12 0 R 16. 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. JURISDICTION AND VENUE 1. /Annots [] See also Chapter 224.08, Special Acts of Florida, 1943. /Type /Page /Parent 7 0 R ( 14. 4. /Contents [234 0 R 235 0 R 236 0 R] /MediaBox [0 0 612 792] /Rotate 0 /Parent 7 0 R endobj 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 >> 6th Street Ft. Lauderdale, FL 33301 Defendants. <<14CA263718F8354CB34DA495C0495A29>]>> /Type /Page 15. (ECF No. >> Suing for an injunction in Florida is all about preserving the status quo. /Annots [] /Resources 221 0 R 6108, to obtain temporary, preliminary, and permanent injunctive relief, rescission or reformation of contracts, restitution, the refund of monies paid, disgorgement of ill-gotten . >> /Type /Pages In re Amendments to Florida Small Claims Rules, 123 So.3d 41 (Fla . /Contents [342 0 R 343 0 R 344 0 R] /CropBox [0 0 612 792] Plaintiff, The Second Amendment Foundation, is a Washington Not-For-Profit Garcia controll ed the MJ Companies prior to their going into receivership. The Corps' environmental analysis for this project is based on the same assumptions and Because of its characteristics (e.g. /Parent 4 0 R /Type /Page /Type /Catalog /Annots [] 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. endobj /Contents [302 0 R 303 0 R 304 0 R] /Type /Page /Resources 301 0 R /Producer <4163726F6261742044697374696C6C65722032322E30202857696E646F7773293B206D6F646966696564207573696E67206954657874AE20372E312E3620A9323030302D323031392069546578742047726F7570204E56202841646D696E697374726174697665204F6666696365206F662074686520556E697465642053746174657320436F757274733B206C6963656E7365642076657273696F6E29> /MediaBox [0 0 612 792] /Resources 333 0 R Very often courts do not grant injunctions if there is not a lot of specificity and practicality in the request for an injunction. 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. /Resources 237 0 R /Resources 309 0 R /Parent 4 0 R /Rotate 0 /Rotate 0 Managing Partner /Contents [314 0 R 315 0 R 316 0 R] /Annots [] /Type /Page /Resources 125 0 R << xref /Contents [254 0 R 255 0 R 256 0 R] /Contents [122 0 R 123 0 R 124 0 R] /Annots [] >> /Type /Page /MediaBox [0 0 612 792] After the acquisition, Republic would own two of the three transfer stations, which together would control in excess of 65 percent of the MSW disposal market, which has annual revenues in excess of $3 million. /MediaBox [0 0 612 792] >> ( 52. << endobj >> "Louisville, KY/ Sellersburg, IN area" means the cities of Louisville, Kentucky and Sellersburg, Indiana; Jefferson County, Kentucky; and the parts of Floyd and Clark counties, Indiana abutting Jefferson County, Kentucky. 21 0 obj ( 34. 3601, et seq. Allied is located in and transacts business in the District of Columbia, and Republic submits to the personal jurisdiction of the District of Columbia in this proceeding. /Contents [186 0 R 187 0 R 188 0 R] /Parent 8 0 R /PageLabels 3 0 R << /Parent 13 0 R /Resources 349 0 R /Contents [278 0 R 279 0 R 280 0 R] /Rotate 0 >> << << endobj << /Resources 293 0 R >> /Type /Page /Parent 12 0 R Plaintiff, PRISON LEGAL NEWS ("PLN"), a project of the Human Rights Defense . /Annots [] /MediaBox [0 0 612 792] endobj The HHI takes into account the relative size and distribution of the firms in a market and approaches zero when a market consists of a large number of firms of relatively equal size. /Annots [] /Annots [] 38 0 obj 3 0 obj << 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. /MediaBox [0 0 612 792] /Parent 10 0 R /Rotate 0 /Annots [] endobj /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] /Parent 12 0 R /CropBox [0 0 612 792] /Resources 369 0 R ( /Type /Page /Annots [] 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 /CropBox [0 0 612 792] /Type /Page 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 /Annots [] ( /Subtype /XML endobj /MediaBox [0 0 612 792] In order to obtain comparable operating efficiency, a new firm must achieve route density comparable to existing firms. /MediaBox [0 0 612 792] /Parent 4 0 R << ( 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 . 11. 61. 27. /Parent 7 0 R /Resources 197 0 R D. P. et al., . /Annots [] >> /Type /Page Plaintiff is a Florida resident, lives in Miami- Dade County, is sui juris, and qualifies of a protected class under the ADA, 42 U.S.C. D. Entry Into Commercial Waste Collection of MSW. /Type /Page /CropBox [0 0 612 792] %PDF-1.5 The global coronavirus pandemic threatens to disrupt the Presidential << endobj /Type /Page Rather, its about dealing with the future, not something that happened in the past. /Rotate 0 /Contents [250 0 R 251 0 R 252 0 R] In the Nashville, TN area, the acquisition would reduce from three to two the number of significant firms competing in the collection of small container commercial waste. 13(b) of the Federal Trade Commission Act ("FTC Act"), 15 U.S.C. 67 0 obj ( "Augusta, GA area" means the City of Augusta, Richmond and Columbia counties, Georgia, and Aiken County, South Carolina. /Parent 14 0 R 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. << /Rotate 0 /Rotate 0 endobj /Resources 269 0 R 0000003404 00000 n /Rotate 0 endobj INTRODUCTION . 81 0 obj Allied and Republic directly compete in roll-off waste collection service in a number of markets nationwide, including the Macon, GA area.
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