What Time Zone Is 12 Hours Ahead Of Est, Articles C

/MediaBox [0 0 612 792] /Rotate 0 /Annots [] /CropBox [0 0 612 792] /Type /Page /Parent 10 0 R An official website of the United States government. endobj /Annots [] Significant new entry into small container commercial waste collection service is difficult and time-consuming 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. /Parent 12 0 R /Resources 253 0 R /CropBox [0 0 612 792] << /Resources 293 0 R The length of the presentation is 46:09. 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. /Annots [] PDF COMPLAINT FOR INJUNCTIVE RELIEF AND SANCTIONS PARTIES - The Wall Street /Parent 9 0 R 42 0 obj /Parent 8 0 R 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. 21 0 obj /Contents [234 0 R 235 0 R 236 0 R] To access the presentation, visit YouTube or click play on the embedded image below. /Type /Pages Therefore, it should not be a decision made lightly. << relief pursuant to Chapter 86, Florida Statutes. << 0000006259 00000 n /Resources 377 0 R << >> "Gulf Coast, FL area" means Escambia, Santa Rosa, and Okaloosa counties, Florida. stream This action is filed by the United States of America under Section 15 of the Clayton Act, 15 U.S.C. 2201 a nd 2202. /Annots [] 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. >> /Resources 353 0 R /Rotate 0 << %&'()*456789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz w !1AQaq"2B #3Rbr 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. (2001). << >> >> /MediaBox [0 0 612 792] What happens if the temporary injunction is not granted? >> . ;("(;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;; 44 0 obj endobj 22 and 28 U.S.C. /CropBox [0 0 612 792] /Contents [266 0 R 267 0 R 268 0 R] >> /MediaBox [0 0 612 792] /Type /Page 2018 to May 6, 2021. << >> /Annots [] 30. In addition to differences in container size, other factors distinguish roll-off waste collection from small container commercial and other types of waste collection. On August 20, . endobj Plaintiff, Florida Carry, is a Florida Not-For-Profit Corporation with a principal place of business located at 1090 Wild Holly Drive, Port Orange, Florida, 32129. Defendants because the Amended Complaint seeks injunctive relief only for these Counts, to which qualified immunity does not apply. "Memphis, TN area" means Shelby County, Tennessee; Desoto County, Mississippi, and Crittenden County, Arkansas. PDF IN THE CIRCUIT COURT OF THE - Florida Attorney General 9 0 obj 89 0 obj 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. << /Annots [] (Compl . SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION In re: JOSE SANCHEZ Case No. /CropBox [0 0 612 792] /Contents [390 0 R 391 0 R 392 0 R] SOUTHERN DISTRICT OF FLORIDA . Does the temporary injunction preserve the Status Quo or does it make a change? >> /Resources 285 0 R /Rotate 0 /Parent 10 0 R /Annots [] 39 0 obj ( 12. /MediaBox [0 0 612 792] xYYoH~7"b` recB$hHjRbK6DQ]]WUMb8`}^^l,q8x1O,7~`[)gD,uq+sU+PP)>f90VY-^AEKS2t}g4 X!xH rTmvF4(,W`{kF$tC << Introduction Types of Injunctive Relief - The CLM The transactions likely will have the following effects, among others: 1. 37 0 obj /Type /Page In the Anderson, IN area, almost all of the MSW generated is disposed of in one of three transfer stations. 2320 14 /Resources 181 0 R The extension ofvote-by-mail options and other accommodations at polling places is necessary. endstream Since May 7, 2021, Wilson has been the GC of a private investment firm based in Boca Raton, Florida. /Resources 125 0 R /Parent 13 0 R endobj /MediaBox [0 0 612 792] /CropBox [0 0 612 792] Permit restrictions often impose severe limitations on the type and amount of waste that can be disposed of at landfills. /Length 10 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. 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. 0000001536 00000 n /Parent 4 0 R 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 Louisville, KY/Sellersburg, IN area. /Parent 7 0 R /Resources 317 0 R endobj The next step is careful preparation before the temporary injunction hearing. Haulers, therefore, generally establish garages and related facilities within each major local area served. 76 13 /Parent 10 0 R Last updated on November 21, 2022. 0 >> 3. /Rotate 0 70 0 obj /Contents [166 0 R 167 0 R 168 0 R] JFIF C /Rotate 0 ( /Type /Page 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. /CropBox [0 0 612 792] Complaint for Declaratory Relief in Florida - Trellis /Type /Page endobj 12 0 obj << 33. endobj /MediaBox [0 0 612 792] ( endobj << /Contents [358 0 R 359 0 R 360 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. 73 0 obj << >> /S /D PDF Motion for Summary Judgment - Liberty Counsel An MSW disposal facility must be located on approved types of land and operated under prescribed procedures. 86 0 obj 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; /Contents [102 0 R 103 0 R 104 0 R] 0000001373 00000 n /Resources 189 0 R It is calculated by squaring the market share of each firm competing in the market and then summing the resulting numbers. /CropBox [0 0 612 792] << /Rotate 0 EOs6~W\F3[_y7~r+W3nU>9YRpM/u"%1yK Ivp, Microsoft Word - 2022-08-24 - Complaint - FINAL. Private waste haulers typically contract directly with customers for the collection of waste generated by commercial accounts. /CropBox [0 0 612 792] /MediaBox [0 0 612 792] /Type /Page /Rotate 0 /MediaBox [0 0 612 792] /Type /Page >> COMPLAINT FOR INJUNCTIVE RELIEF AND SANCTIONS Plaintiff, Donald F. Walton, United States Trustee for . 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 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. 60. 33 0 obj /Annots [] >> /CropBox [0 0 612 792] endobj /Contents [322 0 R 323 0 R 324 0 R] << /CropBox [0 0 612 792] startxref /Contents [374 0 R 375 0 R 376 0 R] >> /CropBox [0 0 612 792] /Resources 121 0 R endobj /Resources 405 0 R 36 0 obj Absent injunctive relief by this Court, Defendants are likely to continue to injure consumers, reap unjust enrichment, and harm the public interest. /Parent 9 0 R /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. /Resources 365 0 R /Type /Page endobj /Contents [286 0 R 287 0 R 288 0 R] /Contents [210 0 R 211 0 R 212 0 R] 24. /Resources 309 0 R /MediaBox [0 0 612 792] endobj /Contents [118 0 R 119 0 R 120 0 R] >> 0000000016 00000 n The extension of vote-by-mail options and other accommodations at polling places is necessary. /Contents [242 0 R 243 0 R 244 0 R] Is there any vagueness, or is everything extremely clear? /Rotate 0 >> 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. This is a must-watch video before you consider whether to sue for injunction. . 32. The City changed its name from "New 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. /Title (Microsoft Word - 2022-08-24 - Complaint - FINAL) ( /Contents [354 0 R 355 0 R 356 0 R] 71 0 obj >> endobj 18. 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. /Parent 14 0 R >> endobj The proposed acquisition would reduce from three to two the number of significant competitors for the disposal of MSW in the Anderson, IN area. %PDF-1.4 % endobj >> /CropBox [0 0 612 792] endobj 90 0 obj /CropBox [0 0 612 792] /Resources 237 0 R endstream endobj 29 0 obj <>stream The HHI increases both as the number of firms in the market decreases and as the disparity in size between those firms increases. hb```f`` $V30 1;oO_Ia`sF!gbl!O| ` /MediaBox [0 0 612 792] /Rotate 0 64 0 obj A temporary injunction is sought to stop a party from engaging in certain conduct or to require a party to engage in certain conduct until a final decision may be made concerning the merits of the dispute. endobj provide relief to all the individuals affected by APD's action. /Parent 9 0 R Complaint for Injunctive Relief and Civil Penalties | US EPA Roll-off waste collection services are generally provided in localized areas because a roll-off truck cannot be efficiently or profitably driven significantly longer distances than those driven by a competitor to collect and dispose of the waste. /CropBox [0 0 612 792] /Type /Page 45], filed on August 192021, . << 2. /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 [] &%e2#4DqB#K.tt.GYeMbN!uiW-C`oIynF,fD5c&a8|A!y%?ci6Ywo`aPT=Yz0Id /Contents [134 0 R 135 0 R 136 0 R] Share sensitive information only on official, secure websites. endobj "HHI" means the Herfindahl-Hirschman Index, a commonly accepted measure of market concentration. endobj /Type /Page D. Entry Into Commercial Waste Collection of MSW. /Rotate 0 /Resources 261 0 R /Parent 11 0 R 0000006750 00000 n /CropBox [0 0 612 792] Does the courts have ability to enforce what you are requesting? 2 0 obj /MediaBox [0 0 612 792] That plaintiff recover the costs of this action. 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. <> 31 0 obj The cost advantage of local landfills limits the areas where MSW can be economically transported and disposed of by haulers and creates localized markets for MSW disposal services. ASSOCIATION OF FLORIDA, MIGRANT CLINICIANS NETWORK, PINEROS Y . /MediaBox [0 0 612 792] /Parent 12 0 R PDF United States District Court Northern District of Florida Pensacola /Parent 7 0 R /Parent 9 0 R /Parent 13 0 R /Resources 149 0 R PDF Complaint for Injunctive Relief Representatives