>> << >> 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. << /Parent 12 0 R 0000003135 00000 n << /CropBox [0 0 612 792] << /Type /Page /Annots [] /MediaBox [0 0 612 792] >> /Annots [] /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). ( /Parent 10 0 R 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. /Annots [] In addition, be sure you have competent, knowledgeable and experienced counsel in your corner. /MediaBox [0 0 612 792] REPUBLIC SERVICES, INC., 110 S.E. /Type /Page /MediaBox [0 0 612 792] As such, following the process to the tee will help improve your chances for success. endobj /Rotate 0 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. 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. 57 0 obj "New York City, NY area" means the Borough of Brooklyn, New York. 92 0 obj /Type /Page 26. /Resources 329 0 R << 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. /Parent 11 0 R Preference Primary election in Florida. /Annots [] 0000001275 00000 n endobj Judgment for Permanent Injunctive Relief against MJ Taxes on October 1, 2021. /Annots [] 56. 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. << The county court may issue a temporary and permanent injunction where appropriate for violation of ss. The proposed acquisition would reduce from three to two the number of significant competitors for the disposal of MSW in the Anderson, IN area. /Contents [130 0 R 131 0 R 132 0 R] >> /Contents [170 0 R 171 0 R 172 0 R] /Contents [294 0 R 295 0 R 296 0 R] 2201 a nd 2202. << >> 21-81099-CIV-CANNON/Reinhart . "Macon, GA area" means the City of Macon and Bibb, Peach and parts of Houston, Jones and Monroe counties, Georgia. 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. %PDF-1.5 % %%EOF 45 0 obj /Annots [] /MediaBox [0 0 612 792] /Contents [126 0 R 127 0 R 128 0 R] endobj /Rotate 0 << 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. /Parent 7 0 R 0000001373 00000 n /Type /Page /MediaBox [0 0 612 792] 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. 37 0 obj /Resources 101 0 R /Annots [] /Contents [186 0 R 187 0 R 188 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. 50 0 obj /Contents [318 0 R 319 0 R 320 0 R] 0000006259 00000 n /Contents [238 0 R 239 0 R 240 0 R] 5. >> On September 8, 2021, the Court, by consent, entered a preliminary injunction against Garcia. /MediaBox [0 0 612 792] 6108, to obtain temporary, preliminary, and permanent injunctive relief, rescission or reformation of contracts, restitution, the refund of monies paid, disgorgement of ill-gotten . /Rotate 0 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. /Count 10 Jimerson Birr welcomes inquiries from the media and do our best to respond to deadlines. 3 0 obj It is economically impractical for a roll-off waste collection firm to serve metropolitan areas from a distant base. stream /Annots [] >> endobj /Parent 10 0 R Does the injunction provide broad or limited relief? << Small container commercial waste collection differs in many important respects from the collection of residential or other types of waste. << /Resources 393 0 R 42. /CropBox [0 0 612 792] Defendants because the Amended Complaint seeks injunctive relief only for these Counts, to which qualified immunity does not apply. 12 0 obj endobj 48. Therefore, the video continues on this topic by explaining: A suit for injunction is an extraordinary remedy for businesses and individuals alike. /Resources 97 0 R endobj 9. ( "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. >> This is an action for injunctive relief. "Memphis, TN area" means Shelby County, Tennessee; Desoto County, Mississippi, and Crittenden County, Arkansas. /Annots [] hbbd`b`rfb`gb` # >> Security Personnel as Independent Contractors Part Ii: What Liability Is Incurred to the Company From Accidents Involving Independent Contractors? /Type /Pages "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. 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. 46 0 obj /Kids [65 0 R 66 0 R 67 0 R 68 0 R 69 0 R 70 0 R 71 0 R 72 0 R 73 0 R 74 0 R] 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 (ECF No. /Annots [] /CropBox [0 0 612 792] 41. /Pages 4 0 R D. P. et al., . Entry would also be made more difficult by Republic's use of long-term, automatically renewing contracts for roll-off service. /CropBox [0 0 612 792] endobj PLAINTIFF'S COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF . /Contents [182 0 R 183 0 R 184 0 R] Venue properly lies in the Southern Distri ct of Florida pursuant to 28 U.S.C. Otherwise, there may be something missed or an unintended consequence when you sue for injunction, which can can bring about dissatisfaction, regardless of who prevails. 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. /Annots [] Complaint for Injunctive Relief and Civil Penalties (pdf) (1.93 MB) Contact Us to ask a question, provide feedback, or report a problem. In addition to differences in container size, other factors distinguish roll-off waste collection from small container commercial and other types of waste collection. Florida has reported 149 confirmed cases of COVID-19 and four deaths to date, with every expectation that these numbers will rise. /Contents [270 0 R 271 0 R 272 0 R] /Annots [] /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] 23. << 5. /Resources 201 0 R /CropBox [0 0 612 792] /MediaBox [0 0 612 792] /Resources 221 0 R 49 0 obj /Annots [] /Contents [310 0 R 311 0 R 312 0 R] The City changed its name from "New << >> << >> /Annots [] Official websites use .gov MSW has physical characteristics that readily distinguish it from other liquid or solid waste. /MediaBox [0 0 612 792] /CropBox [0 0 612 792] /CropBox [0 0 612 792] The United States Army Corps of Engineers ("Corps" or "Army Corps") has unlawfully approved a massive dredging project for Port Everglades in Fort Lauderdale, Florida. "Burlington and Camden Counties, NJ area" means Burlington and Camden counties, New Jersey. /MediaBox [0 0 612 792] /Type /Page >> endobj /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] 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. /Contents [258 0 R 259 0 R 260 0 R] JFIF C >> /Type /Pages /Resources 325 0 R /MediaBox [0 0 612 792] 23 0 obj /Rotate 0 /Contents [382 0 R 383 0 R 384 0 R] /MediaBox [0 0 612 792] /Rotate 0 << endobj /Type /Page In order to obtain comparable operating efficiency, a new firm must achieve route density comparable to existing firms. x+ | ( What happens if the temporary injunction is not granted? <>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> << 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. /Contents [306 0 R 307 0 R 308 0 R] /CreationDate (D:20220824140929-04'00') << 53 0 obj /MediaBox [0 0 612 792] /Parent 14 0 R /MediaBox [0 0 612 792] /Annots [] 36 0 obj Managing Partner /Contents [138 0 R 139 0 R 140 0 R] 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. h|VrH}Weo2)RXBr|:=%ts?mlteQG :C:+rl86#m0GcfFmMb`4&;|Xy|^Q(&Y Jf#mb!nDlpfIi QB*Mg< Thus, disposal of MSW is a line of commerce, or relevant service, for purposes of analyzing the effects of the acquisition under Section 7 of the Clayton Act. >> endstream 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. 35. /Parent 8 0 R 15. /Rotate 0 /Contents [250 0 R 251 0 R 252 0 R] << 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. >> >> Typical commercial waste collection customers include office and apartment buildings and retail establishments (e.g. /Parent 7 0 R 41 0 obj 49. %PDF-1.3 % 91 0 obj /Parent 10 0 R >> /MediaBox [0 0 612 792] This is an action for injunctive and declaratory relief, costs, damages, attorney's fees, penalties, and other available statutory relief, pursuant to the Florida Deceptive and Unfair . 59. And yet the State of Florida (the State) has failed to take reasonable emergency measures necessary for voter participation in the face of this crisis. /CropBox [0 0 612 792] 0000000016 00000 n Amended Complaint "Motion") [ECF(the No. /Contents [214 0 R 215 0 R 216 0 R] ( did not involve a claim for declaratory relief. << 82 0 obj After the acquisition, Allied would control over 50 percent--and two firms over 90 percent--of the small container commercial waste hauling market, which has annual revenues of about $31 million. >> >> endobj WEST PALM BEACH DIVISION . A .gov website belongs to an official government organization in the United States. /Resources 297 0 R /Resources 341 0 R 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 [274 0 R 275 0 R 276 0 R] 20. 32. /Type /Page 61 0 obj 85 0 obj /Contents [302 0 R 303 0 R 304 0 R] 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. The customer's MSW is stored in much smaller containers (e.g., garbage bags or trash cans) and instead of FEL trucks, waste collection firms routinely use REL or side-load trucks, manned by larger crews (usually, two-or three-person teams). /Parent 8 0 R /Type /Page 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. >> Due to the high costs of transporting MSW, and the substantial travel time to other disposal facilities based on distance, natural barriers, and congested roadways, haulers of MSW from the Anderson, IN and New York City, NY areas, respectively, are limited to transfer station disposal sites located in each of their local areas. >> To handle this high volume of MSW efficiently, haulers provide commercial customers with small dumpsters for storing the waste. /Resources 349 0 R >> /Rotate 0 /MediaBox [0 0 612 792] /Annots [] /Resources 157 0 R /MediaBox [0 0 612 792] /CropBox [0 0 612 792] /Contents [362 0 R 363 0 R 364 0 R] /Contents [162 0 R 163 0 R 164 0 R] << << 79 0 obj 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. /Annots [] 73 0 obj 60. /Contents [194 0 R 195 0 R 196 0 R] /MediaBox [0 0 612 792] 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. /MediaBox [0 0 612 792] /Parent 12 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. /Resources 269 0 R /MediaBox [0 0 612 792] /Resources 337 0 R Is the injunction prohibitory or mandatory? Plaintiffs also seek temporary injunctive relief as stated in the accompanying Motion for Temporary Injunction. A party seeking an injunction under general Florida case law must demonstrate: 1) irreparable harm; 2) a clear legal right; 3) an inadequate . /Rotate 0 36. /Resources 361 0 R M`5`i`F{qZ Therefore, it should not be a decision made lightly. /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] << 63. /CropBox [0 0 612 792] (Compl . >> Plaintiff seeks temporary, preliminary, and permanent injunctive relief pursuant to Rule 65 . /Resources 253 0 R /Rotate 0 /Parent 9 0 R /Parent 9 0 R /Contents [326 0 R 327 0 R 328 0 R] /Type /Page /Resources 121 0 R 33. endobj ( /CropBox [0 0 612 792] /Resources 257 0 R Alexdex. /Contents [166 0 R 167 0 R 168 0 R] Because of the differences in the collection process, residential customers and commercial customers usually are organized into separate routes. 66. 0000000592 00000 n /Type /Page ( /Contents [110 0 R 111 0 R 112 0 R] /Resources 185 0 R >> /Parent 11 0 R endobj 52. /Contents [266 0 R 267 0 R 268 0 R] /Type /Pages 37. 5 0 obj EOs6~W\F3[_y7~r+W3nU>9YRpM/u"%1yK Ivp, Microsoft Word - 2022-08-24 - Complaint - FINAL. << 38. 21. /Type /Page /Type /Page In the Macon, GA area, the acquisition would also combine the two largest firms that compete in roll-off waste collection service. ( 61. >> /Resources 181 0 R << /Annots [] <> 80 0 obj /Parent 13 0 R /Annots [] endobj /Resources 161 0 R /Rotate 0 >> /Resources 309 0 R /Contents [206 0 R 207 0 R 208 0 R] /Rotate 0 >> In the event of a small but significant increase in the price of the disposal of MSW in the Anderson, IN or New York City, NY areas, haulers of MSW generated in each area would not turn to disposal facilities outside their area. /CropBox [0 0 612 792] 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. /Rotate 0 /Rotate 0 28. /CropBox [0 0 612 792] /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] 22. endobj >> /MediaBox [0 0 612 792] /Contents [118 0 R 119 0 R 120 0 R] /Rotate 0 /MediaBox [0 0 612 792] /Resources 365 0 R The Court has jurisdiction over this action and over the parties pursuant to 15 U.S.C. "Monmouth County, NJ area"means the City of Marlboro and Monmouth County, New Jersey. /MediaBox [0 0 612 792] 8 0 obj endobj endobj >> /Rotate 0 /Contents [226 0 R 227 0 R 228 0 R] /Type /Page /Type /Page 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. /Contents [222 0 R 223 0 R 224 0 R] /Rotate 0 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. /Resources 229 0 R endobj /Contents [406 0 R 407 0 R 408 0 R] /Parent 9 0 R /CropBox [0 0 612 792] /Parent 10 0 R /Parent 7 0 R /Parent 8 0 R Access to competitive disposal sites and reasonable disposal costs are important to providers of roll-off collection services. %PDF-1.3 % 48 0 obj ? /Type /Page /Parent 7 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. 39. /Parent 8 0 R JURISDICTION AND VENUE 13. << endobj >> /Parent 12 0 R Often businesses do not consider the implications for taking this action. /Type /Page /CropBox [0 0 612 792] 35 0 obj 1331 and 1337. >> /CropBox [0 0 612 792] << /CropBox [0 0 612 792] Professional Services Industry Legal Blog>. /Resources 317 0 R 6. /Annots [] /CropBox [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. /Count 10 >> 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. hUN@h/%FT""Qy@Kbxw81FgfvEN.tF2AiP9?{"1zQ. 64 0 obj /CropBox [0 0 612 792] /Contents [122 0 R 123 0 R 124 0 R] /Rotate 0 /Contents [106 0 R 107 0 R 108 0 R] 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. In the Albany, NY area, the proposed acquisition would reduce from four to three the number of significant competitors in the collection of small container commercial waste. 31 0 obj <>stream "Small container commercial waste collection service" means the business of collecting MSW from commercial and industrial accounts, usually in "dumpsters" (i.e., a small container with one to ten cubic yards of storage capacity), and transporting or "hauling" such waste to a disposal site by use of a front-or rear-end loader truck. /Parent 11 0 R /Rotate 0 /Annots [] Plaintiff, The Second Amendment Foundation, is a Washington Not-For-Profit This form is a Complaint for Injunctive Relief and Damages. /Rotate 0 /Type /Page /CropBox [0 0 612 792] /Annots [] The cost of transporting waste to a disposal site is often a substantial component of the cost of disposal. "0A149;>>>%.DIC; C not /Rotate 0 endobj 3601, et seq. >> 0000001469 00000 n 65. Absent injunctive relief by this Court, Defendants are likely to continue to injure consumers, reap unjust enrichment, and harm the public interest. endobj SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION In re: JOSE SANCHEZ Case No. /MediaBox [0 0 612 792] IV. >> /Parent 11 0 R 54 0 obj Complaint for Emergency Injunctive Relief in Florida Primary The global coronavirus pandemic threatens to disrupt the Presidential Preference Primary election in Florida. ( endobj /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] 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. /Parent 14 0 R C. Reduction in Competition As a Consequence of the Acquisition. 0000001994 00000 n /Rotate 0 /CropBox [0 0 612 792] 46. "Clarksville, TN area" means the City of Clarksville and Montgomery, Dickson, the northwestern part of Cheatham, and the western part of Robertson counties, Tennessee. 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. Permit restrictions often impose severe limitations on the type and amount of waste that can be disposed of at landfills. /CropBox [0 0 612 792] Garcia controll ed the MJ Companies prior to their going into receivership. /Type /Page 50. /Contents [378 0 R 379 0 R 380 0 R] /Resources 117 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. Allied and Republic directly compete in roll-off waste collection service in a number of markets nationwide, including the Macon, GA area. endobj hb```f`` $V30 1;oO_Ia`sF!gbl!O| ` /CropBox [0 0 612 792] However, temporary injunctive relief may be granted without the posting of a bond in the following situations: 1) injunctions entered "on the pleading of a municipality or the state or any officer, agency, or political subdivision thereof"; or 2) injunctions "issued solely to prevent physical injury or abuse of a natural person." The operator continues along the route, collecting MSW from each of the commercial accounts until the vehicle is full. /Resources 385 0 R endobj /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] /MediaBox [0 0 612 792] "Columbus, OH area" means the City of Columbus and Franklin and Delaware counties, Ohio. /Resources 245 0 R 34 0 obj /MediaBox [0 0 612 792] endobj ( /Type /Page 56 0 obj 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. /Parent 7 0 R /Rotate 0 47 0 obj /PageLabels 3 0 R /Parent 12 0 R 19. /Rotate 0 31. >> /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] /Annots [] /Length 10 The roll-off container, when filled, is picked up by roll-off trucks, which are uniquely well suited for roll-off waste collection, and driven to a nearby disposal site, where the container's contents are disposed. /MediaBox [0 0 612 792] 76 13 ( /Rotate 0 /Resources 145 0 R /Parent 8 0 R Injunctive relief is considered an extraordinary remedy in both State and Federal court. /MediaBox [0 0 612 792] /Annots [] /Type /Page endobj /Rotate 0 ASSOCIATION OF FLORIDA, MIGRANT CLINICIANS NETWORK, PINEROS Y . /Type /Page 20 0 obj 4. Charles B. Jimerson In each of these markets, Allied and Republic each account for a substantial share of total revenues from commercial waste collection services. << endobj If the major roll-off competitor in a market likewise precludes significant competition through the use of long-term customer contracts which automatically renew, entry by new competitors and growth from existing ones are further hindered. Is there any vagueness, or is everything extremely clear? 2322 0 obj<>stream /Resources 381 0 R << /Type /Page endobj 11. 69. See Merger Guidelines 1.51. U.S. v. Allied Waste Industries, Inc. and Republic Services, Inc. /Type /Page /Resources 357 0 R 72 0 obj Complaint for purposes of Florida Statutes Sections 501.207(5) and 95.11(3). /Contents [150 0 R 151 0 R 152 0 R] endobj 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. /Parent 11 0 R Plaintiff, PRISON LEGAL NEWS ("PLN"), a project of the Human Rights Defense . /Annots [] /Parent 12 0 R /CropBox [0 0 612 792] /MediaBox [0 0 612 792] /Kids [35 0 R 36 0 R 37 0 R 38 0 R 39 0 R 40 0 R 41 0 R 42 0 R 43 0 R 44 0 R] In the Anderson, IN area, almost all of the MSW generated is disposed of in one of three transfer stations. >> 66 0 obj 77 0 obj /Rotate 0 /Parent 7 0 R Rather, these are some additional factors to consider while determining the feasibility of this action: Will the court be able to enforce the injunction, or will it require intensive court supervision? See also Chapter 224.08, Special Acts of Florida, 1943. /Rotate 0 ( /Resources 209 0 R %PDF-1.5 /Type /Page /Contents [330 0 R 331 0 R 332 0 R] << ( ;,hn \ic6rZFi+|:GsL$KGqzed8;M+"N7i~4Dr?_1hHa:`R[B%Qm*?u9Lh=?y%x8;e$AD+xx 16. << 8. On residential routes, the crews generally hand-load the customer's MSW, typically by tossing garbage bags and emptying trash cans into the vehicle's storage section. /Contents [390 0 R 391 0 R 392 0 R] >> The acquisition would reduce from four to three the number of significant firms that compete in the collection of small container commercial waste in the Monmouth County, NJ area. >> 17. Small Container Commercial Waste Collection Service. ( /Rotate 0 This is a must-watch video before you consider whether to sue for injunction. >> /Annots [] 1 0 obj Plaintiff is a Florida resident, lives in Miami- Dade County, is sui juris, and qualifies of a protected class under the ADA, 42 U.S.C. COMPLAINT FOR INJUNCTIVE RELIEF AND SANCTIONS Plaintiff, Donald F. Walton, United States Trustee for . /Parent 9 0 R /Rotate 0 /Contents [298 0 R 299 0 R 300 0 R] Since May 7, 2021, Wilson has been the GC of a private investment firm based in Boca Raton, Florida. /Rotate 0 /Contents [262 0 R 263 0 R 264 0 R] >> << << 27 0 obj << 39 0 obj xYYoH~7"b` recB$hHjRbK6DQ]]WUMb8`}^^l,q8x1O,7~`[)gD,uq+sU+PP)>f90VY-^AEKS2t}g4 X!xH rTmvF4(,W`{kF$tC 2320 0 obj<> endobj endobj >> 12. Suing for an injunction in Florida is all about preserving the status quo. /Annots [] Filing fees are due at the time a party files a pleading to initiate a proceeding or files a pleading for relief. ]Wx C1>*yvL#uR$=I$$WJQg%=ElRS3DE27y1 G. } !1AQa"q2#BR$3br 68. 27. /MediaBox [0 0 612 792] /Contents [202 0 R 203 0 R 204 0 R] /Parent 13 0 R << 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.