"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. /Annots [] The length of the presentation is 46:09. /Annots [] /MediaBox [0 0 612 792] /Type /Page /CropBox [0 0 612 792] /CropBox [0 0 612 792] /Annots [] After the acquisition, Republic would control over 85 percent of the small container commercial waste hauling market, which has annual revenues of about $5 million. /Parent 7 0 R /Type /Page xb```c``b`f`0gg@ ~G@|*{jd`q%T3e83:! @`HsXD|",e0`A 21. 90 0 obj 69 0 obj Contains legal complaint for injunctive releif and civil penalties against BCX facility Site, Jacksonville, Duval County, Florida, June 7, 2004. /Type /Page endobj /MediaBox [0 0 612 792] /Parent 14 0 R /MediaBox [0 0 612 792] >> /Annots [] /Rotate 0 #%$""!&+7/&)4)! /Type /Metadata 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. trailer /Type /Page /CropBox [0 0 612 792] /CropBox [0 0 612 792] /Annots [] /CropBox [0 0 612 792] << /Contents [246 0 R 247 0 R 248 0 R] /Rotate 0 endobj 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. 31. 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. PDF United States District Court Middle District of Florida Tampa Division >> /Type /Page /Type /Page /Type /Pages : 01-42230-BKC-AJC . /Contents [342 0 R 343 0 R 344 0 R] /CropBox [0 0 612 792] >> Therefore, its important to not consider it a tool for righting a wrong. This form is a Complaint for Injunctive Relief and Damages. 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. 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. /Parent 8 0 R 5. /MediaBox [0 0 612 792] /Contents [378 0 R 379 0 R 380 0 R] 17. 3. 56. /Annots [] Does the temporary injunction preserve the Status Quo or does it make a change? /CropBox [0 0 612 792] %%EOF PDF United States District Court Northern District of Florida Pensacola /Type /Page /Parent 10 0 R Z( /Annots [] 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. /Resources 237 0 R 0000003868 00000 n 86 0 obj /Type /Page /Contents [250 0 R 251 0 R 252 0 R] 8. 0 >> 75 0 obj /Rotate 0 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. >> 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." endobj /Contents [218 0 R 219 0 R 220 0 R] endobj >> /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] /Rotate 0 /Resources 289 0 R PDF COMPLAINT FOR PERMANENT INJUNCTION - United States Department of Justice 4. /MediaBox [0 0 612 792] endstream endobj 2333 0 obj<>/W[1 1 1]/Type/XRef/Index[246 2074]>>stream 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. /Contents [174 0 R 175 0 R 176 0 R] /Annots [] << /Annots [] for the Middle Distrct of Florida, hereby files this complaint for permanent injunction and alleges as follows: 1. _______/s/____________________ Donna E. Patterson Deputy Assistant Attorney General, _________/s/__________________ Constance K. Robinson Director of Operations and Merger Enforcement, ________/s/___________________ J. Robert Kramer II Chief, Litigation II Section, _________/s/__________________ Willie L. Hudgins Assistant Chief, Litigation II Section, ___________/s/________________ Arthur A. Feiveson IL Bar # 3125793, __________/s/_________________ Michael K. Hammaker DC Bar # 233684, __________/s/_________________ Chinita M. Sinkler MD Bar, U.S. Department of Justice Antitrust Division, Litigation II Section 1401 H Street, NW, Suite 3000 Washington, D.C. 20530 (202) 307-0924. Is there any vagueness, or is everything extremely clear? << COMPLAINT FOR INJUNCTIVE RELIEF AND SANCTIONS Plaintiff, Donald F. Walton, United States Trustee for . Download the PDF of the Complaint IN THIS PUBLICATION Summary Issues COVID-19 /Type /Pages 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. The global coronavirus pandemic threatens to disrupt the Presidential /Parent 10 0 R 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. 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. /Annots [] In its 1998 fiscal year, Republic reported total revenues of approximately $1.8 billion. /Type /Page >> GsYzQh50ee' Anyone who fails to dispose of MSW in an approved facility can be subject to severe civil and criminal penalties. /Resources 241 0 R /Type /Page THIS COURT'S POWER TO GRANT RELIEF 84. 26. >> US District Court for the Southern District of Florida: Presiding Judge: Raag Singhal: Nature of Suit: Trademark: Cause of Action: 15 U.S.C. /Length 10 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. /Type /Page 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. /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] 41. 66 0 obj CASE NO. MSW has physical characteristics that readily distinguish it from other liquid or solid waste. /Resources 113 0 R >> /CropBox [0 0 612 792] 93 0 obj To access the presentation, visit YouTube or click play on the embedded image below. /Type /Page PDF Motion for Summary Judgment - Liberty Counsel ( /Type /Page 12. /MediaBox [0 0 612 792] <<14CA263718F8354CB34DA495C0495A29>]>> /Contents [186 0 R 187 0 R 188 0 R] 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. /CropBox [0 0 612 792] There could be a negative impact on the plaintiffs public image. /Annots [] endobj 0000001149 00000 n ? /Parent 13 0 R /Annots [] /Count 10 /Rotate 0 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. /Contents [270 0 R 271 0 R 272 0 R] Firms that compete in the disposal of MSW generated in the Anderson, IN or New York City, NY areas can profitably increase their charges for disposal of MSW generated in each area without losing significant sales to more distant disposal sites. 26 0 obj endobj IV. /Rotate 0 /Contents [166 0 R 167 0 R 168 0 R] >> Jimerson Birr welcomes inquiries from the media and do our best to respond to deadlines. ( "Memphis, TN area" means Shelby County, Tennessee; Desoto County, Mississippi, and Crittenden County, Arkansas. endstream /Annots [] /CropBox [0 0 612 792] 53(b), empowers this Court to grant injunctive and such other relief as the Court may deem appropriate to halt 12. prices charged by roll-off waste collection firms in the Macon, GA area market will likely increase. stream endstream endobj 29 0 obj <>stream Likewise, roll-off customers generate volumes of waste which are too large to be serviced by a FEL truck on a pre-scheduled commercial route. /Parent 12 0 R 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] << /Type /Page Waiver recipients are entitled to continuation of services that they are currently receiving through the completion of the fair hearing In the United States District Court for The Southern District of New York << K.A%aut\@Uaa[pVWnOe 21. 18. << 67. /Contents [134 0 R 135 0 R 136 0 R] /Annots [] /CropBox [0 0 612 792] 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. << /Contents [258 0 R 259 0 R 260 0 R] /Creator (PScript5.dll Version 5.2.2) /MediaBox [0 0 612 792] >> /Annots [] << /MediaBox [0 0 612 792] /Type /Page 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. 37 0 obj . PDF COMPLAINT FOR INJUNCTIVE RELIEF AND SANCTIONS PARTIES - The Wall Street 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. /Annots [] ( << /Annots [] Complaint for Emergency Injunctive Relief in Florida Primary } !1AQa"q2#BR$3br /CropBox [0 0 612 792] /Rotate 0 Rather, its about dealing with the future, not something that happened in the past. << endobj /Resources 293 0 R /Resources 109 0 R /MediaBox [0 0 612 792] endobj /MediaBox [0 0 612 792] 21 0 obj 5.) << << /MediaBox [0 0 612 792] /Filter /FlateDecode VERIFIED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF Introduction 1. "Nashville, TN area" means the City of Nashville and Davidson, Sumner, Williamson, Rutherford, Wilson, the southeastern part of Robertson, and the eastern part of Cheatham counties, Tennessee. endobj The operator continues along the route, collecting MSW from each of the commercial accounts until the vehicle is full. /MediaBox [0 0 612 792] 67 0 obj /Parent 4 0 R >> endobj 38. (ECF No. /Parent 13 0 R << /CropBox [0 0 612 792] >> endobj ]Wx C1>*yvL#uR$=I$$WJQg%=ElRS3DE27y1 G. 22. 50 0 obj /Resources 181 0 R /Rotate 0 64. 8 0 obj << 44 0 obj 10941 and Laws of Florida, Ch. /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] 58 0 obj /Annots [] /CropBox [0 0 612 792] << /Rotate 0 PDF United States District Court Southern District of Florida Case No /Annots [] /CropBox [0 0 612 792] /MediaBox [0 0 612 792] endobj << /Resources 369 0 R endstream endobj startxref _l {:\! D. P. et al., . Republic is engaged in providing waste collection and disposal services throughout the United States.