/Parent 11 0 R << /Annots [] Contains legal complaint for injunctive releif and civil penalties against BCX facility Site, Jacksonville, Duval County, Florida, June 7, 2004. /Contents [330 0 R 331 0 R 332 0 R] >> /Contents [158 0 R 159 0 R 160 0 R] /MediaBox [0 0 612 792] /CropBox [0 0 612 792] 3 0 obj
/Type /Page endobj /Annots [] /Parent 9 0 R >> << "Anderson, IN area" means the City of Anderson and Madison County, Indiana. /CropBox [0 0 612 792] 2201 a nd 2202. endobj /Rotate 0 D. Entry Into Commercial Waste Collection of MSW. >> << The United States of America, acting under the direction of the Attorney General of the United States, brings this civil antitrust action to enjoin the acquisition of certain waste hauling and disposal assets by Defendants Allied Waste Industries, Inc. ("Allied") and Republic Services, Inc. ("Republic") and to obtain equitable relief and other relief as appropriate. 40. >> /MediaBox [0 0 612 792] << 53(b), empowers this Court to grant injunctive and such other relief as the Court may deem appropriate to halt Plaintiff, PRISON LEGAL NEWS ("PLN"), a project of the Human Rights Defense . /MediaBox [0 0 612 792] /Parent 13 0 R /Parent 12 0 R /Resources 157 0 R Professional Services Industry Legal Blog>. /CropBox [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. 83 0 obj /MediaBox [0 0 612 792] /Parent 8 0 R JURISDICTION AND VENUE 2. 42 0 obj endobj 2320 0 obj<>
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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. << /CropBox [0 0 612 792] /Contents [386 0 R 387 0 R 388 0 R] /Type /Page /Parent 7 0 R /Annots [] 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. endobj 15. /Annots [] /Type /Page ( This is a must-watch video before you consider whether to sue for injunction. /Contents [174 0 R 175 0 R 176 0 R] Virtually all of the MSW generated in each of these areas is disposed of in transfer stations in each of their local areas. . /Rotate 0 "Macon, GA area" means the City of Macon and Bibb, Peach and parts of Houston, Jones and Monroe counties, Georgia. /Type /Page /MediaBox [0 0 612 792] Suing for an injunction in Florida is all about preserving the status quo. /Rotate 0 << endobj 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. COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF . 59. << << /Parent 8 0 R /Annots [] clearly appears from specific facts shown by affidavit or by verified complaint that immediate or /Annots [] endobj
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. /PageLabels 3 0 R 31. 7.) 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. 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. endobj /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. /MediaBox [0 0 612 792] Rather, its about dealing with the future, not something that happened in the past. Private waste haulers typically contract directly with customers for the collection of waste generated by commercial accounts. stream
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/Parent 10 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? /Annots [] /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] 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. Each of these areas is a section of the country, or relevant geographic market, for purposes of analyzing the effects of the acquisitions under Section 7 of the Clayton Act. /MediaBox [0 0 612 792] /Subtype /XML Often businesses do not consider the implications for taking this action. "0A149;>>>%.DIC; C /Parent 4 0 R 82 0 obj prescribed by these rules and by section 51.011, Florida Statutes, the statutory provision shall govern. 0000002992 00000 n
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/Annots [] /Parent 13 0 R /Resources 133 0 R << /Type /Page ( 49 0 obj In its 1998 fiscal year, Republic reported total revenues of approximately $1.8 billion. /Rotate 0 /Contents [142 0 R 143 0 R 144 0 R] /CropBox [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 . /Resources 269 0 R << /Parent 4 0 R << /Rotate 0 /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] /Resources 153 0 R /Type /Page 43 0 obj "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. /MediaBox [0 0 612 792] 84 0 obj Less frequently, haulers may use more maneuverable, but less efficient, rear-end loader ("REL") trucks, especially in those areas in which a collection route includes narrow alleyways or streets. /CropBox [0 0 612 792] /Type /Page /Count 10 /Resources 221 0 R /Rotate 0 /CropBox [0 0 612 792] 42. << /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] /CropBox [0 0 612 792] /Rotate 0 endobj endobj >> /Annots [] Allied and Republic directly compete in roll-off waste collection service in a number of markets nationwide, including the Macon, GA area. 16 0 obj In addition, Wilson traveled at least twice to Florida for work-related trips in 2019, including once to Miami and Tampa in or around the spring of 2019 and once to Orlando in or around November or December 2019. An MSW disposal facility must be located on approved types of land and operated under prescribed procedures. 72 0 obj /CropBox [0 0 612 792] endobj /Type /Page /Resources 265 0 R ( >> /Parent 13 0 R Managing Partner The Corps' environmental analysis for this project is based on the same assumptions and In order to obtain comparable operating efficiency, a new firm must achieve route density comparable to existing firms. 31 0 obj /Type /Page /CropBox [0 0 612 792] >> To access the presentation, visit YouTube or click play on the embedded image below. /MediaBox [0 0 612 792] /Rotate 0 >> 7. 27. /CropBox [0 0 612 792] /Type /Page 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. 0000002929 00000 n
>> ( 21-81099-CIV-CANNON/Reinhart . /Annots [] /Rotate 0 In addition, be sure you have competent, knowledgeable and experienced counsel in your corner. 44. In the Macon, GA market, Allied and Republic each account for a substantial share of total revenues from roll-off waste collection services. /Parent 8 0 R /Contents [234 0 R 235 0 R 236 0 R] /Metadata 2 0 R 61 0 obj endobj /CropBox [0 0 612 792] /Resources 377 0 R See Laws of Florida, Ch. /Rotate 0 /Resources 353 0 R << << /MediaBox [0 0 612 792] <<14CA263718F8354CB34DA495C0495A29>]>>
/Resources 197 0 R 38 0 obj 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. 53 0 obj 20. << hb```"FN%n010pKsg``Z ^^@Y"bL38/4F `}
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/Type /Page 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. << <<21a9e19eaa9d774d8bfb9315a3d3f5db>]>>
5 0 obj /Contents [298 0 R 299 0 R 300 0 R] The Court has jurisdiction over this action and over the parties pursuant to 15 U.S.C. << An official website of the United States government. ( << /Parent 11 0 R What impact will it have on third-parties and employees? endstream construction debris) and volume, roll-off waste is deposited by the customer/generator into a disposal container (usually 20 to 40 cubic yards in size) which is larger than those routinely used in small container commercial collection (usually one to 10 cubic yards in size). /CropBox [0 0 612 792] 6th Street Ft. Lauderdale, FL 33301 Defendants. /CropBox [0 0 612 792] 94 0 obj >> /Annots [] >> /Rotate 0 /Annots [] /Resources 381 0 R endobj 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. /Annots [] 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. /CropBox [0 0 612 792] /MediaBox [0 0 612 792] /Contents [334 0 R 335 0 R 336 0 R] >> /Parent 4 0 R >> << "Augusta, GA area" means the City of Augusta, Richmond and Columbia counties, Georgia, and Aiken County, South Carolina. /MediaBox [0 0 612 792] /Resources 281 0 R /Parent 14 0 R /CropBox [0 0 612 792] provide preliminary and permanent injunctive relief pursuant to Rules 57 and 64 of the Federal Rules of Civil Procedure and 28 U.S.C. /Rotate 0 /Contents [358 0 R 359 0 R 360 0 R] /Annots [] /MediaBox [0 0 612 792] /Resources 201 0 R /Resources 145 0 R << /Parent 14 0 R For instance, in many states, most MSW is disposed of in landfills, which are permitted under and regulated by the state. << /CropBox [0 0 612 792] << For a number of reasons, landfills may not be located close to where the waste is generated. %PDF-1.6 endobj >> endobj /Type /Page /CropBox [0 0 612 792] /Parent 10 0 R 4. have exclusive jurisdiction: (a) In all actions at law cognizable by the county . 31 0 obj
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5. /Annots [] /Rotate 0 ( /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. /Contents [282 0 R 283 0 R 284 0 R] In each of these markets, Allied and Republic each account for a substantial share of total revenues from commercial waste collection services. 95 0 obj << /Type /Page This form is a Complaint for Injunctive Relief and Damages. /Contents [182 0 R 183 0 R 184 0 R] /Rotate 0 /Annots [] /Parent 10 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. 0000000016 00000 n
/Type /Pages endobj /Annots [] 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. 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. 25 0 obj >> << /Rotate 0 >> << ( endobj 69. /Parent 4 0 R stores and restaurants). /Creator (PScript5.dll Version 5.2.2) << (2001). 2 0 obj
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/Count 10 /Parent 4 0 R /Type /Page Waiver recipients are entitled to continuation of services that they are currently receiving through the completion of the fair hearing /Annots [] << /Contents [262 0 R 263 0 R 264 0 R] There are no good substitutes for MSW disposal. stream
/Parent 9 0 R << Plaintiffs Rural & Migrant Ministry, Alianza Nacional De Campesinas, El Comite . 41 0 obj This is an action for injunctive relief. Does the temporary injunction preserve the Status Quo or does it make a change? >> 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. /Contents [402 0 R 403 0 R 404 0 R] 6 0 obj /MediaBox [0 0 612 792] %
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. /Annots [] Complaint for Injunctive Relief Case (s): U.S. v. Allied Waste Industries, Inc. and Republic Services, Inc. /Resources 225 0 R On September 8, 2021, the Court, by consent, entered a preliminary injunction against Garcia. 22 and 28 U.S.C. ( 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. 12.
>> 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. 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. Defendant is defined as a "Public Accommodation" within meaning of Title III } !1AQa"q2#BR$3br /Length 3282 58 0 obj /MediaBox [0 0 612 792] /Type /Page Markets in which the HHI is between 1000 and 1800 points are considered to be moderately concentrated, and those in which the HHI is in excess of 1800 points are considered to be highly concentrated. /Kids [25 0 R 26 0 R 27 0 R 28 0 R 29 0 R 30 0 R 31 0 R 32 0 R 33 0 R 34 0 R] 71 0 obj /Contents [378 0 R 379 0 R 380 0 R] "Memphis, TN area" means Shelby County, Tennessee; Desoto County, Mississippi, and Crittenden County, Arkansas. /Type /Page >> /Type /Page Does the injunction provide broad or limited relief? /CropBox [0 0 612 792] ]Wx C1>*yvL#uR$=I$$WJQg%=ElRS3DE27y1 G. /Type /Page endobj 0000003946 00000 n
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21. 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. /Parent 8 0 R /MediaBox [0 0 612 792] /Type /Page ( << >> /Type /Page ( ( /Parent 11 0 R Republic is engaged in providing waste collection and disposal services throughout the United States. /Annots [] What happens if the temporary injunction is not granted? If the major roll-off collection competitor in a market also controls the primary disposal site(s) therein, other roll-off competitors are at a large disadvantage and entry is difficult. /Contents [278 0 R 279 0 R 280 0 R] Entry would also be made more difficult by Republic's use of long-term, automatically renewing contracts for roll-off service. /Resources 401 0 R Therefore, its important to not consider it a tool for righting a wrong. Jurisdiction is conferred on this Court by Chapters 26, 34, 86.011. /Parent 9 0 R In this presentation, Jimerson Birr AssociateAustin B. Calhouncovers Florida law on injunctive relief as a remedy, the process for seeking and obtaining injunctive relief through the judicial system, pre-litigation considerations, and enforcement of an injunction order once entered. 8. /Rotate 0 << /Rotate 0 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. << /MediaBox [0 0 612 792] After the acquisition, Allied would control over 40 percent and two firms would control over 65 percent of the small container commercial waste hauling market, which has annual revenues of about $5 million. In 1998, for example, these three transfer stations disposed of over 85 percent of the MSW generated in the Anderson, IN area. << >> /CropBox [0 0 612 792] /CropBox [0 0 612 792] 32. 74 0 obj /Rotate 0 After the acquisition, Republic would control over 60 percent of the roll-off hauling market, which has annual revenues of about $8 million. 68 0 obj In the Macon, GA area, the acquisition would also combine the two largest firms that compete in roll-off waste collection service. /MediaBox [0 0 612 792] <>>>
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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. If you are interested in speaking to a Jimerson Birr lawyer or want general information about the firm, our practice areas, lawyers, publications, or events, please contact us via email or telephone for assistance at (904) 389-0050. /Nums [0 6 0 R] ( << It is calculated by squaring the market share of each firm competing in the market and then summing the resulting numbers. /Resources 189 0 R /Parent 11 0 R 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. /Rotate 0 "New York City, NY area" means the Borough of Brooklyn, New York. /CropBox [0 0 612 792] endobj 79 0 obj 0000001536 00000 n
endobj /Annots [] The global coronavirus pandemic threatens to disrupt the Presidential /Rotate 0 25, to prevent and restrain the violation by defendants of Section 7 of the Clayton Act, 15 U.S.C. << /Rotate 0 /Rotate 0 41. /Contents [238 0 R 239 0 R 240 0 R] endobj .t. 28. /Parent 13 0 R 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. judgment, and preliminary and permanent injunctive relief and damages. /Rotate 0 COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF Introduction 1. /Parent 8 0 R /Contents [274 0 R 275 0 R 276 0 R] << 13(b) of the Federal Trade Commission Act ("FTC Act"), 15 U.S.C. /MediaBox [0 0 612 792] endobj /Contents [246 0 R 247 0 R 248 0 R] "MSW" means municipal solid waste, a term of art used to describe solid putrescible waste generated by households and commercial establishments such as retail stores, offices, restaurants, warehouses, and non-manufacturing activities in industrial facilities. endobj
Typical commercial waste collection customers include office and apartment buildings and retail establishments (e.g. /CropBox [0 0 612 792] 39 0 obj /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 10 0 R ( /MediaBox [0 0 612 792] ( Copyright 2008-2023 Jimerson Birr, P.A. hUN@h/%FT""Qy@Kbxw81FgfvEN.tF2AiP9?{"1zQ. /Resources 273 0 R /Resources 389 0 R /Rotate 0 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. /Type /Catalog 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 . In the Macon, GA area, the proposed acquisitions would result in Republic controlling more than 60 percent of the roll-off waste collection market at the same time it owns the two primary disposal options which any roll-off competitor would most likely use. . /Author (JacqmeinV) 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. %%EOF
/CropBox [0 0 612 792] /Count 10 63 0 obj 45], filed on August 192021, . /Contents [350 0 R 351 0 R 352 0 R] /Rotate 0 /Annots [] endobj >> << Thus, small container commercial 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. 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. Obtaining a permit to construct a new disposal facility or to expand an existing one is a costly and time-consuming process, which typically takes many years to conclude. 29. 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. Small container commercial service vehicles routinely employ compaction systems on the truck to increase storage capacity, and can empty numerous small containers located on a scheduled route before being driven to a disposal site. 51. /Annots [] /Rotate 0 /Rotate 0 Venue is therefore proper in this district under Section 12 of the Clayton Act, 15 U.S.C. >> endobj 2320 14
In addition, a FEL or REL vehicle cannot be efficiently driven long distances without collecting significant amounts of MSW, which makes it economically impractical for a small container commercial waste collection firm to serve metropolitan areas from a distant base. /Type /Page <>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>>
>> Therefore, it should not be a decision made lightly. 76 13
/MediaBox [0 0 612 792] A .gov website belongs to an official government organization in the United States. /Annots [] /CropBox [0 0 612 792] /MediaBox [0 0 612 792] 14. /Type /Page /Parent 9 0 R >> 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." 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. 22408. /CropBox [0 0 612 792] /Rotate 0 /Type /Page /CropBox [0 0 612 792] >> /Type /Pages 4. 55 0 obj endobj >> 21. There may be disclosure of confidential information such as trade secrets. /Resources 97 0 R These differences mean that roll-off waste collection firms can profitably increase their charges for roll-off waste collection services without losing significant sales or revenues to firms engaged in the provision of other types of waste collection services. /Contents [306 0 R 307 0 R 308 0 R] >> $4%&'()*56789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz r! /Annots [] 39. endobj /MediaBox [0 0 612 792] endobj << endobj 45. >> 13. 66 0 obj 43. 1114 Trademark Infringement . 22. 0000006750 00000 n
/Resources 325 0 R >> /MediaBox [0 0 612 792] /CropBox [0 0 612 792] endobj /Rotate 0 endobj >> /Type /Page Share sensitive information only on official, secure websites. /Contents [150 0 R 151 0 R 152 0 R] 47 0 obj /MediaBox [0 0 612 792] /Contents [214 0 R 215 0 R 216 0 R] IV. provide relief to all the individuals affected by APD's action. /Type /Page /Rotate 0 33 0 obj Plaintiff seeks temporary, preliminary, and permanent injunctive relief pursuant to Rule 65 . The county court may issue a temporary and permanent injunction where appropriate for violation of ss. >> /Rotate 0 >> >> << 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;