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complaint for injunctive relief florida

0000001536 00000 n endobj 77 0 obj /CropBox [0 0 612 792] Amended Complaint "Motion") [ECF(the No. /MediaBox [0 0 612 792] /Parent 4 0 R /Annots [] /Rotate 0 1 0 obj 18 0 obj /Resources 313 0 R /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] <> 1 1 On February 7, 2023 and February 16, 2023, Plaintiff filed motions for preliminary 2 injunctive relief. 28 0 obj 69. /Annots [] 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. endobj 0000006750 00000 n In its 1998 fiscal year, Republic reported total revenues of approximately $1.8 billion. /Contents [374 0 R 375 0 R 376 0 R] Roll-off waste collection customers typically generate bulkier items of waste and/or substantially larger volumes of waste than residential or small container commercial waste customers from sources such as construction sites or industrial plants. 56. 25 0 obj In such instances, the waste is brought to a nearby transfer station where it is compacted and combined with other waste and then transported to a more distant permanent disposal site. << /Contents [106 0 R 107 0 R 108 0 R] /CropBox [0 0 612 792] endobj In the Macon, GA area, the acquisition would reduce from two to one the number of significant firms that compete in the collection of small container commercial waste. /Contents [122 0 R 123 0 R 124 0 R] /Contents [158 0 R 159 0 R 160 0 R] /Parent 8 0 R An individual commercial customer typically generates substantially more MSW than a residential customer. Plaintiffs Rural & Migrant Ministry, Alianza Nacional De Campesinas, El Comite . /Parent 11 0 R Allied and Republic directly compete in the disposal of waste in a number of markets nationwide, including the Anderson, IN; New York City, NY; and Macon, Georgia areas. endobj Secure .gov websites use HTTPS In the Albany, NY area, the proposed acquisition would reduce from four to three the number of significant competitors in the collection of small container commercial waste. "Burlington and Camden Counties, NJ area" means Burlington and Camden counties, New Jersey. endobj This is an action for permanent injunctive relief, declaratory relief, and /Contents [330 0 R 331 0 R 332 0 R] endobj ;,hn \ic6rZFi+|:GsL$KGqzed8;M+"N7i~4Dr?_1hHa:`R[B%Qm*?u9Lh=?y%x8;e$AD+xx 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. >> endobj 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. /Annots [] /Annots [] 1391, . /Annots [] ( Share sensitive information only on official, secure websites. 2320 0 obj<> endobj /Annots [] /Annots [] 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 . /Contents [314 0 R 315 0 R 316 0 R] /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] 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. /Rotate 0 /Resources 381 0 R << 70 0 obj 63. 32. endstream endobj 29 0 obj <>stream Therefore, its important to not consider it a tool for righting a wrong. 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. endobj >> /MediaBox [0 0 612 792] /Rotate 0 36. /Rotate 0 /Contents [406 0 R 407 0 R 408 0 R] >> /CropBox [0 0 612 792] endobj endobj >> See also Chapter 224.08, Special Acts of Florida, 1943. /Contents [234 0 R 235 0 R 236 0 R] /Contents [354 0 R 355 0 R 356 0 R] /MediaBox [0 0 612 792] << 22 and 28 U.S.C. << /Type /Page /Contents [290 0 R 291 0 R 292 0 R] 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. 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. Complaint for purposes of Florida Statutes Sections 501.207(5) and 95.11(3). /Rotate 0 ( /CropBox [0 0 612 792] >> /Annots [] /Rotate 0 /Parent 14 0 R %%EOF >> endobj /Rotate 0 /CropBox [0 0 612 792] Garcia is a resident of North Lauderdale, Fl orida. << 29. /Parent 10 0 R /Type /Page 7 0 obj 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. 89 0 obj /Rotate 0 /Resources 165 0 R >> /Parent 7 0 R 25. hbbd`b`rfb`gb` # "Memphis, TN area" means Shelby County, Tennessee; Desoto County, Mississippi, and Crittenden County, Arkansas. /Rotate 0 ( 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. /Parent 12 0 R 23 0 obj ( 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. /Rotate 0 /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] Because of its characteristics (e.g. /CropBox [0 0 612 792] CASE NO. The Anderson, IN and New York City, NY areas are therefore sections of the country, or relevant geographic markets, for purposes of analyzing the competitive effects of the acquisition under Section 7 of the Clayton Act. endobj ( ( << /Resources 153 0 R /Resources 229 0 R 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. 13(b) of the Federal Trade Commission Act ("FTC Act"), 15 U.S.C. /Type /Page 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. >> /CropBox [0 0 612 792] /Type /Pages /Type /Page >> Filing fees $ 402.00 receipt number AFLSDC-16386893, filed by OMEGA SA.. (Attachments: #1 . 53. 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. endobj /Rotate 0 6. << /Type /Page /Rotate 0 /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] 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. x1 04) F&`/MFWxC. /Type /Page /MediaBox [0 0 612 792] endobj /Resources 277 0 R /Parent 4 0 R << /Rotate 0 62. 71 0 obj 57. 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. 16. 6108, to obtain temporary, preliminary, and permanent injunctive relief, rescission or reformation of contracts, restitution, the refund of monies paid, disgorgement of ill-gotten . 19 0 obj /Annots [] /CropBox [0 0 612 792] /MediaBox [0 0 612 792] Plaintiff, PRISON LEGAL NEWS ("PLN"), a project of the Human Rights Defense . /MediaBox [0 0 612 792] /Resources 397 0 R /CropBox [0 0 612 792] /CropBox [0 0 612 792] 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. /MediaBox [0 0 612 792] Haulers, therefore, generally establish garages and related facilities within each major local area served. ( 36 0 obj /Contents [394 0 R 395 0 R 396 0 R] << /Type /Page /Type /Page This is a civil action brought by the United States of America to enjoin defendant . 76 0 obj <> endobj /Resources 265 0 R << 12. /Count 10 45 0 obj ( 3 0 obj << 14 0 obj An MSW disposal facility must be located on approved types of land and operated under prescribed procedures. Republic would thus be in a position to raise the disposal costs at the landfill and transfer stations which it would own to any new or existing roll-off collection competitor in the Macon, GA area. 62 0 obj 82 0 obj 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. 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. /Parent 12 0 R ( endobj A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. 86 0 obj 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. Significant new entry into the disposal of MSW in the Anderson, IN and New York City, NY areas would be difficult and time-consuming. >> /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] 50 0 obj /Filter /FlateDecode Professional Services Industry Legal Blog>. 54 0 obj x+ | >> 72 0 obj The extension of vote-by-mail options and other accommodations at polling places is necessary. /Rotate 0 $4%&'()*56789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz r! endobj /CropBox [0 0 612 792] 0000001641 00000 n 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. endobj >> /Contents [254 0 R 255 0 R 256 0 R] /Resources 109 0 R (Compl . << Waiver recipients are entitled to continuation of services that they are currently receiving through the completion of the fair hearing endobj /Resources 149 0 R Complaint for Injunctive Relief and Civil Penalties (pdf) (1.93 MB) Contact Us to ask a question, provide feedback, or report a problem. << 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. /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] Judgment for Permanent Injunctive Relief against MJ Taxes on October 1, 2021. /Parent 10 0 R stores and restaurants). endobj This form is a Complaint for Injunctive Relief and Damages. /Annots [] 0000000592 00000 n clearly appears from specific facts shown by affidavit or by verified complaint that immediate or 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." /Contents [294 0 R 295 0 R 296 0 R] startxref /CropBox [0 0 612 792] /Contents [194 0 R 195 0 R 196 0 R] Filing 1 COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. ( 6. /Annots [] 61 0 obj 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. << %PDF-1.4 % ( 40 0 obj 2 0 obj /Rotate 0 There may be disclosure of confidential information such as trade secrets. Defendant is defined as a "Public Accommodation" within meaning of Title III 22408. 7402(a) to prevent such conduct. 63 0 obj startxref "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. 0000001994 00000 n endobj /Parent 10 0 R Plaintiff seeks temporary, preliminary, and permanent injunctive relief pursuant to Rule 65 . 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. 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. endobj /MediaBox [0 0 612 792] /Parent 14 0 R << 9. << 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. /MediaBox [0 0 612 792] /Rotate 0 ( 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? 49. >> PLAINTIFF'S COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF . Small Container Commercial Waste Collection Service. /MediaBox [0 0 612 792] 33 0 obj /Parent 4 0 R /Rotate 0 /Type /Pages /Type /Page >> /Type /Page 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 [] /Parent 4 0 R Florida has reported 149 confirmed cases of COVID-19 and four deaths to date, with every expectation that these numbers will rise. /Resources 201 0 R /MediaBox [0 0 612 792] /Rotate 0 >> /Resources 241 0 R 2 0 obj The President of the United States and the Governor of Florida have each declared a state of emergency. /Resources 245 0 R The Court has jurisdiction over this action and over the parties pursuant to 15 U.S.C. >> endobj This document is available in two formats: this web page (for browsing content) and. /Type /Page "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. << judgment, and preliminary and permanent injunctive relief and damages. << /Rotate 0 >> Anderson, IN and New York City, NY are two such areas. /MediaBox [0 0 612 792] 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. It is engaged in providing waste collection and disposal services throughout the United States. 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 . Very often courts do not grant injunctions if there is not a lot of specificity and practicality in the request for an injunction. /MediaBox [0 0 612 792] /Type /Page /Annots [] endobj Section 13(b) of the FTC Act, 15 U.S.C. ? /Resources 173 0 R endobj /Annots [] >> 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 161 0 R 11 0 obj endobj 23. Therefore, it should not be a decision made lightly. /Count 10 /Parent 11 0 R /CropBox [0 0 612 792] /Rotate 0 /Rotate 0 After the acquisition, Allied would control over 55 percent--and two firms over 90 percent--of the small container commercial waste hauling market, which has annual revenues of about $28 million. /Annots [] /MediaBox [0 0 612 792] /Annots [] /Rotate 0 /Count 10 /MediaBox [0 0 612 792] %PDF-1.5 % /Rotate 0 >> /Contents [154 0 R 155 0 R 156 0 R] /Type /Page 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. /Resources 329 0 R 2. /Type /Page /Resources 113 0 R >> /MediaBox [0 0 612 792] 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. /Annots [] /Type /Page /Type /Page endobj trailer << 0000003868 00000 n /Rotate 0 trailer << /Resources 121 0 R /MediaBox [0 0 612 792] 76 0 obj /MediaBox [0 0 612 792] 73 0 obj /CreationDate (D:20220824140929-04'00') /CropBox [0 0 612 792] /Producer <4163726F6261742044697374696C6C65722032322E30202857696E646F7773293B206D6F646966696564207573696E67206954657874AE20372E312E3620A9323030302D323031392069546578742047726F7570204E56202841646D696E697374726174697665204F6666696365206F662074686520556E697465642053746174657320436F757274733B206C6963656E7365642076657273696F6E29> /Contents [358 0 R 359 0 R 360 0 R] /Parent 8 0 R ( 5 0 obj /Annots [] >> 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. The United States is entitled to injunctive relief under 26 U.S.C. /CropBox [0 0 612 792] /Count 10 The front-end load containers used by small container commercial collection customers cannot be serviced by roll-off trucks. /MediaBox [0 0 612 792] ASSOCIATION OF FLORIDA, MIGRANT CLINICIANS NETWORK, PINEROS Y . /Parent 14 0 R 2201 a nd 2202. <<14CA263718F8354CB34DA495C0495A29>]>> 5. /Contents [342 0 R 343 0 R 344 0 R] %PDF-1.3 % 26 0 obj /Rotate 0 15. endobj << << 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. /Rotate 0 . /Rotate 0 << endobj Therefore, the video continues on this topic by explaining: A suit for injunction is an extraordinary remedy for businesses and individuals alike. << << /Rotate 0 22 and 28 U.S.C. 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. /Parent 13 0 R Rather, its about dealing with the future, not something that happened in the past. >> /Annots [] << Venue is proper in the Circuit Court of the Seventh Judicial Circuit, in and for 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. /Parent 9 0 R In exchange, pursuant to other agreements, Republic would acquire from Allied: disposal assets in Anderson, Indiana; hauling assets in Columbus, Ohio; hauling assets in Lakeland, Florida; hauling assets in Louisville, Kentucky and Sellersburg, Indiana; hauling and disposal assets in Macon, Georgia; and hauling assets in Monmouth, Burlington and Camden counties, New Jersey. /Rotate 0 ( >> >> % /Rotate 0 /Type /Page In the Anderson, IN area, almost all of the MSW generated is disposed of in one of three transfer stations. << 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. /Annots [] << endobj Does the injunction provide broad or limited relief? /CropBox [0 0 612 792] These differences mean that small container commercial waste collection firms can profitably increase their charges for small container commercial waste collection services without losing significant sales or revenues to firms engaged in the provision of other types of waste collection services. /Resources 233 0 R >> /CropBox [0 0 612 792] ( endobj /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] /Type /Page /Annots [] /Type /Page /Annots [] /Type /Page 53(b), to secure preliminary and permanent injunctive relief, rescission of contracts, restitution, disgorgement, and other . Security Personnel as Independent Contractors Part Ii: What Liability Is Incurred to the Company From Accidents Involving Independent Contractors? >> /Parent 14 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. /Type /Page On February 10, 2023, the Court screened the 27 First Amended Complaint and dismissed it for failure to state a claim, with leave to amend within 28 thirty days. Allied is a Delaware corporation with its principal office in Scottsdale, Arizona. /Parent 12 0 R Injunctive relief is considered an extraordinary remedy in both State and Federal court. xref 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. In addition to differences in container size, other factors distinguish roll-off waste collection from small container commercial and other types of waste collection. /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] /Type /Page /MediaBox [0 0 612 792] >> 25 0 obj <> endobj Anyone who fails to dispose of MSW in an approved facility can be subject to severe civil and criminal penalties. "Clarksville, TN area" means the City of Clarksville and Montgomery, Dickson, the northwestern part of Cheatham, and the western part of Robertson counties, Tennessee. 83.40 et seq. Plaintiff filed this action against defendant for breaching a non-competition agreement. /MediaBox [0 0 612 792] 4. 13. /Contents [322 0 R 323 0 R 324 0 R] /Annots [] endobj /CropBox [0 0 612 792] /Resources 157 0 R Small container commercial waste collection differs in many important respects from the collection of residential or other types of waste. 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. SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION In re: JOSE SANCHEZ Case No. endobj << /Contents [138 0 R 139 0 R 140 0 R] /MediaBox [0 0 612 792] /Contents [346 0 R 347 0 R 348 0 R] /CropBox [0 0 612 792] Since May 7, 2021, Wilson has been the GC of a private investment firm based in Boca Raton, Florida. 0000002992 00000 n >> In 1999, Allied reported total revenues of approximately $6 billion. /MediaBox [0 0 612 792] endobj /Resources 181 0 R /Annots [] >> 3601, et seq. /Resources 337 0 R /Rotate 0 An official website of the United States government. /Parent 10 0 R >> /CropBox [0 0 612 792] /Resources 221 0 R /Type /Page Jurisdiction is conferred on this Court by Chapters 26, 34, 86.011. ( prices charged by roll-off waste collection firms in the Macon, GA area market will likely increase. endobj /Resources 357 0 R 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. /Type /Page This action is brought to That defendants' proposed sales of hauling assets 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, and defendants' proposed sales of MSW disposal assets in the Anderson, IN; Macon, GA and New York City, NY area markets be adjudged and decreed to be unlawful and in violation of Section 7 of the Clayton Act; 2.

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complaint for injunctive relief florida