9. Filing 1 COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. /Parent 8 0 R 0000001536 00000 n
not . /Type /Page << 3. endobj /Type /Page 13 0 obj /Resources 241 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. endobj
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26 0 obj /Resources 181 0 R 61 0 obj Venue properly lies in the Southern Distri ct of Florida pursuant to 28 U.S.C. << Jimerson Birr welcomes inquiries from the media and do our best to respond to deadlines. 4. have exclusive jurisdiction: (a) In all actions at law cognizable by the county . /CropBox [0 0 612 792] /CropBox [0 0 612 792] 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. >> >> 6. /Parent 12 0 R /Type /Catalog /Contents [346 0 R 347 0 R 348 0 R] 68.
United States District Court Southern District of Florida How long will the injunction be effective? /Contents [350 0 R 351 0 R 352 0 R] 3 0 obj Therefore, you should ask yourself these questions before proceeding: So, you answered the questions above, and you consider this to be the best approach to resolving your matter. << /Resources 257 0 R /Annots [] endstream Complaint for purposes of Florida Statutes Sections 501.207(5) and 95.11(3). /CropBox [0 0 612 792] /Type /Page endobj >> >> << 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. /CropBox [0 0 612 792] /MediaBox [0 0 612 792] /CropBox [0 0 612 792] endobj Complaint for Injunctive Relief Case (s): U.S. v. Allied Waste Industries, Inc. and Republic Services, Inc. /CropBox [0 0 612 792] endobj Access to competitive disposal sites and reasonable disposal costs are important to providers of roll-off collection services. 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. 0000003404 00000 n
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/Annots [] endobj In these markets, Allied and Republic each account for a substantial share of MSW disposal capacity. /Type /Pages /Resources 173 0 R 2320 0 obj<>
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/Rotate 0 /Contents [298 0 R 299 0 R 300 0 R] endobj xref
endobj /Annots [] /Type /Page /MediaBox [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. /Parent 9 0 R 43 0 obj /Type /Page .t. /MediaBox [0 0 612 792] /Type /Page endobj /Contents [206 0 R 207 0 R 208 0 R] /Type /Page /Rotate 0 It is calculated by squaring the market share of each firm competing in the market and then summing the resulting numbers. Complaint for Injunctive Relief . endobj /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. /Type /Page 84 0 obj provide preliminary and permanent injunctive relief pursuant to Rules 57 and 64 of the Federal Rules of Civil Procedure and 28 U.S.C. /CropBox [0 0 612 792] _l {:\! The President of the United States and the Governor of Florida have each declared a state of emergency. /Annots [] endobj 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. To handle this high volume of MSW efficiently, haulers provide commercial customers with small dumpsters for storing the waste. advance, Plaintiffs seek immediate declaratory and injunctive relief that directs Defendants to permit a designated representative of each affected candidate and political party into the recount room, as Florida law requires. Charles B. Jimerson /Type /Pages 83.40 et seq. /Type /Page /Contents [382 0 R 383 0 R 384 0 R] 8 0 obj %
endobj >> INTRODUCTION . /Parent 4 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. /Resources 225 0 R /Resources 321 0 R >> It is engaged in providing waste collection and disposal services throughout the United States. /CropBox [0 0 612 792] /Annots [] /Resources 113 0 R /Rotate 0 << endobj 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. Judgment for Permanent Injunctive Relief against MJ Taxes on October 1, 2021. /Parent 7 0 R /PageLabels 3 0 R << ( /MediaBox [0 0 612 792] endobj See Merger Guidelines 1.51. /Resources 405 0 R /Rotate 0 In their waste collection and waste disposal businesses, defendants make sales and purchases in interstate commerce, ship waste in the flow of interstate commerce, and engage in activities substantially affecting interstate commerce. /Contents [102 0 R 103 0 R 104 0 R] 36 0 obj The operator continues along the route, collecting MSW from each of the commercial accounts until the vehicle is full. "Burlington and Camden Counties, NJ area" means Burlington and Camden counties, New Jersey. /Annots [] /Parent 13 0 R and Florida Statute 86.011, et seq. /Annots [] ( /MediaBox [0 0 612 792] In the Macon, GA area, the acquisition would also combine the two largest firms that compete in roll-off waste collection service. Small container commercial waste collection differs in many important respects from the collection of residential or other types of waste.
PDF United States District Court Middle District of Florida Tampa Division 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. ( /CreationDate (D:20220824140929-04'00') Virtually all of the MSW generated in each of these areas is disposed of in transfer stations in each of their local areas. Because of its characteristics (e.g. 1. endobj /CropBox [0 0 612 792] /Resources 129 0 R /Rotate 0
PDF COMPLAINT FOR INJUNCTIVE RELIEF AND SANCTIONS PARTIES - The Wall Street 42. 63 0 obj /Parent 9 0 R 0000002235 00000 n
/Parent 11 0 R "Albany, NY area" means the City of Albany and Albany, Schenectady, Saratoga, and Rensselaer counties, New York. << /CropBox [0 0 612 792] /Resources 389 0 R /Resources 109 0 R /MediaBox [0 0 612 792] On August 20, . /CropBox [0 0 612 792] /Type /Page /Rotate 0 << /Contents [106 0 R 107 0 R 108 0 R] /Rotate 0
/Annots [] /Type /Pages /Count 10 /Contents [218 0 R 219 0 R 220 0 R] /MediaBox [0 0 612 792]
clearly appears from specific facts shown by affidavit or by verified complaint that immediate or 12102(1)-(2), the regulations implementing the . >> /CropBox [0 0 612 792] /Resources 121 0 R 3. /Resources 137 0 R /MediaBox [0 0 612 792] 15 0 obj /CropBox [0 0 612 792] /MediaBox [0 0 612 792] /CropBox [0 0 612 792] Venue is proper in the Circuit Court of the Seventh Judicial Circuit, in and for /Rotate 0 Does the temporary injunction preserve the Status Quo or does it make a change? /Parent 7 0 R relief pursuant to Chapter 86, Florida Statutes. This Court has the authority to grant the requested declaratory and injunctive relief pursuant to 28 U.S.C. /MediaBox [0 0 612 792] 28 0 obj /Annots [] ( 29 0 obj endobj 37. endstream 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. 85 0 obj
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( There are immediate expenditures necessary.
PDF Florida Small Claims Rules Annotated 2020 - The Florida Bar 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. /Type /Page /Subtype /XML
PDF Verified Second Amended Complaint for Injunctive and Declaratory Relief 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. /MediaBox [0 0 612 792] << 4. /Annots [] Section 13(b) of the FTC Act, 15 U.S.C. /Resources 205 0 R << endobj /Annots [] /Contents [134 0 R 135 0 R 136 0 R]
PDF Verified Complaint for Damages and Injunctive Relief 39 0 obj >> >> ("MFS"), is a Florida corporation that has a principal place of . 55 0 obj /Resources 313 0 R "Monmouth County, NJ area"means the City of Marlboro and Monmouth County, New Jersey. /CropBox [0 0 612 792] 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. 33 0 obj >> /MediaBox [0 0 612 792] "Memphis, TN area" means Shelby County, Tennessee; Desoto County, Mississippi, and Crittenden County, Arkansas. /Annots [] /MediaBox [0 0 612 792] /Resources 193 0 R 40. /Contents [114 0 R 115 0 R 116 0 R] /Annots [] As such, following the process to the tee will help improve your chances for success. 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. /Parent 7 0 R 78 0 obj MSW has physical characteristics that readily distinguish it from other liquid or solid waste. /Parent 9 0 R SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION In re: JOSE SANCHEZ Case No. /Contents [266 0 R 267 0 R 268 0 R] /Contents [182 0 R 183 0 R 184 0 R] ( Plaintiffs also seek temporary injunctive relief as stated in the accompanying Motion for Temporary Injunction. /Rotate 0 67. 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. endobj /Rotate 0 endobj /Resources 189 0 R /CropBox [0 0 612 792] /Resources 261 0 R The front-end load containers used by small container commercial collection customers cannot be serviced by roll-off trucks. /Resources 381 0 R After the acquisition, Allied would control over 40 percent--and two firms would control over 80 percent--of the small container commercial waste hauling market, which has annual revenues of about $8 million. /Rotate 0 << /Resources 157 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. stores and restaurants). /Parent 12 0 R /Annots [] << /Parent 13 0 R /Type /Page /CropBox [0 0 612 792] _______/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. /Resources 233 0 R /MediaBox [0 0 612 792] >> endobj << 1 0 obj
/Type /Page Republic is engaged in providing waste collection and disposal services throughout the United States. /Rotate 0 /Annots [] 27 0 obj /Annots [] 24 0 obj 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. /CropBox [0 0 612 792] /Count 10 For the Court's convenience, Florida has attached a redline, as Exhibit A, showing changes from the First Amended Complaint. /Length 10 88 0 obj Since May 7, 2021, Wilson has been the GC of a private investment firm based in Boca Raton, Florida. >> << 23. endobj 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). 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. /Contents [362 0 R 363 0 R 364 0 R] << /Rotate 0 U.S. v. Allied Waste Industries, Inc. and Republic Services, Inc. 46 0 obj << endobj /Resources 285 0 R /Type /Page endobj /Parent 9 0 R /MediaBox [0 0 612 792] 14. /CropBox [0 0 612 792] << Local public opposition often makes it more difficult and costly, and increases the time and uncertainty of successfully permitting a facility. /Contents [274 0 R 275 0 R 276 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. /Parent 14 0 R /MediaBox [0 0 612 792] /Type /Page /Annots [] /Type /Page The City changed its name from "New COMPLAINT FOR INJUNCTIVE RELIEF AND SANCTIONS Plaintiff, Donald F. Walton, United States Trustee for . << Reopen fees are due at the time a party files a pleading to reopen a proceeding if at least 90 days have . %PDF-1.5
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/Annots [] /Length 3282 /CropBox [0 0 612 792] <<14CA263718F8354CB34DA495C0495A29>]>>
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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. /Annots [] The extension of vote-by-mail options and other accommodations at polling places is necessary. /Length 1411 >> 5. /Contents [170 0 R 171 0 R 172 0 R] << << /Rotate 0 /Parent 4 0 R /Type /Page >> /Resources 141 0 R >> /Resources 349 0 R /Resources 293 0 R 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. /MediaBox [0 0 612 792] /Rotate 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. ]\q( $QSRP@=8`) $CC16 PI_ XL /Parent 10 0 R /Parent 10 0 R /Filter /FlateDecode /MediaBox [0 0 612 792] /Parent 14 0 R /Type /Page 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. Filing fees $ 402.00 receipt number AFLSDC-16386893, filed by OMEGA SA.. (Attachments: #1 . Preference Primary election in Florida. ( << 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. /Type /Pages endobj >> >> /Resources 177 0 R /Annots [] 2. For a variety of reasons, other types of collection activities, such as roll-off containers (typically used for construction debris) and collection of liquid or hazardous waste, are also rarely combined with commercial waste collection activities. Official websites use .gov << >> 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. ( /Parent 12 0 R << 13. 82 0 obj Venue is therefore proper in this district under Section 12 of the Clayton Act, 15 U.S.C. << << What happens if the temporary injunction is not granted? 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. 0000000016 00000 n
14 0 obj 12. Complaint for Injunctive Relief and Civil Penalties (pdf) (1.93 MB) Contact Us to ask a question, provide feedback, or report a problem. 31 0 obj
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? endobj << 7402(a) to prevent such conduct. /CropBox [0 0 612 792] /CropBox [0 0 612 792] /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] /Contents [122 0 R 123 0 R 124 0 R] /Type /Page /Resources 201 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. /CropBox [0 0 612 792] 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. 3 0 obj
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>> What impact will it have on third-parties and employees? /Annots [] In order to obtain comparable operating efficiency, a new firm must achieve route density comparable to existing firms. << << endobj << /Annots [] /Annots [] /Contents [310 0 R 311 0 R 312 0 R] Allied and Republic are two of only a few providers of waste collection or disposal services in each of the identified areas. 30 0 obj /Rotate 0 /Rotate 0 >> /Rotate 0 /Parent 11 0 R
How to Obtain a Temporary (Preliminary) Injunction in Florida - Ewusiak Law The extension ofvote-by-mail options and other accommodations at polling places is necessary.
PDF United States District Court Southern District of Florida Case No } !1AQa"q2#BR$3br 53 0 obj /CropBox [0 0 612 792] /CropBox [0 0 612 792] 31. ( Amended Complaint "Motion") [ECF(the No. endobj /Contents [94 0 R 95 0 R 96 0 R] /Type /Page /Type /Page /MediaBox [0 0 612 792] endobj Share sensitive information only on official, secure websites. 67 0 obj /Count 79 /Type /Page endobj
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/Contents [402 0 R 403 0 R 404 0 R] /Contents [370 0 R 371 0 R 372 0 R] >> >> /Rotate 0 Allied is a Delaware corporation with its principal office in Scottsdale, Arizona. /Rotate 0 Is there any vagueness, or is everything extremely clear? /Resources 365 0 R /CropBox [0 0 612 792] /CropBox [0 0 612 792] /ModDate (D:20220824143048-04'00') 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. 90 0 obj /Annots [] Permit restrictions often impose severe limitations on the type and amount of waste that can be disposed of at landfills. 6 0 obj Rather, its about dealing with the future, not something that happened in the past. 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. 22408. /Parent 4 0 R /Parent 10 0 R 18 0 obj /Rotate 0 /Parent 8 0 R /MediaBox [0 0 612 792] /Contents [278 0 R 279 0 R 280 0 R] 87 0 obj A complaint for declaratory relief must allege the following: there is a bona fide dispute between the parties; the plaintiff has a justiciable question as to the existence or nonexistence of some right, status, immunity, power or privilege, or as to some fact upon which existence of such a claim may depend; /CropBox [0 0 612 792] 89 0 obj 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." << 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. << /Parent 7 0 R Download the PDF of the Complaint IN THIS PUBLICATION Summary Issues COVID-19 Does the injunction provide broad or limited relief? 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. /Contents [258 0 R 259 0 R 260 0 R] 4 0 obj
/Parent 9 0 R endobj JFIF C << 65. /Contents [374 0 R 375 0 R 376 0 R] /Parent 7 0 R While small container commercial waste collection typically involves a FEL truck making regular stops on pre-scheduled routes to empty numerous containers at multiple customer locations, roll-off waste collection is often performed on an "on-call" basis for customers whose waste is not part of any route. endobj /CropBox [0 0 612 792]
PDF Motion for Summary Judgment - Liberty Counsel << /Contents [282 0 R 283 0 R 284 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. 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. /MediaBox [0 0 612 792] /Pages 4 0 R /MediaBox [0 0 612 792]
#%$""!&+7/&)4)! << 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. 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. <<21a9e19eaa9d774d8bfb9315a3d3f5db>]>>
/Contents [290 0 R 291 0 R 292 0 R] (Compl . /Type /Metadata /Parent 9 0 R Is the injunction prohibitory or mandatory? /Contents [162 0 R 163 0 R 164 0 R] >> 59 0 obj 6th Street Ft. Lauderdale, FL 33301 Defendants. /Parent 12 0 R /Parent 14 0 R 47 0 obj /Rotate 0 endobj /CropBox [0 0 612 792] %&'()*456789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz w !1AQaq"2B #3Rbr 22 and 28 U.S.C. /Rotate 0 Finally, prices for small container service are influenced principally by the density of the routes served by each vehicle; prices for roll-off services are influenced primarily by the distance of the customer's location from the hauler's location and the disposal site, the time required to travel those distances, and the cost of disposal at the disposal site. << 0000000016 00000 n
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US District Court for the Southern District of Florida: Presiding Judge: Raag Singhal: Nature of Suit: Trademark: Cause of Action: 15 U.S.C.
Deciding Whether to Sue for Injunction, and What is the Process to 27. /Type /Page /Resources 309 0 R /Resources 409 0 R 59. /Type /Page hbbd`b`rfb`gb`
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/Contents [386 0 R 387 0 R 388 0 R] 1331 and 1337. /Annots [] /Annots [] /Resources 145 0 R /MediaBox [0 0 612 792] /Contents [210 0 R 211 0 R 212 0 R] /MediaBox [0 0 612 792] /Type /Page /Contents [354 0 R 355 0 R 356 0 R] 64. JacqmeinV /Rotate 0 49 0 obj 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. /MediaBox [0 0 612 792] ( /Rotate 0 << (2001). /Parent 7 0 R 35. xb```c``b`f`0gg@ ~G@|*{jd`q%T3e83:! @`HsXD|",e0`A
21.
;("(;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;; ( >> Entry would also be made more difficult by Republic's use of long-term, automatically renewing contracts for roll-off service. 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.
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