complaint for injunctive relief florida

/Type /Pages Access to competitive disposal sites and reasonable disposal costs are important to providers of roll-off collection services. /MediaBox [0 0 612 792] endobj In its 1998 fiscal year, Republic reported total revenues of approximately $1.8 billion. >> /Rotate 0 >> Often businesses do not consider the implications for taking this action. the Florida Deceptive and Unfair Trade Practices Act, Chapter 501, Part II, Florida Statutes ("FDUTPA"), which authorizes the State of Florida to seek, and the Court to order, permanent injunctive relief, recission or reformation of contracts, consumer restitution, the refund of monies /Parent 9 0 R 0000000556 00000 n 49 0 obj /Annots [] /Parent 13 0 R /Resources 341 0 R /Resources 293 0 R 12. /Resources 401 0 R /Type /Page /Resources 177 0 R /Annots [] /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] 59. xref >> 48. Very often courts do not grant injunctions if there is not a lot of specificity and practicality in the request for an injunction. /Contents [310 0 R 311 0 R 312 0 R] >> /S /D << 21 0 obj There are immediate expenditures necessary. >> 66 0 obj Otherwise, there may be something missed or an unintended consequence when you sue for injunction, which can can bring about dissatisfaction, regardless of who prevails. 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. relief pursuant to Chapter 86, Florida Statutes. /Resources 333 0 R 2322 0 obj<>stream Since May 7, 2021, Wilson has been the GC of a private investment firm based in Boca Raton, Florida. endobj << 51. /Metadata 2 0 R /CropBox [0 0 612 792] 17 0 obj 1 1 On February 7, 2023 and February 16, 2023, Plaintiff filed motions for preliminary 2 injunctive relief. /Type /Metadata /Contents [198 0 R 199 0 R 200 0 R] 24. /Filter /FlateDecode 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. 43. /Contents [218 0 R 219 0 R 220 0 R] 10 0 obj 58 0 obj 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. /Contents [94 0 R 95 0 R 96 0 R] /Contents [282 0 R 283 0 R 284 0 R] 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. 0000001187 00000 n /Type /Page /Type /Page /Rotate 0 /MediaBox [0 0 612 792] There could be a negative impact on the plaintiffs public image. /Annots [] ( In addition, be sure you have competent, knowledgeable and experienced counsel in your corner. /Annots [] 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. /Type /Page JacqmeinV >> >> /CropBox [0 0 612 792] 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. not ( >> 0000001641 00000 n Rule 1.610 of the Florida Rules of Civil Procedure governs requests for temporary injunctions. 3. Secure .gov websites use HTTPS 57. The HHI increases both as the number of firms in the market decreases and as the disparity in size between those firms increases. /Rotate 0 ( /Parent 12 0 R Plaintiff, PRISON LEGAL NEWS ("PLN"), a project of the Human Rights Defense . /Parent 7 0 R 21. /MediaBox [0 0 612 792] /Contents [270 0 R 271 0 R 272 0 R] << %PDF-1.6 APPROPRIATENESS OF INJUNCTIVE RELIEF 26 . 1114 Trademark Infringement . 1391, . 0 40. endobj 12102(1)-(2), the regulations implementing the . /Contents [150 0 R 151 0 R 152 0 R] /Parent 14 0 R 5. /MediaBox [0 0 612 792] /Type /Page /Parent 9 0 R /MediaBox [0 0 612 792] /Type /Page >> That plaintiff recover the costs of this action. /Rotate 0 << /MediaBox [0 0 612 792] << 36 0 obj /Rotate 0 In contrast to a commercial collection route, a residential waste collection route is significantly more labor intensive. /CropBox [0 0 612 792] /Resources 409 0 R /Parent 8 0 R >> /MediaBox [0 0 612 792] /Annots [] ( Small Container Commercial Waste Collection Service. /Contents [110 0 R 111 0 R 112 0 R] >> 53. /Type /Page /MediaBox [0 0 612 792] /Contents [102 0 R 103 0 R 104 0 R] /Rotate 0 /MediaBox [0 0 612 792] 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. 42. See Laws of Florida, Ch. "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. 63. endobj << /Annots [] /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] /Resources 189 0 R << What happens if the temporary injunction is not granted? /CropBox [0 0 612 792] /Creator (PScript5.dll Version 5.2.2) /MediaBox [0 0 612 792] >> Suitable landfills are difficult and time-consuming to obtain, and sometimes difficult to expand, because of the scarcity of suitable land, local resident opposition, environmental concerns, and government regulation. In the Clarksville, TN area, the acquisition would reduce from five to four the number of significant firms competing in the collection of small container commercial waste. 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. 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. 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. Federal, state and local safety, environmental, zoning, and permit laws and regulations dictate critical aspects of storage, handling, transportation, processing and disposal of MSW. As a result, Austin begins the presentation by sharing some of the things you should think about before pursuing an injunction: There is a lot on the line. /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] "Columbus, OH area" means the City of Columbus and Franklin and Delaware counties, Ohio. 64. /CropBox [0 0 612 792] /Rotate 0 For the Court's convenience, Florida has attached a redline, as Exhibit A, showing changes from the First Amended Complaint. /Resources 405 0 R /CropBox [0 0 612 792] /Contents [398 0 R 399 0 R 400 0 R] /Rotate 0 /Contents [214 0 R 215 0 R 216 0 R] /Annots [] >> << /CropBox [0 0 612 792] /CropBox [0 0 612 792] endobj /Resources 213 0 R 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. /Contents [226 0 R 227 0 R 228 0 R] >> /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] This Court has jurisdiction to enter declaratory and injunctive relief pursuant to Florida Statute 86.011 and Article V, 20 of the Florida Constitution. 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. /CropBox [0 0 612 792] /Type /Page /Annots [] endobj /CropBox [0 0 612 792] SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION In re: JOSE SANCHEZ Case No. /Type /Page /Parent 14 0 R endobj /CropBox [0 0 612 792] /Annots [] 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. In re Amendments to Florida Small Claims Rules, 123 So.3d 41 (Fla . >> 0000001149 00000 n 49. << /Resources 273 0 R endobj /MediaBox [0 0 612 792] In this presentation, Jimerson Birr Associate Austin B. Calhoun covers 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. 61 0 obj /Rotate 0 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. /Resources 153 0 R endobj /Annots [] /Annots [] 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. 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 . /Type /Page endobj endobj In each of these markets, Allied and Republic each account for a substantial share of total revenues from commercial waste collection services. /CropBox [0 0 612 792] endobj /CropBox [0 0 612 792] /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] 13. endobj /Count 10 endobj /Producer <4163726F6261742044697374696C6C65722032322E30202857696E646F7773293B206D6F646966696564207573696E67206954657874AE20372E312E3620A9323030302D323031392069546578742047726F7570204E56202841646D696E697374726174697665204F6666696365206F662074686520556E697465642053746174657320436F757274733B206C6963656E7365642076657273696F6E29> Significant new entry into the disposal of MSW in the Anderson, IN and New York City, NY areas would be difficult and time-consuming. An MSW disposal facility must be located on approved types of land and operated under prescribed procedures. /Type /Pages "Lakeland, FL area" means Polk County, Florida. /Contents [330 0 R 331 0 R 332 0 R] >> << /CropBox [0 0 612 792] /Annots [] 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. /Contents [238 0 R 239 0 R 240 0 R] /Type /Page /Annots [] ( 9 0 obj Florida has reported 149 confirmed cases of COVID-19 and four deaths to date, with every expectation that these numbers will rise. /Rotate 0 Complaint for purposes of Florida Statutes Sections 501.207(5) and 95.11(3). 36. Transactions that increase the HHI by more than 100 points in highly concentrated markets presumptively raise antitrust concerns under the Horizontal Merger Guidelines issued by the U.S. Department of Justice and the Federal Trade Commission. >> /Contents [206 0 R 207 0 R 208 0 R] 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.

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