endobj << endobj /Resources 157 0 R "Anderson, IN area" means the City of Anderson and Madison County, Indiana. /Annots [] Share sensitive information only on official, secure websites. /Rotate 0 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. This Court has jurisdiction to enter declaratory and injunctive relief pursuant to Florida Statute 86.011 and Article V, 20 of the Florida Constitution. /MediaBox [0 0 612 792] PDF Verified Complaint for Damages and Injunctive Relief 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. Judgment for Permanent Injunctive Relief against MJ Taxes on October 1, 2021. /Contents [318 0 R 319 0 R 320 0 R] 55 0 obj 38 0 obj /Parent 7 0 R /Parent 12 0 R << endobj 59 0 obj >> << /Contents [282 0 R 283 0 R 284 0 R] Complaint for Emergency Injunctive Relief in Florida Primary /Annots [] >> /MediaBox [0 0 612 792] /Annots [] /Resources 385 0 R . /Contents [262 0 R 263 0 R 264 0 R] 66 0 obj /MediaBox [0 0 612 792] /Parent 12 0 R /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] 20 0 obj 3 0 obj /CropBox [0 0 612 792] >> 0000001641 00000 n /Contents [334 0 R 335 0 R 336 0 R] 17. 68. /Parent 9 0 R This action is filed by the United States of America under Section 15 of the Clayton Act, 15 U.S.C. After the acquisition, Allied would control roughly 30 percent--and two firms about 66 percent--of the New York City, NY area MSW disposal market, which has annual revenues of about $40 million. >> CASE NO. 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. Thus, disposal of MSW is a line of commerce, or relevant service, for purposes of analyzing the effects of the acquisition under Section 7 of the Clayton Act. ("MFS"), is a Florida corporation that has a principal place of . Charles B. Jimerson VERIFIED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF Introduction 1. /Parent 7 0 R << 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. /Contents [394 0 R 395 0 R 396 0 R] "0A149;>>>%.DIC; C 65. 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. /Resources 277 0 R /MediaBox [0 0 612 792] . /Resources 229 0 R Garcia is a resident of North Lauderdale, Fl orida. The HHI increases both as the number of firms in the market decreases and as the disparity in size between those firms increases. /CropBox [0 0 612 792] >> /Annots [] /Rotate 0 /MediaBox [0 0 612 792] >> Omega SA v. The Individuals, Business Entities, and Unincorporated /MediaBox [0 0 612 792] /Parent 4 0 R /CropBox [0 0 612 792] /Resources 233 0 R /Type /Page ( endobj Complaint for Emergency Injunctive Relief in Florida Primary The global coronavirus pandemic threatens to disrupt the Presidential Preference Primary election in Florida. >> 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. PDF United States District Court Middle District of Florida Tampa Division /Annots [] 83 0 obj /CropBox [0 0 612 792] /Contents [222 0 R 223 0 R 224 0 R] 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. 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. 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. /Resources 113 0 R /Parent 10 0 R /Contents [198 0 R 199 0 R 200 0 R] Is the injunction prohibitory or mandatory? /CropBox [0 0 612 792] /Contents [250 0 R 251 0 R 252 0 R] /MediaBox [0 0 612 792] /Producer <4163726F6261742044697374696C6C65722032322E30202857696E646F7773293B206D6F646966696564207573696E67206954657874AE20372E312E3620A9323030302D323031392069546578742047726F7570204E56202841646D696E697374726174697665204F6666696365206F662074686520556E697465642053746174657320436F757274733B206C6963656E7365642076657273696F6E29> After the acquisition, Allied would control over 50 percent--and two firms over 90 percent--of the small container commercial waste hauling market, which has annual revenues of about $31 million. /CropBox [0 0 612 792] 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. << /Annots [] "HHI" means the Herfindahl-Hirschman Index, a commonly accepted measure of market concentration. /MediaBox [0 0 612 792] In each of these markets, the resulting substantial increase in concentration, loss of competition, and absence of reasonable prospect of significant new entry or expansion by market incumbents, ensures that consumers will pay substantially higher prices for collection of small container commercial waste, the collection of roll-off waste, or the disposal of MSW. Pursuant to the purchase agreements, Allied would acquire from Superior: hauling assets in Albany, New York; hauling assets in Augusta, Georgia; hauling assets in Memphis, Nashville and Clarksville, Tennessee; disposal assets in New York, New York; hauling assets in Norfolk, Virginia; and hauling assets in Okaloosa, Escambia and Santa Rosa counties, Florida. endobj An individual commercial customer typically generates substantially more MSW than a residential customer. <>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> Deciding Whether to Sue for Injunction, and What is the Process to 45], filed on August 192021, . 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. PDF COMPLAINT FOR PERMANENT INJUNCTION - United States Department of Justice In contrast to a commercial collection route, a residential waste collection route is significantly more labor intensive. 30 0 obj /Resources 265 0 R The Court has jurisdiction over this action and over the parties pursuant to 15 U.S.C. 8 0 obj 31 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. Because of its characteristics (e.g. /Rotate 0 /MediaBox [0 0 612 792] Jimerson Birr welcomes inquiries from the media and do our best to respond to deadlines. Download the PDF of the Complaint IN THIS PUBLICATION Summary Issues COVID-19 ( 7. /MediaBox [0 0 612 792] IV. /Parent 7 0 R endobj 43. /Type /Page endstream endobj startxref /Contents [238 0 R 239 0 R 240 0 R] /Annots [] >> /Resources 201 0 R >> /Contents [206 0 R 207 0 R 208 0 R] Copyright 2008-2023 Jimerson Birr, P.A. /Rotate 0 stores and restaurants). Rather, its about dealing with the future, not something that happened in the past. << << /Type /Page /Metadata 2 0 R For the Court's convenience, Florida has attached a redline, as Exhibit A, showing changes from the First Amended Complaint. /MediaBox [0 0 612 792] >> /Rotate 0 0000001275 00000 n 0000000817 00000 n ( >> 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. >> endobj 6108, to obtain temporary, preliminary, and permanent injunctive relief, rescission or reformation of contracts, restitution, the refund of monies paid, disgorgement of ill-gotten . /Resources 165 0 R >> /Resources 281 0 R << /CropBox [0 0 612 792] 4. The United States Army Corps of Engineers ("Corps" or "Army Corps") has unlawfully approved a massive dredging project for Port Everglades in Fort Lauderdale, Florida. Filing fees are due at the time a party files a pleading to initiate a proceeding or files a pleading for relief. What impact will it have on third-parties and employees? 22 and 28 U.S.C. 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. << M`5`i`F{qZ 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. 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. There are immediate expenditures necessary. /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] A party seeking an injunction under general Florida case law must demonstrate: 1) irreparable harm; 2) a clear legal right; 3) an inadequate . 0000003404 00000 n Last updated on November 21, 2022. 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. MSW landfills can only accept waste up to their permitted daily capacity and have a finite life span. << "Lakeland, FL area" means Polk County, Florida. /Parent 11 0 R /Type /Page endobj Access to competitive disposal sites and reasonable disposal costs are important to providers of roll-off collection services. $4%&'()*56789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz r! /CropBox [0 0 612 792] 30. GsYzQh50ee' /Annots [] &%e2#4DqB#K.tt.GYeMbN!uiW-C`oIynF,fD5c&a8|A!y%?ci6Ywo`aPT=Yz0Id endobj /Resources 117 0 R /Annots [] /Parent 12 0 R 33. In addition to differences in container size, other factors distinguish roll-off waste collection from small container commercial and other types of waste collection. /Type /Page /CropBox [0 0 612 792] Noncompete Agreements: Protecting Referral Relationships as Legitimate Business Interests, Hiring for Florida Banks and Credit Unions: A Summary of Background Checks and Other Information Required to Comply With Various Regulatory Schemes. /Annots [] << /MediaBox [0 0 612 792] ASSOCIATION OF FLORIDA, MIGRANT CLINICIANS NETWORK, PINEROS Y . 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. /Contents [290 0 R 291 0 R 292 0 R] /CropBox [0 0 612 792] ( 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. See Laws of Florida, Ch. /Resources 241 0 R endobj 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. /Rotate 0 /Parent 7 0 R PDF Complaint for injunction and declaratory relief 1114 Trademark Infringement . /Rotate 0 /Resources 345 0 R /Rotate 0 33 0 obj /CropBox [0 0 612 792] endobj >> /MediaBox [0 0 612 792] 0000001536 00000 n /CropBox [0 0 612 792] 25. trailer /Type /Page 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. endobj /Type /Page /Resources 213 0 R ( ( /Resources 321 0 R For instance, in many states, most MSW is disposed of in landfills, which are permitted under and regulated by the state. /Parent 11 0 R Plaintiff seeks temporary, preliminary, and permanent injunctive relief pursuant to Rule 65 . Allied and Republic are two of only a few providers of waste collection or disposal services in each of the identified areas. /Title (Microsoft Word - 2022-08-24 - Complaint - FINAL) 5 0 obj >> /Resources 369 0 R /Contents [370 0 R 371 0 R 372 0 R] %PDF-1.3 % /Parent 9 0 R /Resources 205 0 R Defendants because the Amended Complaint seeks injunctive relief only for these Counts, to which qualified immunity does not apply. /Annots [] endobj /Resources 373 0 R . /MediaBox [0 0 612 792] EOs6~W\F3[_y7~r+W3nU>9YRpM/u"%1yK Ivp, Microsoft Word - 2022-08-24 - Complaint - FINAL. % /Length 10 /Type /Page 47 0 obj endobj /CropBox [0 0 612 792] After the acquisition, Republic would control over 85 percent of the small container commercial waste hauling market, which has annual revenues of about $5 million. << /Parent 14 0 R PDF COMPLAINT FOR INJUNCTIVE RELIEF - archive.org /Type /Page /CropBox [0 0 612 792] 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. "Gulf Coast, FL area" means Escambia, Santa Rosa, and Okaloosa counties, Florida. /Rotate 0 /Contents [162 0 R 163 0 R 164 0 R] /Type /Page /Resources 393 0 R The operator continues along the route, collecting MSW from each of the commercial accounts until the vehicle is full. >> /Type /Page /Parent 9 0 R There may be disclosure of confidential information such as trade secrets. /Rotate 0 ( /Parent 8 0 R /Parent 13 0 R /Parent 13 0 R /Parent 12 0 R /Parent 4 0 R /Contents [110 0 R 111 0 R 112 0 R] The extension of vote-by-mail options and other accommodations at polling places is necessary. /Annots [] SOUTHERN DISTRICT OF FLORIDA . >> /Annots [] /Rotate 0 Security Personnel as Independent Contractors Part I: What Makes an Individual an Independent Contractor Instead of an Employee? /Parent 10 0 R endobj 23 0 obj endstream 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. 32. 26 0 obj /CropBox [0 0 612 792] 27 0 obj 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 JURISDICTION AND VENUE 1. /Contents [194 0 R 195 0 R 196 0 R] /Annots [] << 1391(c). 17 0 obj 30 0 obj <>/Filter/FlateDecode/ID[<3860DCF29749FC4EACF121159FB5FA73><3860DCF29749FC4EACF121159FB5FA73>]/Index[25 7]/Info 24 0 R/Length 36/Prev 968458/Root 26 0 R/Size 32/Type/XRef/W[1 2 0]>>stream >> 13. >> /Resources 305 0 R /Contents [314 0 R 315 0 R 316 0 R] In such areas, many of the problems associated with the permitting and construction of a landfill could make it difficult to permit and construct a transfer station. 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. PDF United States District Court Northern District of Florida Pensacola >> "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. /Type /Page Firms that compete in the disposal of MSW generated in the Anderson, IN or New York City, NY areas can profitably increase their charges for disposal of MSW generated in each area without losing significant sales to more distant disposal sites. 48 0 obj After the acquisition, Republic would control over 60 percent of the roll-off hauling market, which has annual revenues of about $8 million. Allied and Republic directly compete in the disposal of waste in a number of markets nationwide, including the Anderson, IN; New York City, NY; and Macon, Georgia areas. However, the incumbents' use of price discrimination and long-term contracts prevents new entrants from winning a large enough base of customers to achieve efficient routes in sufficient time to constrain the post-acquisition firm from significantly raising prices after the transaction. Often businesses do not consider the implications for taking this action. /Contents [166 0 R 167 0 R 168 0 R] /Contents [322 0 R 323 0 R 324 0 R] COMPLAINT FOR INJUNCTIVE, DECLARATORY RELIEF, AND DAMAGES Plaintiff, STATE OF FLORIDA, DEPARTMENT OF LEGAL AFFAIRS sues Defendant, TODD TEAL d/b/a WALTER A. SMITH, SNUFFY SMITH, (TEAL) and alleges: NATURE OF THE ACTION 1. This action is brought to /CropBox [0 0 612 792] Injunctive relief is considered an extraordinary remedy in both State and Federal court. /Parent 10 0 R endobj Plaintiff LEAGUE OF WOMEN VOTERS OF FLORIDA ("LWVF" or the "League") is the Florida affiliate of the League of Women Voters of the United States. (2001). >> THIS COURT'S POWER TO GRANT RELIEF 84. 5. /Resources 389 0 R 2201 a nd 2202. /Type /Page Defendants Allied and Republic collect municipal solid waste from residential, commercial, and industrial customers, and they own and operate transfer stations, landfills, and incinerators, which process and dispose of municipal solid waste. 55. << /CropBox [0 0 612 792] /MediaBox [0 0 612 792] 35 0 obj << In these markets, Allied and Republic each account for a substantial share of MSW disposal capacity. /Type /Page /Contents [182 0 R 183 0 R 184 0 R] PDF United States District Court Southern District of Florida Case No endobj >> /Contents [302 0 R 303 0 R 304 0 R] /Type /Page /Filter /FlateDecode endobj 3. /Annots [] >> ]Wx C1>*yvL#uR$=I$$WJQg%=ElRS3DE27y1 G. 91 0 obj 0000003135 00000 n endobj /MediaBox [0 0 612 792] 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. /Resources 325 0 R 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. endobj Waiver recipients are entitled to continuation of services that they are currently receiving through the completion of the fair hearing /CropBox [0 0 612 792] /Contents [146 0 R 147 0 R 148 0 R] ( 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. /Resources 341 0 R << >> 69 0 obj /Parent 13 0 R 81 0 obj 39 0 obj 25 0 obj Statutes & Constitution :View Statutes : Online Sunshine >> << "Louisville, KY/ Sellersburg, IN area" means the cities of Louisville, Kentucky and Sellersburg, Indiana; Jefferson County, Kentucky; and the parts of Floyd and Clark counties, Indiana abutting Jefferson County, Kentucky. stream 86 0 obj /Resources 397 0 R endobj It is calculated by squaring the market share of each firm competing in the market and then summing the resulting numbers. /Resources 261 0 R This action arises under Chapter 713 and 720, Florida Statutes, and under the Fair Housing Act of 1968, as amended, 42 U.S.C. /Rotate 0 "Norfolk, VA area" means the cities of Chesapeake, Suffolk, Virginia Beach, Norfolk, Poquoson, Newport News and Portsmouth, and York, Surry, James City, Southampton, and Isle of Wight counties, Virginia. /Resources 185 0 R %%EOF /Annots [] >> 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 . >> ( /Annots [] 0000000879 00000 n /Resources 121 0 R 88 0 obj<>stream xref PDF Complaint for Permanent Injunction and Other Equitable Relief 41. 14. /CropBox [0 0 612 792] 0 80 0 obj endobj ( << Haulers, therefore, generally establish garages and related facilities within each major local area served. 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. /Rotate 0 In the Macon, GA market, Allied and Republic each account for a substantial share of total revenues from roll-off waste collection services. /Parent 14 0 R ( endobj 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. /Rotate 0 /Type /Page /Resources 317 0 R /Contents [190 0 R 191 0 R 192 0 R] /CropBox [0 0 612 792] /Resources 289 0 R 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. 1391, . /Rotate 0 60. 28. 92 0 obj PDF COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF - NSB Anglers Yacht That plaintiff recover the costs of this action. << << >> /Parent 11 0 R /Author (JacqmeinV) endobj >> /Contents [178 0 R 179 0 R 180 0 R] /Annots [] 6th Street Ft. Lauderdale, FL 33301 Defendants. endobj 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. 13 0 obj /Resources 377 0 R Complaint for Injunctive Relief Case (s): U.S. v. Allied Waste Industries, Inc. and Republic Services, Inc. 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. 21. >> /Type /Page /Rotate 0 52 0 obj /Resources 409 0 R 2201-202, and . /Count 10 endobj /Parent 12 0 R PDF Complaint for Permanent Injunction, Monetary Relief, and Other Relief 4. Significant new entry into the disposal of MSW in the Anderson, IN and New York City, NY areas would be difficult and time-consuming. 28 0 obj /CropBox [0 0 612 792] PDF In the Supreme Court of Florida Case No.: Sc11- Third District Case No 8. 15. /Type /Page endobj /Annots [] 62 0 obj "Clarksville, TN area" means the City of Clarksville and Montgomery, Dickson, the northwestern part of Cheatham, and the western part of Robertson counties, Tennessee. 42. /Annots [] 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. /Rotate 0 /Rotate 0 << << /Annots [] /MediaBox [0 0 612 792] 22. /Resources 361 0 R endobj Local roll-off waste collection firms in the Macon, GA area can profitably increase charges to local customers without losing significant sales to more distant competitors. /CropBox [0 0 612 792] /Annots [] /CropBox [0 0 612 792] /Annots [] /CropBox [0 0 612 792] 3 0 obj xref >> Venue properly lies in the Southern Distri ct of Florida pursuant to 28 U.S.C. H*23430P AsKN$r{(s /CropBox [0 0 612 792] /Parent 11 0 R endobj 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 transactions likely will have the following effects, among others: 1. "Burlington and Camden Counties, NJ area" means Burlington and Camden counties, New Jersey. 0000001149 00000 n 51. /Type /Page /MediaBox [0 0 612 792] /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] 0 /Resources 401 0 R "New York City, NY area" means the Borough of Brooklyn, New York. 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. 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 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. /Resources 161 0 R In re Amendments to Florida Small Claims Rules, 123 So.3d 41 (Fla . /CropBox [0 0 612 792] /Parent 8 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. /Rotate 0 endobj /Contents [214 0 R 215 0 R 216 0 R] _______/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.
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