<< 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. 92 0 obj /CreationDate (D:20220824140929-04'00') /Type /Pages /Rotate 0 /CropBox [0 0 612 792] 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. endobj /Rotate 0 /Contents [354 0 R 355 0 R 356 0 R] endobj /Count 10 /Parent 4 0 R /Contents [302 0 R 303 0 R 304 0 R] << /CropBox [0 0 612 792] Filing fees $ 402.00 receipt number AFLSDC-16386893, filed by OMEGA SA.. (Attachments: #1 . ( 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. /Rotate 0 /Resources 285 0 R endobj << /Type /Page /MediaBox [0 0 612 792] /CropBox [0 0 612 792] /Rotate 0 /CropBox [0 0 612 792] /Parent 14 0 R << /Parent 9 0 R The acquisitions by Allied and Republic would remove a significant competitor in small container commercial waste collection service, roll-off waste collection service, and/or the disposal of MSW, in already highly concentrated and difficult-to-enter markets. 17 0 obj 10. >> /Rotate 0 >> /Rotate 0 >> xYYoH~7"b` recB$hHjRbK6DQ]]WUMb8`}^^l,q8x1O,7~`[)gD,uq+sU+PP)>f90VY-^AEKS2t}g4 X!xH rTmvF4(,W`{kF$tC /Parent 4 0 R /CropBox [0 0 612 792] 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. << ( /CropBox [0 0 612 792] /CropBox [0 0 612 792] /Parent 9 0 R .t. 0000001852 00000 n 34 0 obj << ( /MediaBox [0 0 612 792] Access to competitive disposal sites and reasonable disposal costs are important to providers of roll-off collection services. /Resources 145 0 R /MediaBox [0 0 612 792] /Rotate 0 /Type /Page The Corps' environmental analysis for this project is based on the same assumptions and In the Macon, GA area, the acquisition would also combine the two largest firms that compete in roll-off waste collection service. There may be disclosure of confidential information such as trade secrets. << 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. After the acquisition, Republic would control over 60 percent of the roll-off hauling market, which has annual revenues of about $8 million. 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. /Resources 353 0 R endobj /MediaBox [0 0 612 792] /Rotate 0 /Parent 4 0 R "Transfer station" means an intermediate disposal site, often used in more densely populated areas, for the processing and temporary storage of solid waste before transfer, in bulk, to more distant facilities for final disposal. "HHI" means the Herfindahl-Hirschman Index, a commonly accepted measure of market concentration. 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. See Laws of Florida, Ch. . Allied and Republic directly compete in small container commercial waste collection service in a number of markets nationwide, including the areas of: 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. /Annots [] ( endobj 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. /Resources 269 0 R /Rotate 0 << /Resources 257 0 R /Resources 233 0 R >> /Rotate 0 /Filter /FlateDecode endobj /Rotate 0 endobj 68. /Type /Page 53(b), to secure preliminary and permanent injunctive relief, rescission of contracts, restitution, disgorgement, and other . /Rotate 0 13 0 obj 12102(1)-(2), the regulations implementing the . /Annots [] /Resources 197 0 R /MediaBox [0 0 612 792] Plaintiff filed this action against defendant for breaching a non-competition agreement. 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. /Resources 329 0 R /Contents [298 0 R 299 0 R 300 0 R] /Annots [] >> /Rotate 0 Filing 1 COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. endobj ( /Type /Page /Resources 333 0 R 94 0 obj /Annots [] 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. /Contents [242 0 R 243 0 R 244 0 R] 3. provide relief to all the individuals affected by APD's action. 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. 6. /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] /MediaBox [0 0 612 792] endobj /Type /Page trailer /Parent 9 0 R SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION In re: JOSE SANCHEZ Case No. 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 $31 million. /Title (Microsoft Word - 2022-08-24 - Complaint - FINAL) 13. /Parent 12 0 R /Resources 361 0 R Share sensitive information only on official, secure websites. << /Parent 13 0 R /Rotate 0 /Rotate 0 endobj 17. Suing for an injunction in Florida is all about preserving the status quo. /Type /Page /Type /Page /Type /Page << ;,hn \ic6rZFi+|:GsL$KGqzed8;M+"N7i~4Dr?_1hHa:`R[B%Qm*?u9Lh=?y%x8;e$AD+xx Since May 7, 2021, Wilson has been the GC of a private investment firm based in Boca Raton, Florida. /CropBox [0 0 612 792] /Contents [350 0 R 351 0 R 352 0 R] /Resources 377 0 R 2201-202, and . 16 0 obj .+p>hPhb4yiK=c`/XOv@|fe`iY /Resources 337 0 R An individual commercial customer typically generates substantially more MSW than a residential customer. endobj 91 0 obj /Type /Page 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. >> endobj endobj There are no good substitutes for MSW disposal. /MediaBox [0 0 612 792] /Contents [142 0 R 143 0 R 144 0 R] 24. How long will the injunction be effective? prices charged by roll-off waste collection firms in the Macon, GA area market will likely increase. In its 1998 fiscal year, Republic reported total revenues of approximately $1.8 billion. /Type /Page /MediaBox [0 0 612 792] The acquisition would reduce from three to two the number of significant firms that compete in the collection of small container commercial waste in the Burlington and Camden Counties, NJ area. 63. (ECF No. /Contents [370 0 R 371 0 R 372 0 R] Z( /MediaBox [0 0 612 792] Private waste haulers typically contract directly with customers for the collection of waste generated by commercial accounts. Because of its characteristics (e.g. /Type /Page /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] 78 0 obj Charles B. Jimerson /Rotate 0 This is an action for permanent injunctive relief, declaratory relief, and h|VrH}Weo2)RXBr|:=%ts?mlteQG :C:+rl86#m0GcfFmMb`4&;|Xy|^Q(&Y Jf#mb!nDlpfIi QB*Mg< /Rotate 0 endobj 28. /Contents [246 0 R 247 0 R 248 0 R] 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. The City changed its name from "New /Contents [386 0 R 387 0 R 388 0 R] 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. 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. 80 0 obj << /Contents [382 0 R 383 0 R 384 0 R] ( /Type /Page /Annots [] >> 46 0 obj << An MSW disposal facility must be located on approved types of land and operated under prescribed procedures. << Very often courts do not grant injunctions if there is not a lot of specificity and practicality in the request for an injunction. /Annots [] Unless the twelve acquisitions are enjoined, consumers of waste collection and disposal services will likely pay higher prices and receive fewer services as a consequence of the elimination of the vigorous competition between defendants Allied and Republic. >> $4%&'()*56789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz r! endobj JacqmeinV /Parent 4 0 R /Contents [218 0 R 219 0 R 220 0 R] Republic is engaged in providing waste collection and disposal services throughout the United States. << /MediaBox [0 0 612 792] The transactions likely will have the following effects, among others: 1. /Parent 11 0 R endstream /CropBox [0 0 612 792] 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. /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. /Contents [138 0 R 139 0 R 140 0 R] ( /Resources 217 0 R endobj 45], filed on August 192021, . /MediaBox [0 0 612 792] Managing Partner 38 0 obj For instance, in many states, most MSW is disposed of in landfills, which are permitted under and regulated by the state. 2322 0 obj<>stream 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. /Annots [] /CropBox [0 0 612 792] /Contents [346 0 R 347 0 R 348 0 R] 32. /Type /Page Copyright 2008-2023 Jimerson Birr, P.A. << >> /Rotate 0 /MediaBox [0 0 612 792] 19 0 obj << endobj EOs6~W\F3[_y7~r+W3nU>9YRpM/u"%1yK Ivp, Microsoft Word - 2022-08-24 - Complaint - FINAL. >> 6th Street Ft. Lauderdale, FL 33301 Defendants. /Rotate 0 endobj 26 0 obj 20 0 obj 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. /Type /Page /Rotate 0 /MediaBox [0 0 612 792] 7 0 obj /Parent 12 0 R In the Anderson, IN area, almost all of the MSW generated is disposed of in one of three transfer stations. << /CropBox [0 0 612 792] 11. 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. /CropBox [0 0 612 792] JURISDICTION AND VENUE 13. << 84 0 obj /Annots [] /Resources 125 0 R >> /Resources 249 0 R /Type /Pages /Annots [] /Annots [] /CropBox [0 0 612 792] /Contents [178 0 R 179 0 R 180 0 R] /CropBox [0 0 612 792] endobj /MediaBox [0 0 612 792] 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 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 $29 million. /Type /Page /Parent 11 0 R /Contents [286 0 R 287 0 R 288 0 R] Local small container commercial waste collection firms in the Albany, NY; Augusta, GA; Burlington and Camden Counties, NJ; Clarksville, TN; Columbus, OH; Gulf Coast, FL; Lakeland, FL; Louisville, KY/Sellersburg, IN; Macon, GA; Memphis, TN; Monmouth County, NJ; Nashville, TN and Norfolk, VA areas can profitably increase charges to local customers without losing significant sales to more distant competitors. /MediaBox [0 0 612 792] 36 0 obj /MediaBox [0 0 612 792] 34. ( 66. MSW generated by residential customers, on the other hand, is often collected by either local governments or by private haulers pursuant to contracts bid by, or franchises granted by, municipal authorities. /Resources 289 0 R << /Resources 221 0 R /Parent 12 0 R /Rotate 0 /MediaBox [0 0 612 792] /Resources 309 0 R Haulers, therefore, generally establish garages and related facilities within each major local area served. The cost of transporting waste to a disposal site is often a substantial component of the cost of disposal. In addition to differences in container size, other factors distinguish roll-off waste collection from small container commercial and other types of waste collection. /Parent 8 0 R /MediaBox [0 0 612 792] trailer 41 0 obj 0000000016 00000 n /CropBox [0 0 612 792] Roll-off vehicles have no compaction system on board and are designed to carry only one large container at a time to a disposal site. << << Allied is located in and transacts business in the District of Columbia, and Republic submits to the personal jurisdiction of the District of Columbia in this proceeding. "Gulf Coast, FL area" means Escambia, Santa Rosa, and Okaloosa counties, Florida. /Resources 317 0 R H*23430P AsKN$r{(s endobj /Rotate 0 /Annots [] /Parent 7 0 R /Contents [250 0 R 251 0 R 252 0 R] /Count 10 M`5`i`F{qZ /Type /Page endobj /Contents [206 0 R 207 0 R 208 0 R] /Type /Page /CropBox [0 0 612 792] /Contents [154 0 R 155 0 R 156 0 R] /MediaBox [0 0 612 792] /Type /Pages /Type /Page /Parent 14 0 R /Annots [] /MediaBox [0 0 612 792] 65. 2 0 obj 3601, et seq. If you are interested in speaking to a Jimerson Birr lawyer or want general information about the firm, our practice areas, lawyers, publications, or events, please contact us via email or telephone for assistance at (904) 389-0050. 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). /Annots [] /Annots [] << "Clarksville, TN area" means the City of Clarksville and Montgomery, Dickson, the northwestern part of Cheatham, and the western part of Robertson counties, Tennessee. 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. 0000003868 00000 n /Rotate 0 /Annots [] 18 0 obj /Type /Page 55 0 obj >> /MediaBox [0 0 612 792] A .gov website belongs to an official government organization in the United States. >> 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. 2320 14 62. /Type /Page 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? /Parent 10 0 R This action is brought to /Parent 8 0 R /MediaBox [0 0 612 792] 1391(c). >> endobj 44 0 obj 65 0 obj >> << /Resources 113 0 R /Rotate 0 /CropBox [0 0 612 792] This is an action for injunctive relief. 68 0 obj % 4. 25 0 obj ( endobj /Contents [162 0 R 163 0 R 164 0 R] /Count 10 /Contents [190 0 R 191 0 R 192 0 R] /Type /Pages . 8. It is calculated by squaring the market share of each firm competing in the market and then summing the resulting numbers. /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] /Resources 109 0 R /MediaBox [0 0 612 792] /Contents [310 0 R 311 0 R 312 0 R] /Contents [194 0 R 195 0 R 196 0 R] Is the injunction prohibitory or mandatory? 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. Although, where available, MSW can be transported to distant landfills through transfer stations using large transfer trailer trucks, the use of transfer stations adds fixed transportation and processing costs. >> Secure .gov websites use HTTPS Alexdex. /Parent 10 0 R The United States of America, acting under the direction of the Attorney General of the United States, brings this civil antitrust action to enjoin the acquisition of certain waste hauling and disposal assets by Defendants Allied Waste Industries, Inc. ("Allied") and Republic Services, Inc. ("Republic") and to obtain equitable relief and other relief as appropriate. /Resources 133 0 R /Resources 381 0 R ("MFS"), is a Florida corporation that has a principal place of . /Annots [] /Creator (PScript5.dll Version 5.2.2) /Annots [] In 1999, Allied reported total revenues of approximately $6 billion. /Rotate 0 /CropBox [0 0 612 792] /Resources 409 0 R Likewise, roll-off customers generate volumes of waste which are too large to be serviced by a FEL truck on a pre-scheduled commercial route. endobj /Annots [] endobj /Type /Page >> endobj 0000002235 00000 n endobj /Parent 14 0 R Small container commercial waste collection differs in many important respects from the collection of residential or other types of waste. COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF . /Resources 273 0 R >> /Rotate 0 << /Resources 365 0 R /CropBox [0 0 612 792] 81 0 obj /MediaBox [0 0 612 792] endobj /Rotate 0 /MediaBox [0 0 612 792] /Contents [258 0 R 259 0 R 260 0 R] << /Contents [290 0 R 291 0 R 292 0 R] /Parent 10 0 R This action is filed by the United States of America under Section 15 of the Clayton Act, 15 U.S.C. /Type /Page /MediaBox [0 0 612 792] 53(b), empowers this Court to grant injunctive and such other relief as the Court may deem appropriate to halt This is a must-watch video before you consider whether to sue for injunction. /Parent 12 0 R 7402(a) to prevent such conduct. x1 04) F&`/MFWxC. 48. Because of the differences in the collection process, residential customers and commercial customers usually are organized into separate routes. "Macon, GA area" means the City of Macon and Bibb, Peach and parts of Houston, Jones and Monroe counties, Georgia. 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. /MediaBox [0 0 612 792] << 7. In the New York City, NY area, the acquisition would reduce from five to four the number of significant firms competing to dispose of commercial MSW. >> /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. endobj Reopen fees are due at the time a party files a pleading to reopen a proceeding if at least 90 days have . << VERIFIED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF Introduction 1. /Rotate 0 << ( endobj stream /Annots [] /Annots [] Injunctive relief is considered an extraordinary remedy in both State and Federal court. ( Defendants because the Amended Complaint seeks injunctive relief only for these Counts, to which qualified immunity does not apply. /MediaBox [0 0 612 792] /Type /Page /Resources 213 0 R /CropBox [0 0 612 792] Is there any vagueness, or is everything extremely clear? << /Type /Page /Resources 313 0 R The cost advantage of local landfills limits the areas where MSW can be economically transported and disposed of by haulers and creates localized markets for MSW disposal services. /Annots [] /Rotate 0 /Contents [166 0 R 167 0 R 168 0 R] "Augusta, GA area" means the City of Augusta, Richmond and Columbia counties, Georgia, and Aiken County, South Carolina. startxref /Contents [294 0 R 295 0 R 296 0 R] /Type /Page /Parent 11 0 R /CropBox [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. Does the temporary injunction preserve the Status Quo or does it make a change? /Annots [] This form is a Complaint for Injunctive Relief and Damages. /Parent 11 0 R >> << /Type /Page /Type /Page /Kids [25 0 R 26 0 R 27 0 R 28 0 R 29 0 R 30 0 R 31 0 R 32 0 R 33 0 R 34 0 R] 16. /Type /Page >> <>>> /Annots [] << 5 0 obj endobj 6 0 obj /MediaBox [0 0 612 792] /CropBox [0 0 612 792] /Contents [202 0 R 203 0 R 204 0 R] There could be a negative impact on the plaintiffs public image. Complaint for Emergency Injunctive Relief in Florida Primary The global coronavirus pandemic threatens to disrupt the Presidential Preference Primary election in Florida. /Resources 393 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. endobj endobj In these markets, Allied and Republic each account for a substantial share of MSW disposal capacity. 55. endobj >> /Type /Page 0 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. << << /MediaBox [0 0 612 792] This is an action for injunctive and declaratory relief, costs, damages, attorney's fees, penalties, and other available statutory relief, pursuant to the Florida Deceptive and Unfair . << ( /CropBox [0 0 612 792] /Resources 101 0 R << /MediaBox [0 0 612 792] >> 59 0 obj 48 0 obj /Type /Page prescribed by these rules and by section 51.011, Florida Statutes, the statutory provision shall govern. Anyone who fails to dispose of MSW in an approved facility can be subject to severe civil and criminal penalties. >> stores and restaurants). /Contents [102 0 R 103 0 R 104 0 R] "Columbus, OH area" means the City of Columbus and Franklin and Delaware counties, Ohio. /MediaBox [0 0 612 792] /Parent 10 0 R /MediaBox [0 0 612 792] /Resources 401 0 R >> 7. /Type /Page The extension ofvote-by-mail options and other accommodations at polling places is necessary. <>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> << /Type /Pages /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] PLAINTIFF'S COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF . >> /Author (JacqmeinV) << 85 0 obj /Type /Page /Type /Pages /Rotate 0 Official websites use .gov Plaintiff seeks temporary, preliminary, and permanent injunctive relief pursuant to Rule 65 . /Rotate 0 57 0 obj Should you request a temporary injunction or push quickly for final permanent injunction. /Type /Page >> /Rotate 0 /Parent 9 0 R /CropBox [0 0 612 792] This is a lawsuit for declaratory and injunctive relief under 86.011, Fla. Stat. << /MediaBox [0 0 612 792] /Rotate 0 /MediaBox [0 0 612 792] Garcia is a resident of North Lauderdale, Fl orida. << 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. 22 and 28 U.S.C. /Contents [266 0 R 267 0 R 268 0 R] /Contents [342 0 R 343 0 R 344 0 R] 9 0 obj /Resources 181 0 R /Annots [] 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. >> /MediaBox [0 0 612 792] /Type /Page /CropBox [0 0 612 792] /Resources 117 0 R << /Annots [] A party seeking an injunction under general Florida case law must demonstrate: 1) irreparable harm; 2) a clear legal right; 3) an inadequate . xref /Type /Page 12. hbbd``b`@q=`v0012,I00"0 endstream endobj startxref 0 %%EOF 33 0 obj <>stream /Contents [118 0 R 119 0 R 120 0 R] endstream endobj 29 0 obj <>stream 45. This document is available in two formats: this web page (for browsing content) and. /Contents [230 0 R 231 0 R 232 0 R] 0000000016 00000 n << /Resources 173 0 R endobj