complaint for injunctive relief florida

endobj In re Amendments to Florida Small Claims Rules, 123 So.3d 41 (Fla . /Resources 221 0 R << >> /Resources 269 0 R /Rotate 0 >> /Type /Page 32 0 obj endobj /Parent 10 0 R ( /Rotate 0 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 [106 0 R 107 0 R 108 0 R] /Resources 385 0 R /Contents [110 0 R 111 0 R 112 0 R] 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. endobj /Contents [198 0 R 199 0 R 200 0 R] /Rotate 0 0000001275 00000 n /Rotate 0 ( This action arises under Chapter 713 and 720, Florida Statutes, and under the Fair Housing Act of 1968, as amended, 42 U.S.C. hb```f`` $V30 1;oO_Ia`sF!gbl!O| ` endobj /CropBox [0 0 612 792] /CropBox [0 0 612 792] /Parent 4 0 R This is a lawsuit for declaratory and injunctive relief under 86.011, Fla. Stat. 0000006750 00000 n endobj /Type /Page /Resources 321 0 R << endobj For the Court's convenience, Florida has attached a redline, as Exhibit A, showing changes from the First Amended Complaint. /Resources 201 0 R /Resources 249 0 R /Rotate 0 /Contents [134 0 R 135 0 R 136 0 R] /Resources 313 0 R /Resources 309 0 R endobj /MediaBox [0 0 612 792] endobj /CropBox [0 0 612 792] endobj endobj /CropBox [0 0 612 792] /Parent 11 0 R 94 0 obj 22 and 28 U.S.C. /Contents [130 0 R 131 0 R 132 0 R] /Rotate 0 /Contents [142 0 R 143 0 R 144 0 R] /Rotate 0 1. /Type /Page endobj 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. 40. /Rotate 0 << COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF . /Type /Pages /Parent 8 0 R 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. /MediaBox [0 0 612 792] /Parent 7 0 R 39 0 obj /MediaBox [0 0 612 792] 1114 Trademark Infringement . /Parent 10 0 R SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION In re: JOSE SANCHEZ Case No. %PDF-1.3 % IV. /PageLabels 3 0 R 57. /Annots [] /CropBox [0 0 612 792] /Rotate 0 Complaint for Injunctive Relief . 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. /Type /Pages "Albany, NY area" means the City of Albany and Albany, Schenectady, Saratoga, and Rensselaer counties, New York. 7. 14 0 obj >> 2018 to May 6, 2021. 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] /Resources 333 0 R 74 0 obj /Length 1411 %PDF-1.3 % /CreationDate (D:20220824140929-04'00') >> startxref /Type /Pages endobj >> /Parent 13 0 R /MediaBox [0 0 612 792] Does the injunction provide broad or limited relief? "Augusta, GA area" means the City of Augusta, Richmond and Columbia counties, Georgia, and Aiken County, South Carolina. 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. << /Annots [] 58 0 obj 31. /Contents [286 0 R 287 0 R 288 0 R] /Annots [] 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. 45], filed on August 192021, . /Annots [] /Contents [254 0 R 255 0 R 256 0 R] Roll-off waste haulers, therefore, generally establish garages and related facilities within each major local area served. /Annots [] The front-end load containers used by small container commercial collection customers cannot be serviced by roll-off trucks. endobj << /Parent 7 0 R endobj 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 $24 million. /Type /Page . /Type /Page /Rotate 0 Filing 1 COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. /Type /Page /Filter /FlateDecode Therefore, you should ask yourself these questions before proceeding: So, you answered the questions above, and you consider this to be the best approach to resolving your matter. xYYoH~7"b` recB$hHjRbK6DQ]]WUMb8`}^^l,q8x1O,7~`[)gD,uq+sU+PP)>f90VY-^AEKS2t}g4 X!xH rTmvF4(,W`{kF$tC /Type /Page #%$""!&+7/&)4)! >> clearly appears from specific facts shown by affidavit or by verified complaint that immediate or /Rotate 0 /Annots [] 5 0 obj /MediaBox [0 0 612 792] /Type /Page /Type /Page 62 0 obj /Resources 297 0 R endobj /Type /Page /Resources 285 0 R /MediaBox [0 0 612 792] The likely effect of these acquisitions is to substantially lessen competition and to tend to create a monopoly in interstate trade and commerce in violation of Section 7 of the Clayton Act. 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. /MediaBox [0 0 612 792] /Parent 14 0 R >> 21 0 obj 16. /Annots [] endobj /CropBox [0 0 612 792] << GsYzQh50ee' /Resources 105 0 R /Contents [402 0 R 403 0 R 404 0 R] /Annots [] stream There are immediate expenditures necessary. /Parent 10 0 R << /Contents [270 0 R 271 0 R 272 0 R] /Type /Page 42. 12 0 obj 56 0 obj /CropBox [0 0 612 792] /MediaBox [0 0 612 792] << A .gov website belongs to an official government organization in the United States. Since May 7, 2021, Wilson has been the GC of a private investment firm based in Boca Raton, Florida. /Resources 137 0 R /Resources 101 0 R /Type /Page 0000002992 00000 n 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 . >> 80 0 obj /MediaBox [0 0 612 792] /Annots [] /Parent 13 0 R %PDF-1.5 % /CropBox [0 0 612 792] Anderson, IN and New York City, NY are two such areas. ( /CropBox [0 0 612 792] % ASSOCIATION OF FLORIDA, MIGRANT CLINICIANS NETWORK, PINEROS Y . /ModDate (D:20220824143048-04'00') 42 0 obj /Rotate 0 /Rotate 0 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. ( Venue is proper in the Circuit Court of the Seventh Judicial Circuit, in and for 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. >> /Resources 153 0 R Should you request a temporary injunction or push quickly for final permanent injunction. 45 0 obj 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. /Type /Page /Resources 345 0 R %&'()*456789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz w !1AQaq"2B #3Rbr >> 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. 0000001563 00000 n endobj << 0000003135 00000 n /Contents [102 0 R 103 0 R 104 0 R] 0000000016 00000 n /Contents [278 0 R 279 0 R 280 0 R] /Parent 4 0 R /Parent 12 0 R /Rotate 0 /Parent 7 0 R /MediaBox [0 0 612 792] "Memphis, TN area" means Shelby County, Tennessee; Desoto County, Mississippi, and Crittenden County, Arkansas. /Parent 8 0 R /Rotate 0 _______/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. >> << 38. 44 0 obj /MediaBox [0 0 612 792] ( 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. K.A%aut\@Uaa[pVWnOe /Type /Page /CropBox [0 0 612 792] The extension ofvote-by-mail options and other accommodations at polling places is necessary. /Rotate 0 0000003868 00000 n /CropBox [0 0 612 792] Haulers, therefore, generally establish garages and related facilities within each major local area served. /Resources 161 0 R 13. 49. >> /MediaBox [0 0 612 792] << >> Managing Partner In the Macon, GA area, the acquisition would also combine the two largest firms that compete in roll-off waste collection service. << /Contents [302 0 R 303 0 R 304 0 R] /Parent 11 0 R xref /Type /Page /Annots [] /Parent 4 0 R >> >> << endobj CASE NO. What happens if the temporary injunction is not granted? ( /Type /Page >> 6. D. Entry Into Commercial Waste Collection of MSW. /MediaBox [0 0 612 792] /Annots [] <<14CA263718F8354CB34DA495C0495A29>]>> 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. /Rotate 0 "Gulf Coast, FL area" means Escambia, Santa Rosa, and Okaloosa counties, Florida. /Type /Page /Contents [282 0 R 283 0 R 284 0 R] endobj This is a civil action brought by the United States of America to enjoin defendant . /Contents [158 0 R 159 0 R 160 0 R] 82 0 obj endobj << 65 0 obj /Parent 9 0 R "Anderson, IN area" means the City of Anderson and Madison County, Indiana. 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. /Filter /FlateDecode << /CropBox [0 0 612 792] /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] endobj stream 50. .+p>hPhb4yiK=c`/XOv@|fe`iY The county court may issue a temporary and permanent injunction where appropriate for violation of ss. endobj 81 0 obj %PDF-1.6 /CropBox [0 0 612 792] 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. /Resources 393 0 R /Annots [] /Annots [] /Rotate 0 20 0 obj 46. /Type /Page 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 >> >> 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). >> /Resources 169 0 R /Rotate 0 /Subtype /XML /Rotate 0 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. >> endobj /Count 10 /CropBox [0 0 612 792] >> /Resources 305 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. ;("(;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;; For a number of reasons, landfills may not be located close to where the waste is generated. "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. H*23430P AsKN$r{(s /Annots [] /Rotate 0 << /Rotate 0 /Count 10 /Resources 217 0 R The operator continues along the route, collecting MSW from each of the commercial accounts until the vehicle is full. Jurisdiction is conferred on this Court by Chapters 26, 34, 86.011. << /Annots [] >> /Contents [126 0 R 127 0 R 128 0 R] << /Rotate 0 /Rotate 0 DECLARATORY AND INJUNCTIVE RELIEF* * Pursuant to Rule 15(a)(2), Florida files the Second Amended Complaint with the written consent of Defendants. /Type /Page /MediaBox [0 0 612 792] >> /Annots [] endobj >> /Annots [] /Type /Page << >> JURISDICTION AND VENUE 2. /Count 10 /CropBox [0 0 612 792] /Resources 109 0 R << endstream /Type /Page /Rotate 0 << 4 0 obj /MediaBox [0 0 612 792] /CropBox [0 0 612 792] >> endobj Judgment for Permanent Injunctive Relief against MJ Taxes on October 1, 2021. /Parent 14 0 R >> The roll-off container, when filled, is picked up by roll-off trucks, which are uniquely well suited for roll-off waste collection, and driven to a nearby disposal site, where the container's contents are disposed. /CropBox [0 0 612 792] >> The cost of transporting waste to a disposal site is often a substantial component of the cost of disposal. /Type /Page 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. /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] /MediaBox [0 0 612 792] /Contents [230 0 R 231 0 R 232 0 R] /Parent 7 0 R Section 13(b) of the FTC Act, 15 U.S.C. /Rotate 0 69. /Type /Page 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. /Annots [] >> /Parent 12 0 R 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. ( /Author (JacqmeinV) /CropBox [0 0 612 792] /Contents [150 0 R 151 0 R 152 0 R] ( endobj 23 0 obj <> endobj 28 0 obj <>/Filter/FlateDecode/ID[<2A277BAC2070266E6BF2C2060AD46B2B>]/Index[23 11]/Info 22 0 R/Length 49/Prev 24323/Root 24 0 R/Size 34/Type/XRef/W[1 2 1]>>stream JacqmeinV >> /Resources 265 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. % /Contents [190 0 R 191 0 R 192 0 R] /Annots [] /MediaBox [0 0 612 792] /Resources 329 0 R /Parent 8 0 R Very often courts do not grant injunctions if there is not a lot of specificity and practicality in the request for an injunction. 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. 0000001641 00000 n >> 0000000592 00000 n 50 0 obj Filing fees $ 402.00 receipt number AFLSDC-16386893, filed by OMEGA SA.. (Attachments: #1 . In each of these markets, Allied and Republic each account for a substantial share of total revenues from commercial waste collection services. 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. COMPLAINT FOR INJUNCTIVE RELIEF AND SANCTIONS Plaintiff, Donald F. Walton, United States Trustee for . 23. /Resources 165 0 R /Parent 8 0 R /CropBox [0 0 612 792] 2320 14 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. /Resources 353 0 R endobj Download the PDF of the Complaint IN THIS PUBLICATION Summary Issues COVID-19 /Parent 7 0 R /Annots [] Plaintiff, The Second Amendment Foundation, is a Washington Not-For-Profit /CropBox [0 0 612 792] 10. 16 0 obj endobj /Contents [266 0 R 267 0 R 268 0 R] /MediaBox [0 0 612 792] /CropBox [0 0 612 792] endobj >> /Rotate 0 /CropBox [0 0 612 792] /Resources 357 0 R /Annots [] << /Resources 401 0 R /Resources 261 0 R >> /Contents [138 0 R 139 0 R 140 0 R] Microsoft Word - 2022-08-24 - Complaint - FINAL 76 0 obj <> endobj Typical commercial waste collection customers include office and apartment buildings and retail establishments (e.g. 67 0 obj /CropBox [0 0 612 792] /Parent 13 0 R endstream endobj startxref /Contents [154 0 R 155 0 R 156 0 R] /CropBox [0 0 612 792] /Parent 9 0 R 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. In addition, be sure you have competent, knowledgeable and experienced counsel in your corner. /Type /Page /CropBox [0 0 612 792] ( >> /MediaBox [0 0 612 792] ( 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. 0000003645 00000 n 31 0 obj << 46 0 obj The extension of vote-by-mail options and other accommodations at polling places is necessary. /Type /Page >> >> "Clarksville, TN area" means the City of Clarksville and Montgomery, Dickson, the northwestern part of Cheatham, and the western part of Robertson counties, Tennessee. /Resources 197 0 R /Parent 9 0 R << /Contents [170 0 R 171 0 R 172 0 R] /Annots [] /MediaBox [0 0 612 792] Private waste haulers typically contract directly with customers for the collection of waste generated by commercial accounts. endobj The Court has jurisdiction over this action and over the parties pursuant to 15 U.S.C. 3 0 obj not 77 0 obj /MediaBox [0 0 612 792] 6 0 obj 62. /CropBox [0 0 612 792] /Resources 133 0 R /Rotate 0 53(b), empowers this Court to grant injunctive and such other relief as the Court may deem appropriate to halt 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. /MediaBox [0 0 612 792] 21-81099-CIV-CANNON/Reinhart . /Rotate 0 Page 3 of 15 7. /Annots [] This form is a Complaint for Injunctive Relief and Damages. 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. JURISDICTION AND VENUE 13. /Resources 293 0 R 41 0 obj /Contents [298 0 R 299 0 R 300 0 R] 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. 66. /CropBox [0 0 612 792] 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. It is engaged in providing waste collection and disposal services throughout the United States. /Rotate 0 /MediaBox [0 0 612 792] /Resources 181 0 R /Type /Page 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 >> endobj << An individual commercial customer typically generates substantially more MSW than a residential customer. >> >> /MediaBox [0 0 612 792] /Parent 14 0 R /Rotate 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. endobj . Absent injunctive relief by this Court, Defendants are likely to continue to injure consumers, reap unjust enrichment, and harm the public interest. To handle this high volume of MSW efficiently, haulers provide commercial customers with small dumpsters for storing the waste. The transactions likely will have the following effects, among others: 1. /Type /Page /Contents [370 0 R 371 0 R 372 0 R] ( /Type /Page /Parent 14 0 R /MediaBox [0 0 612 792] /Resources 209 0 R /CropBox [0 0 612 792] In order to obtain comparable operating efficiency, a new firm must achieve route density comparable to existing firms. /CropBox [0 0 612 792] 13(b) of the Federal Trade Commission Act ("FTC Act"), 15 U.S.C. /Annots [] 0000000879 00000 n /MediaBox [0 0 612 792] /CropBox [0 0 612 792] /Parent 12 0 R >> Republic is a Delaware corporation with its principal office in Ft. Lauderdale, Florida. /MediaBox [0 0 612 792] >> /Contents [178 0 R 179 0 R 180 0 R] endstream endobj 29 0 obj <>stream /Contents [386 0 R 387 0 R 388 0 R] /Contents [94 0 R 95 0 R 96 0 R] ( x1 04) F&`/MFWxC. 2 0 obj /Annots [] Plaintiffs also seek temporary injunctive relief as stated in the accompanying Motion for Temporary Injunction. prices charged by roll-off waste collection firms in the Macon, GA area market will likely increase. <> /Rotate 0 /Count 10 << << /MediaBox [0 0 612 792] 29. /Rotate 0 /Contents [174 0 R 175 0 R 176 0 R] /Annots [] 95 0 obj /Contents [162 0 R 163 0 R 164 0 R] 0000000016 00000 n >> ( << ( >> 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. &%e2#4DqB#K.tt.GYeMbN!uiW-C`oIynF,fD5c&a8|A!y%?ci6Ywo`aPT=Yz0Id /Type /Page /Type /Page /MediaBox [0 0 612 792] /Parent 11 0 R "MSW" means municipal solid waste, a term of art used to describe solid putrescible waste generated by households and commercial establishments such as retail stores, offices, restaurants, warehouses, and non-manufacturing activities in industrial facilities. /CropBox [0 0 612 792] /Rotate 0 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. 0 Filing fees are due at the time a party files a pleading to initiate a proceeding or files a pleading for relief. 7 0 obj 40 0 obj 58. Plaintiff, PRISON LEGAL NEWS ("PLN"), a project of the Human Rights Defense . /Parent 12 0 R /Count 10 << stream In its 1998 fiscal year, Republic reported total revenues of approximately $1.8 billion. /Type /Page The length of the presentation is 46:09. 79 0 obj /Resources 317 0 R /CropBox [0 0 612 792] << /Resources 325 0 R /Contents [326 0 R 327 0 R 328 0 R] 21. Security Personnel as Independent Contractors Part I: What Makes an Individual an Independent Contractor Instead of an Employee? /Type /Page $4%&'()*56789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz r! /MediaBox [0 0 612 792] 63 0 obj /Type /Page >> /MediaBox [0 0 612 792] 0000001536 00000 n >> endobj This action is filed by the United States of America under Section 15 of the Clayton Act, 15 U.S.C. COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF Introduction 1. Professional Services Industry Legal Blog>. /CropBox [0 0 612 792]

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complaint for injunctive relief florida