Preference Primary election in Florida. endobj Roll-off waste compactors are generally located at the site of the roll-off container, thereby permitting the customer to increase the container's on-site storage capacity. /Resources 141 0 R >> endobj endobj /Parent 12 0 R Rather, its about dealing with the future, not something that happened in the past. /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] /Resources 297 0 R endobj Contains legal complaint for injunctive releif and civil penalties against BCX facility Site, Jacksonville, Duval County, Florida, June 7, 2004. 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. /Parent 12 0 R /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. Republic is a Delaware corporation with its principal office in Ft. Lauderdale, Florida. 2201-202, and . << /Annots [] >> /Rotate 0 The HHI increases both as the number of firms in the market decreases and as the disparity in size between those firms increases. /Contents [334 0 R 335 0 R 336 0 R] 0000002235 00000 n /Contents [258 0 R 259 0 R 260 0 R] /Type /Metadata (ECF No. Garcia is a resident of North Lauderdale, Fl orida. . /MediaBox [0 0 612 792] In 1999, Allied reported total revenues of approximately $6 billion. 18. 88 0 obj<>stream 63 0 obj /Rotate 0 /Resources 349 0 R << /Rotate 0 ( <<14CA263718F8354CB34DA495C0495A29>]>> /Parent 14 0 R /Contents [266 0 R 267 0 R 268 0 R] /CreationDate (D:20220824140929-04'00') /Resources 185 0 R ( /Contents [198 0 R 199 0 R 200 0 R] ( 8. /Type /Page /MediaBox [0 0 612 792] 93 0 obj 20 0 obj 1. Venue is therefore proper in this district under Section 12 of the Clayton Act, 15 U.S.C. >> The acquisition would reduce from three to two the number of significant firms that compete in the collection of small container commercial waste in the Burlington and Camden Counties, NJ area. A new entrant into small container commercial waste collection service cannot provide a significant competitive constraint on the prices charged by market incumbents until it achieves minimum efficient scale and operating efficiencies comparable to existing firms. /Contents [358 0 R 359 0 R 360 0 R] The Court has jurisdiction over this action and over the parties pursuant to 15 U.S.C. << /MediaBox [0 0 612 792] .t. >> 95 0 obj ( 4. have exclusive jurisdiction: (a) In all actions at law cognizable by the county . Copyright 2008-2023 Jimerson Birr, P.A. /Annots [] << /Annots [] Federal, state and local safety, environmental, zoning, and permit laws and regulations dictate critical aspects of storage, handling, transportation, processing and disposal of MSW. xb```b``Ig`a`X @1V hdc [`&&v/>4427pHG(Og|sW(7_HPpXp'Skgu`.8!B=\2+".b4dh fZ!WHW3`W+.eP9(tb1P,%pX1EaSO6I)1] K,cMpl q m D@,"R:7S&`u@6j(LjfLT[D1,BPf:9= P1!$Ippa8fHNtD {,nPY 5 >> endobj /MediaBox [0 0 612 792] /Contents [226 0 R 227 0 R 228 0 R] << /Type /Page << /CropBox [0 0 612 792] /Resources 117 0 R 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. >> That plaintiff receive such other and further relief as the case requires and the Court deems proper; and. /MediaBox [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. 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. JURISDICTION AND VENUE 2. /Type /Page >> US District Court for the Southern District of Florida: Presiding Judge: Raag Singhal: Nature of Suit: Trademark: Cause of Action: 15 U.S.C. 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. >> 14. /Type /Pages /Contents [102 0 R 103 0 R 104 0 R] /Resources 241 0 R Plaintiffs also seek temporary injunctive relief as stated in the accompanying Motion for Temporary Injunction. 0000001852 00000 n 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. >> /Annots [] Roll-off waste haulers, therefore, generally establish garages and related facilities within each major local area served. /CropBox [0 0 612 792] 0 36 0 obj /Rotate 0 /Parent 7 0 R /Resources 149 0 R 21-81099-CIV-CANNON/Reinhart . 23 0 obj /MediaBox [0 0 612 792] /Rotate 0 C. Reduction in Competition As a Consequence of the Acquisition. 76 0 obj <> endobj After the acquisition, Allied would be a monopolist controlling over 98 percent of the small container Commercial waste hauling market, which has annual revenues of about $5 million. /Contents [158 0 R 159 0 R 160 0 R] 39 0 obj In the Lakeland, FL area, the acquisition would reduce from two to one the number of significant competitors in the collection of small container commercial waste. 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. "Augusta, GA area" means the City of Augusta, Richmond and Columbia counties, Georgia, and Aiken County, South Carolina. ( /Rotate 0 /Resources 189 0 R /Rotate 0 /Type /Page Permit restrictions often impose severe limitations on the type and amount of waste that can be disposed of at landfills. /Annots [] Roll-off haulers typically deal with larger waste volumes from a single customer for which disposal costs constitute a greater percentage of the total revenue received for the service. 1 1 On February 7, 2023 and February 16, 2023, Plaintiff filed motions for preliminary 2 injunctive relief. endobj /Annots [] not There are immediate expenditures necessary. /Annots [] Small container commercial waste collection services are generally provided in highly localized areas because to operate efficiently and profitably, a hauler must have sufficient density in its commercial waste collection operations; i.e., a large number of commercial accounts that are reasonably close together. /Rotate 0 13(b) of the Federal Trade Commission Act ("FTC Act"), 15 U.S.C. 66. 32 0 obj 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 [] COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF Introduction 1. /CropBox [0 0 612 792] /Rotate 0 /Contents [222 0 R 223 0 R 224 0 R] endobj Thus, roll-off 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. 11 0 obj /CropBox [0 0 612 792] Judgment for Permanent Injunctive Relief against MJ Taxes on October 1, 2021. /Resources 369 0 R 0000003868 00000 n 11. DECLARATORY AND INJUNCTIVE RELIEF* * Pursuant to Rule 15(a)(2), Florida files the Second Amended Complaint with the written consent of Defendants. >> IV. /CropBox [0 0 612 792] endobj 0000001275 00000 n /MediaBox [0 0 612 792] /Resources 377 0 R >> 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. /Annots [] 26. endobj endobj 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. It is economically impractical for a roll-off waste collection firm to serve metropolitan areas from a distant base. endobj 46. /CropBox [0 0 612 792] << 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. /Parent 10 0 R << 21 0 obj /MediaBox [0 0 612 792] /Annots [] /CropBox [0 0 612 792] %PDF-1.5 66 0 obj 57 0 obj endobj Roll-off waste collection customers typically generate bulkier items of waste and/or substantially larger volumes of waste than residential or small container commercial waste customers from sources such as construction sites or industrial plants. Anyone who fails to dispose of MSW in an approved facility can be subject to severe civil and criminal penalties. Typical commercial waste collection customers include office and apartment buildings and retail establishments (e.g. Republic is engaged in providing waste collection and disposal services throughout the United States. 17. ( /CropBox [0 0 612 792] ( /Annots [] Date: Wednesday, June 21, 2000 Document Type: Complaint This document is available in two formats: this web page (for browsing content) and PDF (comparable to original document formatting). /Parent 12 0 R /Parent 13 0 R /Contents [238 0 R 239 0 R 240 0 R] >> >> /Annots [] /Parent 13 0 R /Rotate 0 20. INTRODUCTION . 1114 Trademark Infringement . /MediaBox [0 0 612 792] 1391(c). /Type /Page (2001). >> /Resources 197 0 R 59 0 obj /Parent 9 0 R endobj 22 0 obj /Resources 305 0 R /Annots [] /Rotate 0 For example, for a market consisting of four firms with shares of thirty, thirty, twenty, and twenty percent, the HHI is 2600 (302 + 302 + 202 + 202 = 2600). /Type /Page /Annots [] << There may be disclosure of confidential information such as trade secrets. 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. /Annots [] /Annots [] /Rotate 0 /Rotate 0 >> 7. /Rotate 0 An official website of the United States government. 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. 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. Should you request a temporary injunction or push quickly for final permanent injunction. Page 3 of 15 7. /Resources 337 0 R 5. /Parent 8 0 R SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION In re: JOSE SANCHEZ Case No. /Contents [162 0 R 163 0 R 164 0 R] 64 0 obj /Contents [218 0 R 219 0 R 220 0 R] /Type /Page endstream /Parent 7 0 R /Rotate 0 /MediaBox [0 0 612 792] 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] /Rotate 0 << /MediaBox [0 0 612 792] endobj 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 /Parent 8 0 R 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. WEST PALM BEACH DIVISION . /Parent 12 0 R 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. << 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. 2 0 obj /Contents [290 0 R 291 0 R 292 0 R] The differences in the types and volume of MSW collected and in the equipment used in collection distinguish small container commercial waste collection from all other types of waste collection activities. Suing for an injunction in Florida is all about preserving the status quo. 87 0 obj /Parent 14 0 R Jurisdiction is conferred on this Court by Chapters 26, 34, 86.011. Security Personnel as Independent Contractors Part I: What Makes an Individual an Independent Contractor Instead of an Employee? In each of these markets, Allied and Republic each account for a substantial share of total revenues from commercial waste collection services. /MediaBox [0 0 612 792] /Parent 4 0 R /Annots [] >> An MSW disposal facility must be located on approved types of land and operated under prescribed procedures. 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. endstream endobj startxref /Annots [] << Injunctive relief is considered an extraordinary remedy in both State and Federal court. endobj /Parent 9 0 R 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. "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. /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] 25. 53 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. ( How long will the injunction be effective? /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] ( /MediaBox [0 0 612 792] 8 0 obj /Title (Microsoft Word - 2022-08-24 - Complaint - FINAL) /MediaBox [0 0 612 792] /Annots [] ( /Resources 181 0 R << /Type /Page /Resources 177 0 R /Type /Page 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. %PDF-1.3 % 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. 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 "Columbus, OH area" means the City of Columbus and Franklin and Delaware counties, Ohio. << /Contents [306 0 R 307 0 R 308 0 R] >> 89 0 obj 7 0 obj /Contents [126 0 R 127 0 R 128 0 R] /Annots [] M`5`i`F{qZ /Parent 7 0 R for the Middle Distrct of Florida, hereby files this complaint for permanent injunction and alleges as follows: 1. endobj << 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. << Small container commercial waste collection differs in many important respects from the collection of residential or other types of waste. 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 . /Resources 213 0 R 34. /Count 10 3 0 obj It is engaged in providing waste collection and disposal services throughout the United States. /Parent 11 0 R trailer 41 0 obj /Contents [394 0 R 395 0 R 396 0 R] 2. . 44. Is the injunction prohibitory or mandatory? A .gov website belongs to an official government organization in the United States. 62 0 obj /Contents [210 0 R 211 0 R 212 0 R] << /MediaBox [0 0 612 792] /Resources 133 0 R /CropBox [0 0 612 792] endobj << >> D. P. et al., . 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 37. /Parent 12 0 R >> /Rotate 0 /Parent 11 0 R /Annots [] /Parent 13 0 R /Type /Page /Annots [] /Contents [142 0 R 143 0 R 144 0 R] /Contents [234 0 R 235 0 R 236 0 R] /Contents [282 0 R 283 0 R 284 0 R] /Contents [366 0 R 367 0 R 368 0 R] xref << /Contents [250 0 R 251 0 R 252 0 R] Florida has reported 149 confirmed cases of COVID-19 and four deaths to date, with every expectation that these numbers will rise. "Monmouth County, NJ area"means the City of Marlboro and Monmouth County, New Jersey. clearly appears from specific facts shown by affidavit or by verified complaint that immediate or /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. /Rotate 0 /Contents [166 0 R 167 0 R 168 0 R] Garcia controll ed the MJ Companies prior to their going into receivership. endobj /MediaBox [0 0 612 792] 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. /MediaBox [0 0 612 792] /Contents [186 0 R 187 0 R 188 0 R] /Contents [326 0 R 327 0 R 328 0 R] 67. 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. >> /MediaBox [0 0 612 792] /Parent 11 0 R 62. (Compl . /Resources 397 0 R 84 0 obj /Rotate 0 ( /Resources 153 0 R /Type /Page /Annots [] /Rotate 0 6. << 25 0 obj <> endobj endobj endobj /CropBox [0 0 612 792] /CropBox [0 0 612 792] Reopen fees are due at the time a party files a pleading to reopen a proceeding if at least 90 days have . /Contents [350 0 R 351 0 R 352 0 R] endobj << /Parent 10 0 R /Rotate 0 Does the temporary injunction preserve the Status Quo or does it make a change? As such, following the process to the tee will help improve your chances for success. /Type /Page Plaintiff complains and alleges as follows: 1. /CropBox [0 0 612 792] /Resources 321 0 R /Count 10 3601, et seq. /Producer <4163726F6261742044697374696C6C65722032322E30202857696E646F7773293B206D6F646966696564207573696E67206954657874AE20372E312E3620A9323030302D323031392069546578742047726F7570204E56202841646D696E697374726174697665204F6666696365206F662074686520556E697465642053746174657320436F757274733B206C6963656E7365642076657273696F6E29> endobj 37 0 obj endobj /Type /Pages The proposed acquisition would reduce from three to two the number of significant competitors for the disposal of MSW in the Anderson, IN area. << /Pages 4 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. /CropBox [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 . /Rotate 0 endobj /Resources 329 0 R 55. 12. << 0000001187 00000 n /Parent 8 0 R Allied is the nation's second largest waste hauling and disposal company. /Creator (PScript5.dll Version 5.2.2) << /Parent 9 0 R >> endobj endobj In these markets, Allied and Republic each account for a substantial share of MSW disposal capacity. /Annots [] See Laws of Florida, Ch. 74 0 obj >> /MediaBox [0 0 612 792] 49. 1 0 obj 42. 0000006259 00000 n /Annots [] Plaintiffs Rural & Migrant Ministry, Alianza Nacional De Campesinas, El Comite . /CropBox [0 0 612 792] /Count 79 /Parent 13 0 R endobj 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. 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. /MediaBox [0 0 612 792] endobj CASE NO. 60. /Resources 385 0 R 18. 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. /Type /Pages 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. The President of the United States and the Governor of Florida have each declared a state of emergency. /Type /Page 0000000016 00000 n endobj 63. For instance, in many states, most MSW is disposed of in landfills, which are permitted under and regulated by the state. << EOs6~W\F3[_y7~r+W3nU>9YRpM/u"%1yK Ivp, Microsoft Word - 2022-08-24 - Complaint - FINAL. /Annots [] /Contents [174 0 R 175 0 R 176 0 R] 61 0 obj 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. << 52 0 obj /Contents [382 0 R 383 0 R 384 0 R] /MediaBox [0 0 612 792] "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. /Contents [150 0 R 151 0 R 152 0 R] /MediaBox [0 0 612 792] /Rotate 0 /Annots [] /Contents [374 0 R 375 0 R 376 0 R] Parties 13. 15 0 obj 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. /Rotate 0 ( Venue is proper in the Circuit Court of the Seventh Judicial Circuit, in and for 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. << << /Contents [118 0 R 119 0 R 120 0 R] /Type /Page /Rotate 0 << ( /CropBox [0 0 612 792] /Rotate 0 /Parent 14 0 R ? >> 50. 53(b), to secure preliminary and permanent injunctive relief, rescission of contracts, restitution, disgorgement, and other . /Resources 201 0 R /Rotate 0 /Rotate 0 /MediaBox [0 0 612 792] For the Court's convenience, Florida has attached a redline, as Exhibit A, showing changes from the First Amended Complaint.
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