complaint for injunctive relief florida complaint for injunctive relief florida

>> /Rotate 0 /CropBox [0 0 612 792] ( /Annots [] /Annots [] >> 49 0 obj endobj 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. 51 0 obj /MediaBox [0 0 612 792] endobj C. Reduction in Competition As a Consequence of the Acquisition. >> /Annots [] What impact will it have on third-parties and employees? /Type /Page /CropBox [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. On July 28 and October 7, 1999, in twelve (12) separate purchase agreements, defendants agreed to exchange assets of various subsidiary companies ('the acquisitions"). /Rotate 0 /Parent 7 0 R 13. /Annots [] << /Annots [] 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 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. /Rotate 0 EOs6~W\F3[_y7~r+W3nU>9YRpM/u"%1yK Ivp, Microsoft Word - 2022-08-24 - Complaint - FINAL. ( 37. /CropBox [0 0 612 792] << 5 0 obj 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. /Contents [98 0 R 99 0 R 100 0 R] /Parent 12 0 R /Contents [306 0 R 307 0 R 308 0 R] ( >> << /Parent 10 0 R << 66 0 obj Therefore, it should not be a decision made lightly. >> /Rotate 0 22. Reopen fees are due at the time a party files a pleading to reopen a proceeding if at least 90 days have . 88 0 obj >> This is an action for injunctive relief. Security Personnel as Independent Contractors Part I: What Makes an Individual an Independent Contractor Instead of an Employee? Does the courts have ability to enforce what you are requesting? 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. PDF Florida Small Claims Rules Annotated 2020 - The Florida Bar endstream endobj 2333 0 obj<>/W[1 1 1]/Type/XRef/Index[246 2074]>>stream /Parent 13 0 R 80 0 obj 37 0 obj /MediaBox [0 0 612 792] /CropBox [0 0 612 792] /Parent 7 0 R >> 1. /Rotate 0 /Parent 12 0 R Managing Partner /Parent 4 0 R /Resources 197 0 R /CropBox [0 0 612 792] >> Significant new entry into the disposal of MSW in the Anderson, IN and New York City, NY areas would be difficult and time-consuming. /Annots [] Complaint for Injunctive Relief and Damages for Breach of Very often courts do not grant injunctions if there is not a lot of specificity and practicality in the request for an injunction. Roll-off waste collection services are generally provided in localized areas because a roll-off truck cannot be efficiently or profitably driven significantly longer distances than those driven by a competitor to collect and dispose of the waste. >> 83 0 obj 72 0 obj In order to obtain comparable operating efficiency, a new firm must achieve route density comparable to existing firms. This is an action for permanent injunctive relief, declaratory relief, and /Parent 4 0 R /CropBox [0 0 612 792] /Type /Page /Resources 293 0 R /Type /Page The President of the United States and the Governor of Florida have each declared a state of emergency. endobj judgment, and preliminary and permanent injunctive relief and damages. /Resources 329 0 R /Annots [] >> /Rotate 0 /Nums [0 6 0 R] /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. 31 0 obj /Type /Page The county court may issue a temporary and permanent injunction where appropriate for violation of ss. did not involve a claim for declaratory relief. >> 1391, . 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. endobj 86 0 obj Should you request a temporary injunction or push quickly for final permanent injunction. /Resources 281 0 R /MediaBox [0 0 612 792] Florida has reported 149 confirmed cases of COVID-19 and four deaths to date, with every expectation that these numbers will rise. /Type /Page /CropBox [0 0 612 792] endobj /Contents [266 0 R 267 0 R 268 0 R] /Annots [] << /Type /Page /Type /Page /Type /Page endobj ( 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. /Type /Page 47 0 obj Defendant is defined as a "Public Accommodation" within meaning of Title III Plaintiff, PRISON LEGAL NEWS ("PLN"), a project of the Human Rights Defense . US District Court for the Southern District of Florida: Presiding Judge: Raag Singhal: Nature of Suit: Trademark: Cause of Action: 15 U.S.C. /Resources 333 0 R 3. 76 13 endobj << /Type /Page /Type /Page /Rotate 0 /CropBox [0 0 612 792] 0000000556 00000 n /MediaBox [0 0 612 792] /Contents [94 0 R 95 0 R 96 0 R] Waiver recipients are entitled to continuation of services that they are currently receiving through the completion of the fair hearing ASSOCIATION OF FLORIDA, MIGRANT CLINICIANS NETWORK, PINEROS Y . /CropBox [0 0 612 792] /CropBox [0 0 612 792] Complaint for Injunctive Relief | ATR | Department of Justice /MediaBox [0 0 612 792] 24 0 obj 58 0 obj %PDF-1.5 Statutes & Constitution :View Statutes : Online Sunshine /Annots [] "HHI" means the Herfindahl-Hirschman Index, a commonly accepted measure of market concentration. PDF COMPLAINT FOR INJUNCTIVE RELIEF AND SANCTIONS PARTIES - The Wall Street In 1999, Allied reported total revenues of approximately $6 billion. 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. PDF United States District Court Middle District of Florida Tampa Division Complaint for Injunctive Relief Case (s): U.S. v. Allied Waste Industries, Inc. and Republic Services, Inc. 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. /Contents [350 0 R 351 0 R 352 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. /Resources 137 0 R Does the injunction provide broad or limited relief? 54 0 obj /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] endobj /Contents [258 0 R 259 0 R 260 0 R] The customer's MSW is stored in much smaller containers (e.g., garbage bags or trash cans) and instead of FEL trucks, waste collection firms routinely use REL or side-load trucks, manned by larger crews (usually, two-or three-person teams). 15. /Type /Catalog >> /Parent 8 0 R endobj The next step is careful preparation before the temporary injunction hearing. /Resources 201 0 R /CropBox [0 0 612 792] endstream "Memphis, TN area" means Shelby County, Tennessee; Desoto County, Mississippi, and Crittenden County, Arkansas. 8. endobj 0000001563 00000 n /CropBox [0 0 612 792] /Rotate 0 CASE NO. /Annots [] << /Rotate 0 Suing for an injunction in Florida is all about preserving the status quo. 60. /Parent 11 0 R ( /Type /Page /Title (Microsoft Word - 2022-08-24 - Complaint - FINAL) >> 7.) 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. /Type /Page /Contents [114 0 R 115 0 R 116 0 R] 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 . 42 0 obj 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). /Contents [382 0 R 383 0 R 384 0 R] 1 1 On February 7, 2023 and February 16, 2023, Plaintiff filed motions for preliminary 2 injunctive relief. /Contents [262 0 R 263 0 R 264 0 R] /Resources 337 0 R /Rotate 0 70 0 obj /MediaBox [0 0 612 792] 2. Plaintiffs Rural & Migrant Ministry, Alianza Nacional De Campesinas, El Comite . >> /Resources 369 0 R and Florida Statute 86.011, et seq. /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] /Annots [] D. Entry Into Commercial Waste Collection of MSW. /CropBox [0 0 612 792] >> << /MediaBox [0 0 612 792] endobj ( Allied is the nation's second largest waste hauling and disposal company. /CropBox [0 0 612 792] "Gulf Coast, FL area" means Escambia, Santa Rosa, and Okaloosa counties, Florida. 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. Is there any vagueness, or is everything extremely clear? /Parent 10 0 R /Contents [186 0 R 187 0 R 188 0 R] "Columbus, OH area" means the City of Columbus and Franklin and Delaware counties, Ohio. However, temporary injunctive relief may be granted without the posting of a bond in the following situations: 1) injunctions entered "on the pleading of a municipality or the state or any officer, agency, or political subdivision thereof"; or 2) injunctions "issued solely to prevent physical injury or abuse of a natural person." 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. /MediaBox [0 0 612 792] endobj Virtually all of the MSW generated in each of these areas is disposed of in transfer stations in each of their local areas. 0000001852 00000 n ( 40. /Resources 225 0 R 0000003645 00000 n /Parent 13 0 R Judgment for Permanent Injunctive Relief against MJ Taxes on October 1, 2021. /Resources 357 0 R 12 0 obj 4. have exclusive jurisdiction: (a) In all actions at law cognizable by the county . "Nashville, TN area" means the City of Nashville and Davidson, Sumner, Williamson, Rutherford, Wilson, the southeastern part of Robertson, and the eastern part of Cheatham counties, Tennessee. << /MediaBox [0 0 612 792] /Parent 10 0 R 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). 61. 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 Monmouth County, NJ area. << << /Rotate 0 trailer /CropBox [0 0 612 792] x1 04) F&`/MFWxC. /MediaBox [0 0 612 792] 41. This is a civil action brought by the United States of America to enjoin defendant . MSW has physical characteristics that readily distinguish it from other liquid or solid waste. 27. In 1998, for example, these three transfer stations disposed of over 85 percent of the MSW generated in the Anderson, IN area. 90 0 obj The transactions likely will have the following effects, among others: 1. 53(b), to secure preliminary and permanent injunctive relief, rescission of contracts, restitution, disgorgement, and other . /MediaBox [0 0 612 792] /Annots [] /Contents [238 0 R 239 0 R 240 0 R] Omega SA v. The Individuals, Business Entities, and Unincorporated /Resources 253 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. /Parent 10 0 R /Type /Page /Annots [] /Type /Page /Parent 13 0 R endstream endobj ( /Rotate 0 /Annots [] 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. /MediaBox [0 0 612 792] 22 0 obj 2 0 obj /Type /Page /Contents [398 0 R 399 0 R 400 0 R] /Type /Page /PageLabels 3 0 R /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. (PC) Carroll v. Vallejo Police Department, et al., No. 1:2023cv00004 /Type /Page /Type /Page "Anderson, IN area" means the City of Anderson and Madison County, Indiana. %&'()*456789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz w !1AQaq"2B #3Rbr /Parent 11 0 R 11 0 obj >> endobj ( 40 0 obj How to Obtain a Temporary (Preliminary) Injunction in Florida - Ewusiak Law 1391(c). endobj /Parent 7 0 R endobj /Type /Page /MediaBox [0 0 612 792] /Resources 261 0 R >> M`5`i`F{qZ 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. /CropBox [0 0 612 792] 0000003404 00000 n /Rotate 0 63 0 obj Typical commercial waste collection customers include office and apartment buildings and retail establishments (e.g. >> 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. /CropBox [0 0 612 792] /Contents [126 0 R 127 0 R 128 0 R] >> /Parent 13 0 R /Rotate 0 /Kids [65 0 R 66 0 R 67 0 R 68 0 R 69 0 R 70 0 R 71 0 R 72 0 R 73 0 R 74 0 R] 0000002929 00000 n /Type /Page /Contents [174 0 R 175 0 R 176 0 R] /Contents [182 0 R 183 0 R 184 0 R] 74 0 obj /Annots [] /Contents [134 0 R 135 0 R 136 0 R] /Parent 9 0 R /Annots [] PDF Complaint for Injunctive and Other Relief and Demand for Jury Trial I 12. Venue properly lies in the Southern Distri ct of Florida pursuant to 28 U.S.C. /Resources 233 0 R - All Rights Reserved, Community Advocacy & Social Responsibility, Traditional Contract Principles Impacting Enforcement of Noncompete Agreements in Florida. >> /Count 10 /MediaBox [0 0 612 792] endobj /MediaBox [0 0 612 792] IV. << /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. /Contents [138 0 R 139 0 R 140 0 R] << /Rotate 0 endobj In its 1998 fiscal year, Republic reported total revenues of approximately $1.8 billion. /Contents [102 0 R 103 0 R 104 0 R] endobj <>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> 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. 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. endobj << endobj 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. The HHI takes into account the relative size and distribution of the firms in a market and approaches zero when a market consists of a large number of firms of relatively equal size. 12. xref endobj << << endobj /Resources 309 0 R /Annots [] /Type /Page endobj /Resources 349 0 R Complaint for Emergency Injunctive Relief in Florida Primary 43 0 obj Venue is proper in the Circuit Court of the Seventh Judicial Circuit, in and for On August 20, . 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. /Parent 8 0 R ;("(;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;; /Contents [222 0 R 223 0 R 224 0 R] /Type /Page /MediaBox [0 0 612 792] 23 0 obj endobj /Type /Page << /Parent 7 0 R clearly appears from specific facts shown by affidavit or by verified complaint that immediate or 35. /Type /Page xb```c``b`f`0gg@ ~G@|*{jd`q%T3e83:! @`HsXD|",e0`A 21. /Resources 305 0 R /Resources 361 0 R >> 5.) 94 0 obj 50. /Parent 8 0 R /Contents [330 0 R 331 0 R 332 0 R] /Annots [] PDF United States District Court Northern District of Florida Pensacola ("MFS"), is a Florida corporation that has a principal place of . /MediaBox [0 0 612 792] 0000001536 00000 n endobj /Count 9 0000001994 00000 n relief pursuant to Chapter 86, Florida Statutes. /Resources 221 0 R 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. IV. 23. >> << /Resources 177 0 R >> PDF Complaint for Injunctive Relief, Damages, The United States is entitled to injunctive relief under 26 U.S.C. << >> >> 3601, et seq. << /ModDate (D:20220824143048-04'00') << /Annots [] A .gov website belongs to an official government organization in the United States. /Parent 8 0 R 21 0 obj /Type /Page << ( /Annots [] 3. /Parent 12 0 R 18. << /CropBox [0 0 612 792] /Parent 13 0 R /Rotate 0 /MediaBox [0 0 612 792] ( 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. endobj /Annots [] PDF Verified Second Amended Complaint for Injunctive and Declaratory Relief It is economically impractical for a roll-off waste collection firm to serve metropolitan areas from a distant base. /MediaBox [0 0 612 792] << >> for the Middle Distrct of Florida, hereby files this complaint for permanent injunction and alleges as follows: 1. /Contents [322 0 R 323 0 R 324 0 R] endobj << /Rotate 0 >> Complaint for Injunctive Relief and Civil Penalties | US EPA DECLARATORY AND INJUNCTIVE RELIEF* * Pursuant to Rule 15(a)(2), Florida files the Second Amended Complaint with the written consent of Defendants. 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. "Albany, NY area" means the City of Albany and Albany, Schenectady, Saratoga, and Rensselaer counties, New York. It is calculated by squaring the market share of each firm competing in the market and then summing the resulting numbers. /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] /Contents [374 0 R 375 0 R 376 0 R] /CropBox [0 0 612 792] 2201 a nd 2202. 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. See Laws of Florida, Ch. /Contents [202 0 R 203 0 R 204 0 R] /Contents [198 0 R 199 0 R 200 0 R] 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. /Annots [] << 57. /Parent 13 0 R /MediaBox [0 0 612 792] >> /Annots [] JURISDICTION AND VENUE 2. >> /Resources 161 0 R /CropBox [0 0 612 792] In the event of a small but significant increase in the price of the disposal of MSW in the Anderson, IN or New York City, NY areas, haulers of MSW generated in each area would not turn to disposal facilities outside their area. << /Annots [] /Rotate 0 /MediaBox [0 0 612 792] /Annots [] 18. /CropBox [0 0 612 792] >> The cost of transporting waste to a disposal site is often a substantial component of the cost of disposal. /Resources 145 0 R There could be a negative impact on the plaintiffs public image. >> 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. >> hbbd`b`rfb`gb` # /MediaBox [0 0 612 792] /Type /Page endobj Allied and Republic are two of only a few providers of waste collection or disposal services in each of the identified areas. 28. /MediaBox [0 0 612 792] 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 /CropBox [0 0 612 792] /Resources 193 0 R >> /Rotate 0 /CropBox [0 0 612 792] /Type /Page /CropBox [0 0 612 792] % endobj >> /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] /Type /Page 4 0 obj PDF IN THE CIRCUIT COURT OF THE - Florida Attorney General /Contents [166 0 R 167 0 R 168 0 R] %PDF-1.4 % Garcia is a resident of North Lauderdale, Fl orida. In areas where it is not practical to construct and permit a landfill, it is necessary to put in a transfer station to get the waste to a more distant landfill. 45 0 obj Permit restrictions often impose severe limitations on the type and amount of waste that can be disposed of at landfills. << /Type /Page /Rotate 0 >> /CropBox [0 0 612 792] 21. 0000001187 00000 n 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. 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. /Type /Pages /MediaBox [0 0 612 792] /CropBox [0 0 612 792] <<14CA263718F8354CB34DA495C0495A29>]>> /Resources 277 0 R 56. << /Resources 289 0 R 7. /Annots [] Republic is engaged in providing waste collection and disposal services throughout the United States. << << << /Contents [162 0 R 163 0 R 164 0 R] /Rotate 0 Republic is a Delaware corporation with its principal office in Ft. Lauderdale, Florida. In each of these markets, Allied and Republic each account for a substantial share of total revenues from commercial waste collection services. The proposed acquisition would reduce from four to three the number of significant firms that compete in small container commercial waste collection service in the Memphis, TN area. endobj /MediaBox [0 0 612 792] << /MediaBox [0 0 612 792] ( /Rotate 0 /Annots [] /Annots [] /Annots [] /Annots [] /Contents [310 0 R 311 0 R 312 0 R] /Contents [278 0 R 279 0 R 280 0 R] /Rotate 0 /Parent 11 0 R >> /Rotate 0 /MediaBox [0 0 612 792] 22408. endobj 1114 Trademark Infringement . 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). 61 0 obj /Rotate 0 endobj 8 0 obj /CropBox [0 0 612 792] /Resources 153 0 R ( This action is filed by the United States of America under Section 15 of the Clayton Act, 15 U.S.C. 25, to prevent and restrain the violation by defendants of Section 7 of the Clayton Act, 15 U.S.C. GsYzQh50ee' /Type /Page /Resources 301 0 R /Annots [] /MediaBox [0 0 612 792] ( >> /Resources 229 0 R 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.