complaint for injunctive relief florida

endobj << >> endobj 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. >> /Rotate 0 26. /Annots [] 40. /Annots [] 9. 64 0 obj /Type /Page << 33 0 obj /MediaBox [0 0 612 792] 69. 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. 17. did not involve a claim for declaratory relief. 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. /Parent 10 0 R 0000000016 00000 n /Length 1411 0 Plaintiff, PRISON LEGAL NEWS ("PLN"), a project of the Human Rights Defense . << << 65. The cost of transporting waste to a disposal site is often a substantial component of the cost of disposal. /Rotate 0 40 0 obj 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. endobj endobj /MediaBox [0 0 612 792] This action arises under Chapter 713 and 720, Florida Statutes, and under the Fair Housing Act of 1968, as amended, 42 U.S.C. Managing Partner /Rotate 0 66 0 obj Allied and Republic are two of only a few providers of waste collection or disposal services in each of the identified areas. endobj 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). /CropBox [0 0 612 792] /Type /Page /CreationDate (D:20220824140929-04'00') 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. 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. 55. /Annots [] 0000001852 00000 n 4 0 obj 8. 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. 0000001275 00000 n 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. ( 35 0 obj >> /Rotate 0 8 0 obj /Annots [] /Parent 9 0 R /Contents [382 0 R 383 0 R 384 0 R] /Title (Microsoft Word - 2022-08-24 - Complaint - FINAL) /Contents [310 0 R 311 0 R 312 0 R] << >> /Resources 229 0 R clearly appears from specific facts shown by affidavit or by verified complaint that immediate or /Type /Page /Type /Pages PLAINTIFF'S COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF . >> /Resources 269 0 R << 83.40 et seq. /Annots [] endobj /Resources 333 0 R /Contents [354 0 R 355 0 R 356 0 R] /Resources 153 0 R << JURISDICTION AND VENUE 13. There could be a negative impact on the plaintiffs public image. /Rotate 0 There are immediate expenditures necessary. endobj 49 0 obj endobj 46 0 obj 9 0 obj /Contents [130 0 R 131 0 R 132 0 R] /Annots [] /Parent 4 0 R >> /Type /Page << /Resources 241 0 R endobj 0000001469 00000 n /Rotate 0 2. /Contents [326 0 R 327 0 R 328 0 R] 84 0 obj 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. IV. /Contents [194 0 R 195 0 R 196 0 R] << /Parent 10 0 R /MediaBox [0 0 612 792] WEST PALM BEACH DIVISION . /Parent 7 0 R >> Virtually all of the MSW generated in each of these areas is disposed of in transfer stations in each of their local areas. /Rotate 0 /Contents [190 0 R 191 0 R 192 0 R] /Type /Page (ECF No. /Parent 11 0 R 10941 and Laws of Florida, Ch. >> 11 0 obj "HHI" means the Herfindahl-Hirschman Index, a commonly accepted measure of market concentration. /MediaBox [0 0 612 792] /Annots [] 12 0 obj /Length 10 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. /CropBox [0 0 612 792] /Annots [] /Annots [] endobj /Type /Page /Resources 133 0 R /Resources 185 0 R /Parent 8 0 R >> >> ( >> >> Small Container Commercial Waste Collection Service. 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. 0000001536 00000 n >> ( 21. 61 0 obj /Count 10 83 0 obj /Annots [] 1. /Type /Page /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] 59 0 obj /CropBox [0 0 612 792] stream /Count 10 /Resources 249 0 R 54 0 obj /Contents [162 0 R 163 0 R 164 0 R] >> /Annots [] /Parent 14 0 R 58 0 obj endobj << 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 /Type /Page This document is available in two formats: this web page (for browsing content) and. /Count 10 /Resources 117 0 R 58. In re Amendments to Florida Small Claims Rules, 123 So.3d 41 (Fla . /Type /Page /Type /Page See Laws of Florida, Ch. Significant new entry into the disposal of MSW in the Anderson, IN and New York City, NY areas would be difficult and time-consuming. 19 0 obj 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. endobj 48. /Parent 8 0 R 13 0 obj endobj endobj Section 13(b) of the FTC Act, 15 U.S.C. >> /MediaBox [0 0 612 792] /Annots [] "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. 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. >> 16. 88 0 obj<>stream /Type /Page 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. << /Resources 225 0 R 36. /Contents [182 0 R 183 0 R 184 0 R] /MediaBox [0 0 612 792] << /Parent 14 0 R In addition, be sure you have competent, knowledgeable and experienced counsel in your corner. /MediaBox [0 0 612 792] /CropBox [0 0 612 792] /Type /Page /Rotate 0 /Parent 4 0 R <>>> /MediaBox [0 0 612 792] On a typical small container commercial waste collection route, an operator drives a FEL vehicle to the customer's container, engages a mechanism that grasps and lifts the container over the front of the truck, and empties the container into the vehicle's storage section, where the waste is compacted and stored. "Columbus, OH area" means the City of Columbus and Franklin and Delaware counties, Ohio. /CropBox [0 0 612 792] ]\q( $QSRP@=8`) $CC16 PI_ XL Garcia is a resident of North Lauderdale, Fl orida. /Contents [374 0 R 375 0 R 376 0 R] /MediaBox [0 0 612 792] 41 0 obj /Parent 11 0 R /Annots [] /MediaBox [0 0 612 792] /Rotate 0 /Rotate 0 ( 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. /Annots [] << 51. 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. 12. 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. /Type /Page /Parent 11 0 R /Type /Page /Type /Page COMPLAINT FOR INJUNCTIVE, DECLARATORY RELIEF, AND DAMAGES Plaintiff, STATE OF FLORIDA, DEPARTMENT OF LEGAL AFFAIRS sues Defendant, TODD TEAL d/b/a WALTER A. SMITH, SNUFFY SMITH, (TEAL) and alleges: NATURE OF THE ACTION 1. REPUBLIC SERVICES, INC., 110 S.E. CASE NO. 6th Street Ft. Lauderdale, FL 33301 Defendants. << EOs6~W\F3[_y7~r+W3nU>9YRpM/u"%1yK Ivp, Microsoft Word - 2022-08-24 - Complaint - FINAL. /Rotate 0 endobj /Parent 4 0 R The extension of vote-by-mail options and other accommodations at polling places is necessary. 47. /Resources 289 0 R 85 0 obj 25, to prevent and restrain the violation by defendants of Section 7 of the Clayton Act, 15 U.S.C. endobj >> /Contents [346 0 R 347 0 R 348 0 R] /Annots [] Plaintiff LEAGUE OF WOMEN VOTERS OF FLORIDA ("LWVF" or the "League") is the Florida affiliate of the League of Women Voters of the United States. JFIF C ( endobj Share sensitive information only on official, secure websites. /Resources 157 0 R << /Resources 129 0 R 53 0 obj /Filter /FlateDecode /Type /Page /Contents [170 0 R 171 0 R 172 0 R] /CropBox [0 0 612 792] /Contents [238 0 R 239 0 R 240 0 R] After the acquisition, Republic would control over 60 percent of the roll-off hauling market, which has annual revenues of about $8 million. << In the Gulf Coast, FL area, the acquisition would reduce from four to three the number of significant competitors in the collection of small container commercial waste. /Annots [] C. Reduction in Competition As a Consequence of the Acquisition. /Annots [] /Parent 7 0 R VERIFIED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF Introduction 1. /Annots [] Republic is engaged in providing waste collection and disposal services throughout the United States. << >> >> /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] 0000000817 00000 n 38. Entry would also be made more difficult by Republic's use of long-term, automatically renewing contracts for roll-off service. /MediaBox [0 0 612 792] /Rotate 0 And yet the State of Florida (the State) has failed to take reasonable emergency measures necessary for voter participation in the face of this crisis. >> << /MediaBox [0 0 612 792] /Kids [15 0 R 16 0 R 17 0 R 18 0 R 19 0 R 20 0 R 21 0 R 22 0 R 23 0 R 24 0 R] 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. >> /MediaBox [0 0 612 792] ( Since May 7, 2021, Wilson has been the GC of a private investment firm based in Boca Raton, Florida. In contrast to a commercial collection route, a residential waste collection route is significantly more labor intensive. for the Middle Distrct of Florida, hereby files this complaint for permanent injunction and alleges as follows: 1. /Parent 10 0 R 4. The City changed its name from "New endobj MSW landfills can only accept waste up to their permitted daily capacity and have a finite life span. /Parent 9 0 R >> /Type /Page /Rotate 0 72 0 obj JacqmeinV << 24 0 obj << stream /Type /Page 60 0 obj /Contents [226 0 R 227 0 R 228 0 R] /Type /Page << JURISDICTION AND VENUE 2. /CropBox [0 0 612 792] /Resources 369 0 R << /Parent 8 0 R 12. /Contents [278 0 R 279 0 R 280 0 R] trailer Contains legal complaint for injunctive releif and civil penalties against BCX facility Site, Jacksonville, Duval County, Florida, June 7, 2004. endobj ( << 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. << /CropBox [0 0 612 792] /Type /Pages << /Parent 10 0 R 0000001373 00000 n /MediaBox [0 0 612 792] /Contents [254 0 R 255 0 R 256 0 R] 41. /Parent 9 0 R /Count 9 Republic would thus be in a position to raise the disposal costs at the landfill and transfer stations which it would own to any new or existing roll-off collection competitor in the Macon, GA area. ( 46. /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] %%EOF 70 0 obj /Contents [98 0 R 99 0 R 100 0 R] /MediaBox [0 0 612 792] /Rotate 0 ( /CropBox [0 0 612 792] "Burlington and Camden Counties, NJ area" means Burlington and Camden counties, New Jersey. 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. << /Contents [286 0 R 287 0 R 288 0 R] endstream endobj 26 0 obj <> endobj 27 0 obj <>>>/Rotate 0/Type/Page>> endobj 28 0 obj <>stream << 54. /Annots [] /Annots [] /MediaBox [0 0 612 792] endobj << "New York City, NY area" means the Borough of Brooklyn, New York. /Rotate 0 69 0 obj /Parent 12 0 R /Resources 309 0 R /Resources 277 0 R /Resources 401 0 R 5. >> /Rotate 0 /Type /Page 55 0 obj >> 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. 2320 0 obj<> endobj In order to obtain comparable operating efficiency, a new firm must achieve route density comparable to existing firms. . 59. That plaintiff receive such other and further relief as the case requires and the Court deems proper; and. /Resources 101 0 R /Resources 149 0 R xb```c``b`f`0gg@ ~G@|*{jd`q%T3e83:! @`HsXD|",e0`A 21. advance, Plaintiffs seek immediate declaratory and injunctive relief that directs Defendants to permit a designated representative of each affected candidate and political party into the recount room, as Florida law requires. >> /CropBox [0 0 612 792] /Annots [] 0000003868 00000 n /CropBox [0 0 612 792] /Parent 4 0 R /CropBox [0 0 612 792] /Rotate 0 endobj prescribed by these rules and by section 51.011, Florida Statutes, the statutory provision shall govern. /MediaBox [0 0 612 792] /Resources 353 0 R /Rotate 0 18. Federal, state and local safety, environmental, zoning, and permit laws and regulations dictate critical aspects of storage, handling, transportation, processing and disposal of MSW. /Contents [154 0 R 155 0 R 156 0 R] /Rotate 0 11. /Parent 7 0 R /Contents [122 0 R 123 0 R 124 0 R] /Type /Page In these markets, Allied and Republic each account for a substantial share of MSW disposal capacity. $4%&'()*56789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz r! 67 0 obj /CropBox [0 0 612 792] /Type /Page /Rotate 0 /Parent 10 0 R 18 0 obj COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF Introduction 1. endobj "Albany, NY area" means the City of Albany and Albany, Schenectady, Saratoga, and Rensselaer counties, New York. 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. The HHI increases both as the number of firms in the market decreases and as the disparity in size between those firms increases. This action is filed by the United States of America under Section 15 of the Clayton Act, 15 U.S.C. /Contents [270 0 R 271 0 R 272 0 R] h|VrH}Weo2)RXBr|:=%ts?mlteQG :C:+rl86#m0GcfFmMb`4&;|Xy|^Q(&Y Jf#mb!nDlpfIi QB*Mg< /Contents [210 0 R 211 0 R 212 0 R] endobj /Contents [302 0 R 303 0 R 304 0 R] 16 0 obj 82 0 obj 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. /Annots [] /Annots [] /Contents [158 0 R 159 0 R 160 0 R] (ECF No. endobj >> hb```f`` $V30 1;oO_Ia`sF!gbl!O| ` Local public opposition often makes it more difficult and costly, and increases the time and uncertainty of successfully permitting a facility. /Rotate 0 >> /Rotate 0 /Parent 14 0 R /MediaBox [0 0 612 792] 3. What impact will it have on third-parties and employees? 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. << 1 1 On February 7, 2023 and February 16, 2023, Plaintiff filed motions for preliminary 2 injunctive relief. %PDF-1.5 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). /Type /Page >> /Type /Page /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] 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. /Annots [] /CropBox [0 0 612 792] endstream /Rotate 0 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. /CropBox [0 0 612 792] /MediaBox [0 0 612 792] 56. >> /Rotate 0 /Type /Pages Amended Complaint "Motion") [ECF(the No. ( /Rotate 0 endobj /Contents [234 0 R 235 0 R 236 0 R] /Contents [306 0 R 307 0 R 308 0 R] /MediaBox [0 0 612 792] /Parent 7 0 R endobj /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] 78 0 obj 44. /CropBox [0 0 612 792] ;("(;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;; 21-81099-CIV-CANNON/Reinhart . 42. /Type /Page /MediaBox [0 0 612 792] 2201-202, and . /Annots [] /CropBox [0 0 612 792] Private waste haulers typically contract directly with customers for the collection of waste generated by commercial accounts. /CropBox [0 0 612 792] /Type /Page 12102(1)-(2), the regulations implementing the . the Florida Deceptive and Unfair Trade Practices Act, Chapter 501, Part II, Florida Statutes ("FDUTPA"), which authorizes the State of Florida to seek, and the Court to order, permanent injunctive relief, recission or reformation of contracts, consumer restitution, the refund of monies The operator continues along the route, collecting MSW from each of the commercial accounts until the vehicle is full. /Rotate 0 3. /CropBox [0 0 612 792] /MediaBox [0 0 612 792] 28 0 obj << /Contents [366 0 R 367 0 R 368 0 R] It is economically impractical for a roll-off waste collection firm to serve metropolitan areas from a distant base. - All Rights Reserved, Community Advocacy & Social Responsibility, Traditional Contract Principles Impacting Enforcement of Noncompete Agreements in Florida. >> /Annots [] /MediaBox [0 0 612 792] /Contents [282 0 R 283 0 R 284 0 R] 37 0 obj 1331 and 1337. /Contents [142 0 R 143 0 R 144 0 R] /Contents [250 0 R 251 0 R 252 0 R] 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. /Count 10 0 76 0 obj 7402(a) to prevent such conduct. U.S. v. Allied Waste Industries, Inc. and Republic Services, Inc. >> /Parent 11 0 R /CropBox [0 0 612 792] /Annots [] endobj /Annots [] Access to competitive disposal sites and reasonable disposal costs are important to providers of roll-off collection services. /Type /Page % relief pursuant to Chapter 86, Florida Statutes. /Type /Page Download the PDF of the Complaint IN THIS PUBLICATION Summary Issues COVID-19 Anyone who fails to dispose of MSW in an approved facility can be subject to severe civil and criminal penalties. << /Type /Page /Rotate 0 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. /CropBox [0 0 612 792] << /Annots [] /Parent 8 0 R 1391(c). /Contents [318 0 R 319 0 R 320 0 R] /Contents [134 0 R 135 0 R 136 0 R] 25. 52. 42 0 obj MSW has physical characteristics that readily distinguish it from other liquid or solid waste. 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. /Parent 12 0 R Anderson, IN and New York City, NY are two such areas. The Court has jurisdiction over this action and over the parties pursuant to 15 U.S.C. Obtaining a permit to construct a new disposal facility or to expand an existing one is a costly and time-consuming process, which typically takes many years to conclude. Because of the differences in the collection process, residential customers and commercial customers usually are organized into separate routes. 18. /CropBox [0 0 612 792] D. P. et al., . } !1AQa"q2#BR$3br 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 337 0 R /Contents [218 0 R 219 0 R 220 0 R] /Annots [] D. Entry Into Commercial Waste Collection of MSW. endobj /Type /Page 0000000879 00000 n 89 0 obj 5 0 obj ( Charles B. Jimerson endobj /Type /Page 75 0 obj >> /Parent 9 0 R /Contents [146 0 R 147 0 R 148 0 R] 3 0 obj /Contents [166 0 R 167 0 R 168 0 R] /CropBox [0 0 612 792] 74 0 obj /Resources 373 0 R 0000002235 00000 n 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. << "Monmouth County, NJ area"means the City of Marlboro and Monmouth County, New Jersey. 51 0 obj 30 0 obj <>/Filter/FlateDecode/ID[<3860DCF29749FC4EACF121159FB5FA73><3860DCF29749FC4EACF121159FB5FA73>]/Index[25 7]/Info 24 0 R/Length 36/Prev 968458/Root 26 0 R/Size 32/Type/XRef/W[1 2 0]>>stream "Macon, GA area" means the City of Macon and Bibb, Peach and parts of Houston, Jones and Monroe counties, Georgia. << 67. Preference Primary election in Florida. /Type /Page /MediaBox [0 0 612 792] /Parent 13 0 R /Kids [75 0 R 76 0 R 77 0 R 78 0 R 79 0 R 80 0 R 81 0 R 82 0 R 83 0 R 84 0 R] << 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. ? provide relief to all the individuals affected by APD's action. /Resources 393 0 R /CropBox [0 0 612 792]

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