How To Cancel Hotworx Subscription, $55k A Year Is How Much Biweekly After Taxes, Deka Dialysis Machine, What Does It Mean To Ping Someone On Teams, Jessie James Decker Tex Mex Casserole, Articles C

endobj /CropBox [0 0 612 792] Complaint for Injunctive Relief . endobj /Contents [362 0 R 363 0 R 364 0 R] COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF Introduction 1. >> /Subtype /XML ( /Rotate 0 37. 27 0 obj /Contents [114 0 R 115 0 R 116 0 R] "Macon, GA area" means the City of Macon and Bibb, Peach and parts of Houston, Jones and Monroe counties, Georgia. /Contents [138 0 R 139 0 R 140 0 R] /Type /Page 2. Jurisdiction is conferred on this Court by Chapters 26, 34, 86.011. >> ;,hn \ic6rZFi+|:GsL$KGqzed8;M+"N7i~4Dr?_1hHa:`R[B%Qm*?u9Lh=?y%x8;e$AD+xx << /Parent 4 0 R /Parent 8 0 R /Annots [] endobj 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. /Resources 221 0 R /Annots [] hb```f`` $V30 1;oO_Ia`sF!gbl!O| ` /Annots [] << /Resources 225 0 R /Rotate 0 >> Private waste haulers typically contract directly with customers for the collection of waste generated by commercial accounts. 9. /Type /Pages << 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. 55. /MediaBox [0 0 612 792] /Rotate 0 /Annots [] 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. startxref /Contents [106 0 R 107 0 R 108 0 R] /Rotate 0 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. endobj endobj /MediaBox [0 0 612 792] << /Contents [234 0 R 235 0 R 236 0 R] prescribed by these rules and by section 51.011, Florida Statutes, the statutory provision shall govern. 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 $5 million. /Parent 8 0 R 5.) /Annots [] >> /Contents [182 0 R 183 0 R 184 0 R] << >> . /Resources 177 0 R endobj /CropBox [0 0 612 792] endobj /CropBox [0 0 612 792] /MediaBox [0 0 612 792] _______/s/____________________ Donna E. Patterson Deputy Assistant Attorney General, _________/s/__________________ Constance K. Robinson Director of Operations and Merger Enforcement, ________/s/___________________ J. Robert Kramer II Chief, Litigation II Section, _________/s/__________________ Willie L. Hudgins Assistant Chief, Litigation II Section, ___________/s/________________ Arthur A. Feiveson IL Bar # 3125793, __________/s/_________________ Michael K. Hammaker DC Bar # 233684, __________/s/_________________ Chinita M. Sinkler MD Bar, U.S. Department of Justice Antitrust Division, Litigation II Section 1401 H Street, NW, Suite 3000 Washington, D.C. 20530 (202) 307-0924. 0000000592 00000 n 74 0 obj provide preliminary and permanent injunctive relief pursuant to Rules 57 and 64 of the Federal Rules of Civil Procedure and 28 U.S.C. >> For a number of reasons, landfills may not be located close to where the waste is generated. Florida has reported 149 confirmed cases of COVID-19 and four deaths to date, with every expectation that these numbers will rise. ( >> /Contents [386 0 R 387 0 R 388 0 R] %%EOF /Rotate 0 24. /Resources 169 0 R #%$""!&+7/&)4)! endobj endobj /Contents [102 0 R 103 0 R 104 0 R] "Albany, NY area" means the City of Albany and Albany, Schenectady, Saratoga, and Rensselaer counties, New York. /Annots [] endobj 58 0 obj endobj 64. /Resources 185 0 R /Rotate 0 5. ? D. P. et al., . /MediaBox [0 0 612 792] 44. << endobj /Rotate 0 /Contents [218 0 R 219 0 R 220 0 R] /Rotate 0 /Rotate 0 not 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. endobj 94 0 obj 0000001852 00000 n 6108, to obtain temporary, preliminary, and permanent injunctive relief, rescission or reformation of contracts, restitution, the refund of monies paid, disgorgement of ill-gotten . << The proposed acquisition would reduce from three to two the number of significant competitors for the disposal of MSW in the Anderson, IN area. endstream endobj startxref Security Personnel as Independent Contractors Part I: What Makes an Individual an Independent Contractor Instead of an Employee? /Rotate 0 /Contents [126 0 R 127 0 R 128 0 R] (ECF No. THIS COURT'S POWER TO GRANT RELIEF 84. endobj /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] /MediaBox [0 0 612 792] MSW has physical characteristics that readily distinguish it from other liquid or solid waste. /Resources 241 0 R /Parent 7 0 R >> /MediaBox [0 0 612 792] 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. /Contents [370 0 R 371 0 R 372 0 R] This document is available in two formats: this web page (for browsing content) and. /Parent 7 0 R >> /Resources 405 0 R /Contents [158 0 R 159 0 R 160 0 R] Alexdex. /Resources 285 0 R /Resources 309 0 R << >> endobj 73 0 obj >> Defendant is defined as a "Public Accommodation" within meaning of Title III The cost advantage of local landfills limits the areas where MSW can be economically transported and disposed of by haulers and creates localized markets for MSW disposal services. /Annots [] 0000001563 00000 n endobj /Type /Page stream /Annots [] /Resources 377 0 R 85 0 obj 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. /MediaBox [0 0 612 792] Is there any vagueness, or is everything extremely clear? >> 0000002992 00000 n /Type /Page << 0000003946 00000 n << << After the acquisition, Allied would control roughly 69 percent--and two firms over 90 percent--of the small container commercial waste hauling market, which has annual revenues exceeding $25 million. << This action is filed by the United States of America under Section 15 of the Clayton Act, 15 U.S.C. /Resources 353 0 R %PDF-1.6 See also Chapter 224.08, Special Acts of Florida, 1943. 53(b), empowers this Court to grant injunctive and such other relief as the Court may deem appropriate to halt /Rotate 0 ( /Parent 12 0 R /MediaBox [0 0 612 792] Garcia controll ed the MJ Companies prior to their going into receivership. /Annots [] Often businesses do not consider the implications for taking this action. /Contents [222 0 R 223 0 R 224 0 R] >> endstream endobj 2333 0 obj<>/W[1 1 1]/Type/XRef/Index[246 2074]>>stream /CropBox [0 0 612 792] /Annots [] 30 0 obj <>/Filter/FlateDecode/ID[<3860DCF29749FC4EACF121159FB5FA73><3860DCF29749FC4EACF121159FB5FA73>]/Index[25 7]/Info 24 0 R/Length 36/Prev 968458/Root 26 0 R/Size 32/Type/XRef/W[1 2 0]>>stream After the acquisition, 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. /Resources 365 0 R /CropBox [0 0 612 792] /Kids [7 0 R 8 0 R 9 0 R 10 0 R 11 0 R 12 0 R 13 0 R 14 0 R] /CropBox [0 0 612 792] /Pages 4 0 R /Resources 157 0 R VERIFIED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF Introduction 1. prices charged by roll-off waste collection firms in the Macon, GA area market will likely increase. /Annots [] endobj 8 0 obj /Type /Page 0 %PDF-1.5 % /Annots [] /CropBox [0 0 612 792] /MediaBox [0 0 612 792] 2 0 obj /Type /Page 0000006750 00000 n /Resources 253 0 R /MediaBox [0 0 612 792] 0000001469 00000 n >> /Annots [] endobj >> endobj /Count 10 /CropBox [0 0 612 792] /Annots [] endobj endobj 18. Republic is engaged in providing waste collection and disposal services throughout the United States. <>>> 35. Firms that compete in the disposal of MSW generated in the Anderson, IN or New York City, NY areas can profitably increase their charges for disposal of MSW generated in each area without losing significant sales to more distant disposal sites. /Resources 393 0 R /MediaBox [0 0 612 792] x+ | >> 47 0 obj /CropBox [0 0 612 792] /Type /Page /MediaBox [0 0 612 792] /CropBox [0 0 612 792] What happens if the temporary injunction is not granted? /Type /Pages 93 0 obj ( It is engaged in providing waste collection and disposal services throughout the United States. << /Parent 10 0 R >> << This is a must-watch video before you consider whether to sue for injunction. /Parent 10 0 R /Rotate 0 /Resources 205 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. 22 and 28 U.S.C. >> ("MFS"), is a Florida corporation that has a principal place of . Universities have sent students home, people are remaining in quarantine, poll workers are dropping out, and Supervisors of Elections have closed or moved 112 polling places in 22 counties, in many cases less than a week before the election. /Parent 11 0 R /CropBox [0 0 612 792] >> /MediaBox [0 0 612 792] for the Middle Distrct of Florida, hereby files this complaint for permanent injunction and alleges as follows: 1. /MediaBox [0 0 612 792] /Contents [378 0 R 379 0 R 380 0 R] /CropBox [0 0 612 792] 91 0 obj /MediaBox [0 0 612 792] /CropBox [0 0 612 792] /Annots [] h|VrH}Weo2)RXBr|:=%ts?mlteQG :C:+rl86#m0GcfFmMb`4&;|Xy|^Q(&Y Jf#mb!nDlpfIi QB*Mg< DECLARATORY AND INJUNCTIVE RELIEF* * Pursuant to Rule 15(a)(2), Florida files the Second Amended Complaint with the written consent of Defendants. /Parent 12 0 R H*23430P AsKN$r{(s << 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. After the acquisition, Republic would control over 85 percent of the small container commercial waste hauling market, which has annual revenues of about $5 million. 55 0 obj /CropBox [0 0 612 792] /MediaBox [0 0 612 792] /CropBox [0 0 612 792] Parties 13. ( 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. /Parent 4 0 R /CropBox [0 0 612 792] 1. /Contents [154 0 R 155 0 R 156 0 R] 15 0 obj /Resources 121 0 R /Annots [] /Type /Page /Annots [] $4%&'()*56789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz r! 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. Permit restrictions often impose severe limitations on the type and amount of waste that can be disposed of at landfills. 3. A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. /Contents [246 0 R 247 0 R 248 0 R] %PDF-1.4 % "Memphis, TN area" means Shelby County, Tennessee; Desoto County, Mississippi, and Crittenden County, Arkansas. << /Rotate 0 endobj /MediaBox [0 0 612 792] << 63. 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. 3. /CropBox [0 0 612 792] The county court may issue a temporary and permanent injunction where appropriate for violation of ss. "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. >> /MediaBox [0 0 612 792] 32 0 obj /Resources 233 0 R 0000001994 00000 n 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. /Type /Page >> /Rotate 0 /MediaBox [0 0 612 792] /Parent 10 0 R /Type /Page >> endobj endobj /Contents [210 0 R 211 0 R 212 0 R] 65 0 obj >> 72 0 obj ]\q( $QSRP@=8`) $CC16 PI_ XL 16 0 obj endobj Z( 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. /Rotate 0 << 10941 and Laws of Florida, Ch. /Count 10 /Kids [85 0 R 86 0 R 87 0 R 88 0 R 89 0 R 90 0 R 91 0 R 92 0 R 93 0 R] /Rotate 0 /Resources 385 0 R << 0000006259 00000 n 0 51. /Type /Page 3 0 obj /Parent 9 0 R endobj /Parent 11 0 R >> Roll-off waste haulers, therefore, generally establish garages and related facilities within each major local area served. Complaint for Emergency Injunctive Relief in Florida Primary The global coronavirus pandemic threatens to disrupt the Presidential Preference Primary election in Florida. Small container commercial waste collection differs in many important respects from the collection of residential or other types of waste. /Resources 229 0 R /Resources 313 0 R endobj C. Reduction in Competition As a Consequence of the Acquisition. The next step is careful preparation before the temporary injunction hearing. << 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] /CropBox [0 0 612 792] /Annots [] /PageLabels 3 0 R Rule 1.610 of the Florida Rules of Civil Procedure governs requests for temporary injunctions. 6. >> 39. 14 0 obj ( On September 8, 2021, the Court, by consent, entered a preliminary injunction against Garcia. 13 0 obj 79 0 obj >> /Resources 357 0 R /Resources 257 0 R 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. /CropBox [0 0 612 792] Access to competitive disposal sites and reasonable disposal costs are important to providers of roll-off collection services. /Type /Page /Parent 11 0 R 21-81099-CIV-CANNON/Reinhart . >> These differences mean that roll-off waste collection firms can profitably increase their charges for roll-off waste collection services without losing significant sales or revenues to firms engaged in the provision of other types of waste collection services. /Rotate 0 << Secure .gov websites use HTTPS /Contents [354 0 R 355 0 R 356 0 R] 42 0 obj /Rotate 0 /Contents [166 0 R 167 0 R 168 0 R] /Rotate 0 >> /CropBox [0 0 612 792] It is economically impractical for a roll-off waste collection firm to serve metropolitan areas from a distant base. The length of the presentation is 46:09. Should you request a temporary injunction or push quickly for final permanent injunction. In the Nashville, TN area, the acquisition would reduce from three to two the number of significant firms competing in the collection of small container commercial waste. judgment, and preliminary and permanent injunctive relief and damages. endobj /Author (JacqmeinV) << 62 0 obj /Resources 217 0 R endobj << /Type /Page /Resources 237 0 R /Annots [] /Rotate 0 >> 2322 0 obj<>stream ( /Parent 9 0 R /CropBox [0 0 612 792] Entry would also be made more difficult by Republic's use of long-term, automatically renewing contracts for roll-off service. /Annots [] ( /Annots [] /Annots [] /Contents [266 0 R 267 0 R 268 0 R] stream >> 56. /Rotate 0 << /Parent 13 0 R 64 0 obj Does the injunction provide broad or limited relief? 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. /Contents [334 0 R 335 0 R 336 0 R] 2. In contrast to a commercial collection route, a residential waste collection route is significantly more labor intensive. << <> 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. A party seeking an injunction under general Florida case law must demonstrate: 1) irreparable harm; 2) a clear legal right; 3) an inadequate . US District Court for the Southern District of Florida: Presiding Judge: Raag Singhal: Nature of Suit: Trademark: Cause of Action: 15 U.S.C. /Contents [110 0 R 111 0 R 112 0 R] /Contents [298 0 R 299 0 R 300 0 R] << Absent injunctive relief by this Court, Defendants are likely to continue to injure consumers, reap unjust enrichment, and harm the public interest. Significant new entry into the disposal of MSW in the Anderson, IN and New York City, NY areas would be difficult and time-consuming. /Contents [262 0 R 263 0 R 264 0 R] JFIF C /Type /Page >> "Columbus, OH area" means the City of Columbus and Franklin and Delaware counties, Ohio. 59. /Type /Page %PDF-1.5 /Resources 373 0 R /Resources 345 0 R >> endobj >> /Count 9 Anyone who fails to dispose of MSW in an approved facility can be subject to severe civil and criminal penalties. /Resources 125 0 R endobj 61. /Type /Page /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] "Gulf Coast, FL area" means Escambia, Santa Rosa, and Okaloosa counties, Florida. /Rotate 0 10. /MediaBox [0 0 612 792] 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. /CropBox [0 0 612 792] 65. /Type /Pages As such, following the process to the tee will help improve your chances for success. /MediaBox [0 0 612 792] /Type /Page "0A149;>>>%.DIC; C /Count 10 << 34 0 obj << Virtually all of the MSW generated in each of these areas is disposed of in transfer stations in each of their local areas. /Resources 165 0 R 4 0 obj /Parent 4 0 R COMPLAINT FOR INJUNCTIVE RELIEF AND SANCTIONS Plaintiff, Donald F. Walton, United States Trustee for . /CropBox [0 0 612 792] 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 /Page 24 0 obj In 1998, for example, these three transfer stations disposed of over 85 percent of the MSW generated in the Anderson, IN area. /Rotate 0 /MediaBox [0 0 612 792] 57 0 obj /Type /Page /Contents [94 0 R 95 0 R 96 0 R] /Parent 8 0 R Local small container commercial waste collection firms in the Albany, NY; Augusta, GA; Burlington and Camden Counties, NJ; Clarksville, TN; Columbus, OH; Gulf Coast, FL; Lakeland, FL; Louisville, KY/Sellersburg, IN; Macon, GA; Memphis, TN; Monmouth County, NJ; Nashville, TN and Norfolk, VA areas can profitably increase charges to local customers without losing significant sales to more distant competitors. /Rotate 0 /Length 10 /Filter /FlateDecode /Parent 13 0 R /CropBox [0 0 612 792] /Annots [] /Contents [194 0 R 195 0 R 196 0 R] endobj 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. /Parent 11 0 R 51 0 obj /Contents [366 0 R 367 0 R 368 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. >> 89 0 obj /MediaBox [0 0 612 792] << /Type /Page For a variety of reasons, other types of collection activities, such as roll-off containers (typically used for construction debris) and collection of liquid or hazardous waste, are also rarely combined with commercial waste collection activities. /Type /Page << /Type /Page Plaintiff seeks temporary, preliminary, and permanent injunctive relief pursuant to Rule 65 . 67. endobj endobj /Rotate 0 JURISDICTION AND VENUE 1. /Annots [] Complaint for Injunctive Relief Case (s): U.S. v. Allied Waste Industries, Inc. and Republic Services, Inc. /Parent 8 0 R /Annots [] /Contents [230 0 R 231 0 R 232 0 R] endobj /CropBox [0 0 612 792] Allied is located in and transacts business in the District of Columbia, and Republic submits to the personal jurisdiction of the District of Columbia in this proceeding. << << /Type /Page /Rotate 0 /Parent 14 0 R 2201-202, and . >> 15. /Type /Page 6 0 obj In the Macon, GA area, the acquisition would also combine the two largest firms that compete in roll-off waste collection service. /Rotate 0 76 13 /Type /Page 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. /Rotate 0 EOs6~W\F3[_y7~r+W3nU>9YRpM/u"%1yK Ivp, Microsoft Word - 2022-08-24 - Complaint - FINAL. : 01-42230-BKC-AJC . It is calculated by squaring the market share of each firm competing in the market and then summing the resulting numbers. /Resources 145 0 R /Resources 153 0 R ( endobj << /MediaBox [0 0 612 792] 3601, et seq. 31 0 obj <>stream 0000003645 00000 n stream 0000002235 00000 n Injunctive relief is considered an extraordinary remedy in both State and Federal court. /Parent 13 0 R /Contents [118 0 R 119 0 R 120 0 R] 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] After the acquisition, Republic would control over 60 percent of the roll-off hauling market, which has annual revenues of about $8 million. 2018 to May 6, 2021. /Type /Page >> >> 50. /Type /Page /MediaBox [0 0 612 792] >> Suing for an injunction in Florida is all about preserving the status quo. >> /CropBox [0 0 612 792] 62. << /Annots [] There could be a negative impact on the plaintiffs public image. >> Therefore, its important to not consider it a tool for righting a wrong. /Rotate 0 Venue properly lies in the Southern Distri ct of Florida pursuant to 28 U.S.C. /MediaBox [0 0 612 792] >> In such areas, many of the problems associated with the permitting and construction of a landfill could make it difficult to permit and construct a transfer station. /MediaBox [0 0 612 792] >> The front-end load containers used by small container commercial collection customers cannot be serviced by roll-off trucks. >> /Resources 265 0 R << >> /MediaBox [0 0 612 792] /Parent 11 0 R << /Parent 10 0 R /Type /Page /Parent 13 0 R /Rotate 0 /Type /Page << >> endobj 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. /Contents [226 0 R 227 0 R 228 0 R] 53(b), to secure preliminary and permanent injunctive relief, rescission of contracts, restitution, disgorgement, and other . Official websites use .gov Plaintiff, The Second Amendment Foundation, is a Washington Not-For-Profit 78 0 obj << /Contents [238 0 R 239 0 R 240 0 R] ( /CropBox [0 0 612 792] /MediaBox [0 0 612 792] << >> "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.