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1
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AMENDED COMPLAINT
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EXTRACTED KEY WORDS
CHENEY PRESIDENT ENERGY VICE PRESIDENT WASHINGTON POLICY COURT NEPDG DEFENDANT UNITED STATES NATIONAL ENERGY AGENCY EXECUTIVE OFFICE MEMBER MEETINGS DISTRICT COURT FACA ADVISORY COMMITTEE POSSESSION KOPPEL FOIA GOVERNMENT VICE PRES AMENDED COMPLAINT EXECUTIVE OFFICE BUILDING CONSTITUTION MANAGEMENT AGENCY DEVELOPMENT GROUP EISENHOWER EXECUTIVE OFFICE |
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
JUDICIAL WATCH, INC.
501 School Street, SW, Suite 725
Washington, DC 20024
Plaintiff,
AMENDED COMPLAINT
v.
Civil Action No. 01-1530 (EGS)
NATIONAL ENERGY POLICY
DEVELOPMENT GROUP
Office of the Vice President
Eisenhower Executive Office Building
Washington, DC 20501
and
THE HON. RICHARD B. CHENEY
Vice President of the United States
of America
Eisenhower Executive Office Building
Washington, DC 20501
and
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2
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TRIAL VOL9
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EXTRACTED KEY WORDS
DEFENDANTS ABORTION FLYER TESTIMONY POSTER RECALL NUREMBERG FILES DEPOSITION ACLA PRIOR MILLER JUDGE OKAY MEETING CONTRACT DAWN STOVER ANDREW BURNETT PRO-LIFE ACTIVISTS MICHAEL AMERICAN ABORTION INDUSTRY LIFE ACTIVISTS PRESS CONFERENCE ABORTION PROVIDER LOUIS EVENT CATHY RAMEY PLAINTIFFS NEWSPAPER JOSEPH FOREMAN |
1 IN THE UNITED STATES DISTRICT COURT
2 FOR THE DISTRICT OF OREGON
3 PLANNED PARENTHOOD OF THE )
COLUMBIA/WILLAMETTE, INC., et al. )
4 )
Plaintiffs, ) CV 95-1671 JO
5 )
vs. ) January 19, 1999
6 )
AMERICAN COALITION OF LIFE ) Portland, Oregon
7 ACTIVISTS, et al. )) Volume IX
8 Defendants. )
9
10 TRANSCRIPT OF TRIAL PROCEEDINGS
11 BEFORE THE HONORABLE ROBERT E. JONES
12 UNITED STATES DISTRICT COURT JUDGE, AND A JURY
13 APPEARANCES
14
15
FOR THE PLAINTIFF: CAROL BERNICK
16 Davis Wright Tremaine
1300 S.W. Fifth Ave., Suite 2300
17 Portland, Or 97201
503 778-5233
18
MARIA T. VULLO
19 MARTIN LONDON
ELIZABETH MARINGER
20 Paul, Weiss, Rifkind, etc.
1285 Avenue of the Americas
21 New York, NY 10019-6064
212 373-3346
22
ROGER K. EVANS
23 Planned Parenthood Federation of America
810 7th Ave.
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3
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AMICUSACLU
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EXTRACTED KEY WORDS
DEFENDANTS PLAINTIFFS UNITED STATES AMICUS CURIAE ACLU FOUNDATION OREGON JURY INTENT TRIAL COURT MICHAEL THREAT SIMON JURY INSTRUCTION SPEECH LAW FIRST AMENDMENT THREATENS PROTECTED SPEECH PERKINS COIE LLP ATTORNEYS FEDERAL RULES CIVIL LIBERTIES CONSTITUTIONALITY AMERICAN CIVIL LIBERTIES DISTRICT COURT NORTHWESTERN SCHOOL BODILY HARM COMMUNICATIONS EXPRESSLY THREATENING LANGUAGE |
No No. 99-35320 Nos. 99-35320, 99-35325, 99-35327, 99-35331, 99-35333, 99-35405 UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT ____________________________________ PLANNED PARENTHOOD OF THE COLUMBIA/WILLAMETTE, INC., et al., Plaintiffs-Appellees, v. AMERICAN COALITION OF LIFE ACTIVISTS, et al. , Defendants-Appellants. _________________________________________ Appeal from the United States District Court for the District of Oregon, DC NO. CV-95-01671-REJ The Hon. Robert E. Jones, United States District Judge BRIEF OF AMICUS CURIAE ACLU FOUNDATION OF OREGON, INC. (Supporting Affirmance) Michael H. Simon Chin See Ming Perkins Coie LLP Suite 1500 1211 S.W. Fifth Ave.SNIPPETS: |
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4
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NOTICE OF APPEAL
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EXTRACTED KEY WORDS
UNITED STATES APPEALS AMERICA PLAINTIFF UNITED STATES COURT CIRCUIT |
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF KANSAS
)
UNITED STATES OF AMERICA. ))
Plaintiff ))
v. ) Case No. 99-1180-JTM
)
AMR CORPORATION, AMERICAN )
AIRLINES, INC. and AMR EAGLE )
HOLDING CORPORATION, ))
Defendants. )
)
NOTICE OF APPEAL
Notice is hereby given that the United States of America, plaintiff in the above-named
case, hereby appeals to the United States Court of Appeals for the Tenth Circuit from the final
judgment entered in this action on the 27th day of April, 2001.
June 25, 2001
/s/
Craig Conrath
/s/
John P. Fonte
Attorneys
Antitrust Division
United States Department of Justice
601 D Street, N.W.
Washington, D.C. 20530
(202) 514-2435
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5
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ANIMALRIGHTSBRIEF
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EXTRACTED KEY WORDS
COURT RITUALS PETITIONERS HUMANE CITY LAW AMICI ORDINANCES PROTECTION SLAUGHTER CHURCH HIALEAH HUMANE TREATMENT DISTRICT COURT RELIGIOUS PRACTICE RESPONDENT JERSEY ANIMAL RIGHTS UNITED STATES ANIMAL RIGHTS AMICI CURIAE HUMANE SLAUGHTER ACT REGULATION FIRST AMENDMENT PUBLIC HEALTH RUTGERS LAW SCHOOL LUKUMI BABALU AYE SUPREME COURT FREE EXERCISE SECULAR PURPOSE |
Rutgers Rutgers Animal Rights Law Center Brief in Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah IN THE SUPREME COURT OF THE UNITED STATES OCTOBER TERM, 1991 CHURCH OF THE LUKUMI BABALU AYE, INC., and ERNESTO PICHARDO, Petitioners, - v.- CITY OF HIALEAH Respondent ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE ELEVENTH CIRCUIT BRIEF OF PEOPLE FOR THE ETHICAL TREATMENT OF ANIMALS, NEW JERSEY ANIMAL RIGHTS ALLIANCE, AND THE FOUNDATION FOR ANIMAL RIGHTS ADVOCACY AS AMICI CURIAE IN SUPPORT OF RESPONDENT Gary L. Francione Professor of LawSNIPPETS: |
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6
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PROPOSED FINAL CONSENT JUDGMENT
|
EXTRACTED KEY WORDS
MORTON PLANT MEASE PARTNERSHIP CARE UNITED STATES PLAINTIFFS HOSPITALS ENTRY COURT PROVIDER PATIENT CARE MANAGEMENT DISTRICT HEALTH ADMINISTRATIVE SERVICES SEPARATE ANTITRUST COMPETITION FLORIDA ELIGIBLE PARTNERSHIP MARKETING CONTRACTING PARTIES ATTORNEY TRUSTEES PROVISIONS PURSUANT OFFICERS PHYSICIAN |
UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION
________________________________________)
UNITED STATES OF AMERICA and )
STATE OF FLORIDA, ))
Plaintiffs, ) Civ. No. 94-748-CIV-T-23E
)
v. ) Judge Steven D. Merryday
)
MORTON PLANT HEALTH SYSTEM, INC. and ) 6/17/94
TRUSTEES OF MEASE HOSPITAL, INC., )
)
Defendants. )
________________________________________)
STIPULATION
It is stipulated by and between the undersigned parties, by
their respective attorneys, that:
1. The Court has jurisdiction over the subject matter of this
action and over each of the parties hereto, and venue of this action
is proper in the Middle District of Florida;
2. The parties consent that a Final Consent Judgment in the
form hereto attached may be filed and entered by the Court, upon the
motion of any party or upon the Court's own motion, at any time
after compliance with the requirements of the Antitrust Procedures
and Penalties Act (15 U.S.C. § 16), and without further notice to
any party or other proceedings, provided that plaintiffs have not
withdrawn their consent, which they may do at any time before the
entry of the proposed Final Judgment by serving notice thereof on
defendants and by filing that notice with the Court; and
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7
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RESPONSE TO PUBLIC COMMENTS-2
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EXTRACTED KEY WORDS
COMPETITION BALTIMORE AREA DEFENDANTS MARYLAND PROPOSED JUDGMENT INJUNCTIVE RELIEF UNITED STATES WASTE MANAGEMENT COURT COMPLAINT DIVEST OHIO LETTERS FEDERAL DISTRICT COURT COMMERCIAL WASTE REQUIRING DISPOSAL CAPACITY TRANSFER STATIONS CONTAINER COMMERCIAL WASTE FACILITIES MERGER ANTITRUST STROTT ACQUISITION GOVERNMENTS COMMERCIAL WASTE HAULING EASTERN SHORE COMPETITIVE PROBLEMS WASTE DISPOSAL MARKET |
City Center Building
1401 H Street, NW
Washington, DC 20530
September 13, 1999
Mr. Gregory G. Strott
President
Calvert Trash Systems, Inc.
P.O. Box 9
Owings, Maryland 20736-0009
Re: Comment on Proposed Final Judgment in United States, State of Ohio, et al. v. USA
Waste Services, Inc., Waste Management, Inc., et al., Civil No. 98-1616 (N.D. Ohio,
filed July 16, 1998)
Dear Mr. Strott:
This letter responds to your two letters commenting on the proposed Final Judgment,
currently pending in federal district court in Cleveland, Ohio. The Complaint in this case charged,
among other things, that USA Waste's acquisition of Waste Management would substantially lessen
competition in the disposal of commercial waste from the Baltimore, Maryland area. The proposed
Judgment would settle the case by, inter alia, requiring that the defendants divest disposal
three Baltimore area transfer stations owned by USA Waste and Waste Management. In a
transaction approved by the United States in early January 1999, under the terms of the decree, the
defendants divested that disposal capacity to Browning-Ferris Industries, Inc. ("BFI"), which
previously did not own or operate any waste transfer stations in the greater Baltimore area.
In your letters, you expressed concern that the proposed Judgment did not eliminate the
effects of USA Waste's acquisition of Waste Management in several markets that were not alleged in
the governments' Complaint. Specifically, you charged that the defendants should be: (a) enjoined
from entering into any small container commercial waste hauling agreements that exceed a year with
Baltimore area customers; (b) required to divest their small container commercial waste hauling
operations in southern Maryland; (c) enjoined from raising their waste disposal prices, presumably
any of their Maryland facilities; and finally, (d) required to provide their competitors access to a
transfer station on the Eastern Shore of Maryland on the same terms on conditions as the defendants
enjoy at that facility.
The United States strongly believes that the ordered divestiture of Baltimore area disposal
capacity and other injunctive relief contained in the proposed Judgment [see §§ II(C)(2)(b)
IV(A),VII(A)] will alleviate the competitive concerns alleged in the Complaint by introducing a
major new competitor into the waste disposal market, capable of providing a competitive alternative
to the defendants' own Baltimore area waste disposal facilities.
As to your statement that additional injunctive relief is necessary to eliminate
problems the merger would create in Baltimore, and the southern and Eastern Shore areas of
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8
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TRIAL VOL5
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EXTRACTED KEY WORDS
COURT BURNETT LIFE QUOTE COUNSEL LAWYERS PLAINTIFFS OKAY SIR ABORTION SANCTIONS LIFE ADVOCATE NUREMBERG FILES JURY DISTRICT PROFESSIONALS EXHIBIT MATERIALS MAGAZINE PETITION PAUL HILL ACLA AMERICAN COALITION SHANNON ABORTIONISTS BUMPER STICKER MICHAEL LIFE ACTIVISTS CAPITAL PUNISHMENT |
1 IN THE UNITED STATES DISTRICT COURT
2 FOR THE DISTRICT OF OREGON
3 PLANNED PARENTHOOD OF THE )
COLUMBIA/WILLAMETTE, INC., et al. )
4 )
Plaintiffs, ) CV 95-1671 JO
5 )
vs. ) January 13, 1999
6 )
AMERICAN COALITION OF LIFE ) Portland, Oregon
7 ACTIVISTS, et al. ))
8 Defendants. ) Volume V
9
10 TRANSCRIPT OF TRIAL PROCEEDINGS
11 BEFORE THE HONORABLE ROBERT E. JONES
12 UNITED STATES DISTRICT COURT JUDGE, AND A JURY
13 APPEARANCES
14
15
FOR THE PLAINTIFF: CAROL BERNICK
16 Davis Wright Tremaine
1300 S.W. Fifth Ave., Suite 2300
17 Portland, Or 97201
503 778-5233
18
MARIA T. VULLO
19 MARTIN LONDON
ELIZABETH MARINGER
20 Paul, Weiss, Rifkind, etc.
1285 Avenue of the Americas
21 New York, NY 10019-6064
212 373-3346
22
ROGER K. EVANS
23 Planned Parenthood Federation of America
810 7th Ave.
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9
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MOTIONS AND STIPULATION FOR ENTRY OF ENFORCEMENT ORDER
|
EXTRACTED KEY WORDS
MORTON PLANT VIOLATIONS PARTNERSHIP HOSPITALS MEASE CONTRACTING MANAGED CARE STIPULATION ENFORCEMENT ORDER PARAGRAPH FLORIDA MARKETING PRICING HEALTH ENTRY ADMINISTRATORS COMPETITION DIRECTIVES NEGOTIATING CERTIFICATIONS UNITED STATES RELATING SELL MANAGED CARE PLANS OCCASIONS COMPLIANCE OFFICERS EXECUTIVES SEPARATE |
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION
)
UNITED STATES OF AMERICA and )
STATE OF FLORIDA, )
)
Plaintiffs, ))
v. ) Civil Action
) Judge Steven
MORTON PLANT HEALTH SYSTEM, INC. and )
TRUSTEES OF MEASE HOSPITAL, INC., ))
Defendants. ))
)
MOTION AND
STIPULATION FOR ENTRY OF AN ENFORCEMENT ORDER
The United States of America, the State of Florida, Morton Plant Hospital Association,
Inc., formerly known as Morton Plant Health System, Inc. ("Morton Plant"), the Trustees of
Mease Hospital, Inc. ("Mease"), and Morton Plant Mease Healthcare, Inc. ("MPMHC"), hereby
stipulate and agree to the entry of the attached Enforcement Order pursuant to ¶ X of the Final
Consent Judgment ("FCJ") entered in this action on September 29, 1994, and extended, pursuant
to ¶ XI of the FCJ, on September 29, 1999.
The parties further stipulate and agree as follows:
1. Morton Plant and Mease hereby admit that they violated provisions of the FCJ
through the following business activities.
a. Violations of ¶ V, relating to the bona fide Partnership
1) Paragraph V(B) of the FCJ permits Morton Plant and Mease to
create a bona fide partnership (the "Partnership") to produce
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