/Rotate 0 /Title (Microsoft Word - 2022-08-24 - Complaint - FINAL) /Contents [226 0 R 227 0 R 228 0 R] << 4. have exclusive jurisdiction: (a) In all actions at law cognizable by the county . endobj 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. /Type /Page Contains legal complaint for injunctive releif and civil penalties against BCX facility Site, Jacksonville, Duval County, Florida, June 7, 2004. /Parent 14 0 R /MediaBox [0 0 612 792] /Resources 297 0 R /MediaBox [0 0 612 792] %&'()*456789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz w !1AQaq"2B #3Rbr /CropBox [0 0 612 792] /Contents [170 0 R 171 0 R 172 0 R] endobj >> The United States of America, acting under the direction of the Attorney General of the United States, brings this civil antitrust action to enjoin the acquisition of certain waste hauling and disposal assets by Defendants Allied Waste Industries, Inc. ("Allied") and Republic Services, Inc. ("Republic") and to obtain equitable relief and other relief as appropriate. 41 0 obj 5 0 obj /Resources 153 0 R The global coronavirus pandemic threatens to disrupt the Presidential : 01-42230-BKC-AJC . << >> << 27 0 obj Filing 1 COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. 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. endobj 87 0 obj ( /Contents [406 0 R 407 0 R 408 0 R] endobj xYYoH~7"b` recB$hHjRbK6DQ]]WUMb8`}^^l,q8x1O,7~`[)gD,uq+sU+PP)>f90VY-^AEKS2t}g4 X!xH rTmvF4(,W`{kF$tC /Annots [] 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 . ( /Parent 11 0 R endobj >> /Type /Page /Rotate 0 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. ( /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] /CropBox [0 0 612 792] 77 0 obj << /Contents [194 0 R 195 0 R 196 0 R] /CropBox [0 0 612 792] Local roll-off waste collection firms in the Macon, GA area can profitably increase charges to local customers without losing significant sales to more distant competitors. /Parent 9 0 R endobj endobj /Rotate 0 /Parent 13 0 R /Resources 189 0 R Charles B. Jimerson >> Significant new entry into the disposal of MSW in the Anderson, IN and New York City, NY areas would be difficult and time-consuming. endobj 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. >> /Resources 317 0 R endobj >> /Annots [] /Filter /FlateDecode >> /Annots [] 79 0 obj /Parent 14 0 R x+ | /Annots [] 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. << >> Permit restrictions often impose severe limitations on the type and amount of waste that can be disposed of at landfills. endobj /Resources 137 0 R endobj endobj 38 0 obj /Resources 129 0 R 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. APPROPRIATENESS OF INJUNCTIVE RELIEF 26 . /Contents [358 0 R 359 0 R 360 0 R] /Rotate 0 /Annots [] Therefore, its important to not consider it a tool for righting a wrong. 59. . PLAINTIFF'S COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF . /Resources 117 0 R /PageLabels 3 0 R /Rotate 0 (Compl . $4%&'()*56789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz r! endobj not endstream endobj startxref /Parent 10 0 R /Type /Page /Parent 8 0 R /Parent 4 0 R 70 0 obj #%$""!&+7/&)4)! /Count 9 EOs6~W\F3[_y7~r+W3nU>9YRpM/u"%1yK Ivp, Microsoft Word - 2022-08-24 - Complaint - FINAL. /Author (JacqmeinV) The proposed transactions, identified below, would lessen competition substantially in waste collection and/or disposal services: (1) Allied's acquisition of hauling assets in Albany, New York; (2) Allied's acquisition of hauling assets in Augusta, Georgia; (3) Allied's acquisition of hauling assets in Memphis, Nashville and Clarksville, Tennessee; (4) Allied's acquisition of disposal assets in New York, New York; (5) Allied's acquisition of hauling assets in Norfolk, Virginia; (6) Allied's acquisition of hauling assets in Okaloosa, Escambia and Santa Rosa counties, Florida ("Gulf Coast, Florida"); (7) Republic's acquisition of disposal assets in Anderson, Indiana; (8) Republic's acquisition of hauling assets in Columbus, Ohio; (9) Republic's acquisition of hauling assets in Lakeland, Florida; (10) Republic's acquisition of hauling assets in Louisville, Kentucky and Sellersburg, Indiana; (11) Republic's acquisition of hauling and disposal assets in Macon, Georgia; and (12) Republic's acquisition of hauling assets in Monmouth, Burlington and Camden counties, New Jersey. 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. 31 0 obj <>stream << << trailer endobj /CropBox [0 0 612 792] /Parent 11 0 R >> /Parent 13 0 R 0000006259 00000 n 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] /CropBox [0 0 612 792] 69 0 obj 0000001187 00000 n /Type /Page 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] ]\q( $QSRP@=8`) $CC16 PI_ XL /MediaBox [0 0 612 792] JacqmeinV 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. 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. << Defendant is defined as a "Public Accommodation" within meaning of Title III Plaintiff is a Florida resident, lives in Miami- Dade County, is sui juris, and qualifies of a protected class under the ADA, 42 U.S.C. << /MediaBox [0 0 612 792] /Annots [] ( /Resources 205 0 R /Resources 173 0 R 49. /MediaBox [0 0 612 792] << 2 0 obj << >> ( /MediaBox [0 0 612 792] 13 0 obj 22. /Type /Pages /Parent 7 0 R /MediaBox [0 0 612 792] /Rotate 0 /MediaBox [0 0 612 792] /Rotate 0 Plaintiff, PRISON LEGAL NEWS ("PLN"), a project of the Human Rights Defense . /CropBox [0 0 612 792] /Rotate 0 state of Florida in 1925 and yet again in 1943, under the legislative powers granted to the Florida legislature under the 1885 Constitution of the State of Florida. /CropBox [0 0 612 792] /Parent 4 0 R 0000000016 00000 n 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. See also Chapter 224.08, Special Acts of Florida, 1943. /Type /Page 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. /Resources 397 0 R ( >> <<21a9e19eaa9d774d8bfb9315a3d3f5db>]>> 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 [346 0 R 347 0 R 348 0 R] /Parent 12 0 R 34 0 obj 25. /Resources 369 0 R /Type /Page ( /Type /Page /Resources 373 0 R >> 68. << 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. 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 . endobj 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. 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. /Rotate 0 /Rotate 0 The cost of transporting waste to a disposal site is often a substantial component of the cost of disposal. /Resources 193 0 R Although, where available, MSW can be transported to distant landfills through transfer stations using large transfer trailer trucks, the use of transfer stations adds fixed transportation and processing costs. /Parent 11 0 R In order to obtain comparable operating efficiency, a new firm must achieve route density comparable to existing firms. /Resources 289 0 R K.A%aut\@Uaa[pVWnOe did not involve a claim for declaratory relief. /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] ( 5.) /MediaBox [0 0 612 792] /Annots [] /Parent 10 0 R /Contents [254 0 R 255 0 R 256 0 R] Private waste haulers typically contract directly with customers for the collection of waste generated by commercial accounts. The front-end load containers used by small container commercial collection customers cannot be serviced by roll-off trucks. /Contents [290 0 R 291 0 R 292 0 R] /CropBox [0 0 612 792] .+p>hPhb4yiK=c`/XOv@|fe`iY /Contents [354 0 R 355 0 R 356 0 R] /CropBox [0 0 612 792] /Rotate 0 /Annots [] It is calculated by squaring the market share of each firm competing in the market and then summing the resulting numbers. /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. 73 0 obj 10941 and Laws of Florida, Ch. 90 0 obj ( 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. JURISDICTION AND VENUE 1. >> >> 1331 and 1337. MSW landfills can only accept waste up to their permitted daily capacity and have a finite life span. provide relief to all the individuals affected by APD's action. /Resources 333 0 R hbbd`b`rfb`gb` # 17 0 obj /Resources 345 0 R Absent injunctive relief by this Court, Defendants are likely to continue to injure consumers, reap unjust enrichment, and harm the public interest. This is an action for injunctive relief. stream 14 0 obj /Parent 7 0 R The Corps' environmental analysis for this project is based on the same assumptions and ( /CropBox [0 0 612 792] /Annots [] /Annots [] /Contents [330 0 R 331 0 R 332 0 R] /Contents [242 0 R 243 0 R 244 0 R] /Annots [] /Type /Page /Contents [274 0 R 275 0 R 276 0 R] << /Contents [366 0 R 367 0 R 368 0 R] /Parent 10 0 R << Page 3 of 15 7. 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. /Resources 253 0 R endobj /Parent 8 0 R 36 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. /MediaBox [0 0 612 792] 43 0 obj 48 0 obj The proposed acquisition would reduce from three to two the number of significant competitors for the disposal of MSW in the Anderson, IN area. 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. In the Anderson, IN and New York City, NY areas, entry by any new MSW disposal facility would be an extremely costly and time-consuming process, and unlikely to prevent market incumbents from significantly raising prices for the disposal of MSW following the acquisition. >> /Contents [94 0 R 95 0 R 96 0 R] >> /Contents [382 0 R 383 0 R 384 0 R] endobj 42. /Kids [45 0 R 46 0 R 47 0 R 48 0 R 49 0 R 50 0 R 51 0 R 52 0 R 53 0 R 54 0 R] 0000000016 00000 n /Contents [222 0 R 223 0 R 224 0 R] >> 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. /Contents [142 0 R 143 0 R 144 0 R] /MediaBox [0 0 612 792] /Contents [398 0 R 399 0 R 400 0 R] /MediaBox [0 0 612 792] /Parent 8 0 R 84 0 obj endobj /MediaBox [0 0 612 792] >> endobj /Parent 11 0 R A .gov website belongs to an official government organization in the United States. endobj 7 0 obj 37. /Parent 9 0 R >> /Annots [] >> 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. 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. << WEST PALM BEACH DIVISION . << /Contents [362 0 R 363 0 R 364 0 R] endobj /Parent 8 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] % >> endobj /Parent 12 0 R /Parent 10 0 R /Annots [] H*23430P AsKN$r{(s Roll-off waste haulers, therefore, generally establish garages and related facilities within each major local area served. Allied is the nation's second largest waste hauling and disposal company. /Type /Page 24 0 obj >> hUN@h/%FT""Qy@Kbxw81FgfvEN.tF2AiP9?{"1zQ. 12. /Parent 8 0 R /Rotate 0 Because of the differences in the collection process, residential customers and commercial customers usually are organized into separate routes. /MediaBox [0 0 612 792] 25 0 obj stores and restaurants). /Producer <4163726F6261742044697374696C6C65722032322E30202857696E646F7773293B206D6F646966696564207573696E67206954657874AE20372E312E3620A9323030302D323031392069546578742047726F7570204E56202841646D696E697374726174697665204F6666696365206F662074686520556E697465642053746174657320436F757274733B206C6963656E7365642076657273696F6E29> /MediaBox [0 0 612 792] clearly appears from specific facts shown by affidavit or by verified complaint that immediate or /Contents [218 0 R 219 0 R 220 0 R] /Count 10 /Parent 9 0 R /Resources 237 0 R 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. /Type /Pages /CropBox [0 0 612 792] ( /Type /Page /Rotate 0 16 0 obj 40. << /Type /Page /CropBox [0 0 612 792] 33. 6108, to obtain temporary, preliminary, and permanent injunctive relief, rescission or reformation of contracts, restitution, the refund of monies paid, disgorgement of ill-gotten . SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION In re: JOSE SANCHEZ Case No. See Merger Guidelines 1.51. 0000001563 00000 n >> /Type /Pages Jurisdiction is conferred on this Court by Chapters 26, 34, 86.011. 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. << endobj 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. /Annots [] 15. U.S. v. Allied Waste Industries, Inc. and Republic Services, Inc. 53(b), empowers this Court to grant injunctive and such other relief as the Court may deem appropriate to halt /Parent 10 0 R /Contents [390 0 R 391 0 R 392 0 R] /CropBox [0 0 612 792] "Transfer station" means an intermediate disposal site, often used in more densely populated areas, for the processing and temporary storage of solid waste before transfer, in bulk, to more distant facilities for final disposal. /Rotate 0 /Type /Page /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] endobj /MediaBox [0 0 612 792] << endobj 83 0 obj /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] /Annots [] << 4. /MediaBox [0 0 612 792] 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. /Resources 221 0 R /Resources 145 0 R &%e2#4DqB#K.tt.GYeMbN!uiW-C`oIynF,fD5c&a8|A!y%?ci6Ywo`aPT=Yz0Id << SOUTHERN DISTRICT OF FLORIDA . endobj /Parent 8 0 R /Annots [] >> << /Resources 269 0 R /Resources 185 0 R /CropBox [0 0 612 792] /MediaBox [0 0 612 792] 2. /Parent 9 0 R Republic is a Delaware corporation with its principal office in Ft. Lauderdale, Florida. 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. << /Rotate 0 /MediaBox [0 0 612 792] >> 17. /CropBox [0 0 612 792] ( >> /Type /Page 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. 78 0 obj /Type /Page /Contents [186 0 R 187 0 R 188 0 R] /Type /Catalog That plaintiff recover the costs of this action. /Contents [378 0 R 379 0 R 380 0 R] 2201-202, and . >> 4. 6. ( 36. 11. endobj /Annots [] /Type /Page /CropBox [0 0 612 792] << endobj << 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. It is economically impractical for a roll-off waste collection firm to serve metropolitan areas from a distant base. /Contents [230 0 R 231 0 R 232 0 R] /Contents [146 0 R 147 0 R 148 0 R] "Columbus, OH area" means the City of Columbus and Franklin and Delaware counties, Ohio. endobj 2320 14 /Contents [350 0 R 351 0 R 352 0 R] /Resources 329 0 R /Resources 257 0 R In addition, be sure you have competent, knowledgeable and experienced counsel in your corner. 76 0 obj 51. /CropBox [0 0 612 792] << endobj /Annots [] /Parent 10 0 R endobj /MediaBox [0 0 612 792] 10. 46. endobj /Annots [] endobj Microsoft Word - 2022-08-24 - Complaint - FINAL 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." ( << There are no good substitutes for MSW disposal. /Parent 12 0 R 22408. /CropBox [0 0 612 792] Does the courts have ability to enforce what you are requesting? 47. /CropBox [0 0 612 792] /Type /Page ( /CropBox [0 0 612 792] /Resources 261 0 R /Annots [] /MediaBox [0 0 612 792] /Resources 217 0 R /Annots [] << >> endobj << >> 0000003946 00000 n /CropBox [0 0 612 792] /Metadata 2 0 R IV. ( 37 0 obj 0000001373 00000 n << On July 28 and October 7, 1999, in twelve (12) separate purchase agreements, defendants agreed to exchange assets of various subsidiary companies ('the acquisitions"). 35. 3 0 obj Managing Partner /MediaBox [0 0 612 792] . /Type /Page << "New York City, NY area" means the Borough of Brooklyn, New York. "0A149;>>>%.DIC; C The United States is entitled to injunctive relief under 26 U.S.C. endobj /Parent 9 0 R >> Florida has reported 149 confirmed cases of COVID-19 and four deaths to date, with every expectation that these numbers will rise. << /MediaBox [0 0 612 792] 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. /Contents [246 0 R 247 0 R 248 0 R] 3 0 obj On September 8, 2021, the Court, by consent, entered a preliminary injunction against Garcia. /Contents [122 0 R 123 0 R 124 0 R] /Parent 7 0 R /Type /Page In these markets, Allied and Republic each account for a substantial share of MSW disposal capacity. JURISDICTION AND VENUE 2. /Rotate 0 /Rotate 0 (ECF No. Garcia controll ed the MJ Companies prior to their going into receivership. <> >> 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. The transactions likely will have the following effects, among others: 1. Allied and Republic are two of only a few providers of waste collection or disposal services in each of the identified areas. /Parent 13 0 R hbbd``b`@q=`v0012,I00"0 endstream endobj startxref 0 %%EOF 33 0 obj <>stream endobj /Resources 285 0 R /CropBox [0 0 612 792] 1391(c). /Rotate 0 /Resources 245 0 R /MediaBox [0 0 612 792] 66. Does the injunction provide broad or limited relief? /Resources 389 0 R 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. 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. /Resources 377 0 R The extension ofvote-by-mail options and other accommodations at polling places is necessary. 61 0 obj /Contents [310 0 R 311 0 R 312 0 R] 50 0 obj 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. << THIS COURT'S POWER TO GRANT RELIEF 84. /Contents [370 0 R 371 0 R 372 0 R] /Rotate 0 /Parent 8 0 R endobj >> /S /D 75 0 obj 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. DECLARATORY AND INJUNCTIVE RELIEF* * Pursuant to Rule 15(a)(2), Florida files the Second Amended Complaint with the written consent of Defendants. /Parent 14 0 R >> 89 0 obj /Resources 405 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. /Parent 12 0 R >> /MediaBox [0 0 612 792] /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] 46 0 obj Rule 1.610 of the Florida Rules of Civil Procedure governs requests for temporary injunctions. 44 0 obj 65 0 obj << "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. After the acquisition, Republic would control over 60 percent of the roll-off hauling market, which has annual revenues of about $8 million. /Type /Page /Resources 393 0 R Download the PDF of the Complaint IN THIS PUBLICATION Summary Issues COVID-19 /Contents [182 0 R 183 0 R 184 0 R] 18. /Contents [138 0 R 139 0 R 140 0 R] 25, to prevent and restrain the violation by defendants of Section 7 of the Clayton Act, 15 U.S.C. /Rotate 0 h|VrH}Weo2)RXBr|:=%ts?mlteQG :C:+rl86#m0GcfFmMb`4&;|Xy|^Q(&Y Jf#mb!nDlpfIi QB*Mg< /Annots [] Allied and Republic directly compete in roll-off waste collection service in a number of markets nationwide, including the Macon, GA area. 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. /CropBox [0 0 612 792] /Resources 293 0 R /Type /Page /CropBox [0 0 612 792] /Annots [] 0000001317 00000 n /Parent 11 0 R /Annots [] /Parent 7 0 R hb```"FN%n010pKsg``Z ^^@Y"bL38/4F `} endstream endobj 24 0 obj <> endobj 25 0 obj <>/ProcSet[/PDF/Text]>>/Rotate 0/Type/Page>> endobj 26 0 obj <>stream /Rotate 0 >> 47 0 obj /CreationDate (D:20220824140929-04'00') 42 0 obj /MediaBox [0 0 612 792] 0000000556 00000 n /Type /Page /Resources 121 0 R Security Personnel as Independent Contractors Part I: What Makes an Individual an Independent Contractor Instead of an Employee? /Resources 273 0 R endobj 19 0 obj 62. Defendants Allied and Republic collect municipal solid waste from residential, commercial, and industrial customers, and they own and operate transfer stations, landfills, and incinerators, which process and dispose of municipal solid waste.
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