complaint for injunctive relief florida

>> /Type /Page << Venue is therefore proper in this district under Section 12 of the Clayton Act, 15 U.S.C. The Macon, GA area is a section of the country, or relevant geographic market, for purposes of analyzing the effects of the acquisitions under Section 7 of the ClaytonAct. /Type /Page 4. This action is filed by the United States of America under Section 15 of the Clayton Act, 15 U.S.C. /Contents [326 0 R 327 0 R 328 0 R] >> /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] "Burlington and Camden Counties, NJ area" means Burlington and Camden counties, New Jersey. endobj /Type /Page 73 0 obj endobj << Because of the differences in the collection process, residential customers and commercial customers usually are organized into separate routes. /Annots [] hbbd``b`@q=`v0012,I00"0 endstream endobj startxref 0 %%EOF 33 0 obj <>stream 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. /CropBox [0 0 612 792] ( /Annots [] /Annots [] . /Resources 149 0 R /Contents [266 0 R 267 0 R 268 0 R] 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. /Annots [] ;,hn \ic6rZFi+|:GsL$KGqzed8;M+"N7i~4Dr?_1hHa:`R[B%Qm*?u9Lh=?y%x8;e$AD+xx /Annots [] (ECF No. /Annots [] 0000003645 00000 n /CropBox [0 0 612 792] endobj /Resources 309 0 R /CropBox [0 0 612 792] /MediaBox [0 0 612 792] It is calculated by squaring the market share of each firm competing in the market and then summing the resulting numbers. 52 0 obj /Type /Page 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. >> endobj /MediaBox [0 0 612 792] COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF Introduction 1. >> endobj << endobj /Contents [386 0 R 387 0 R 388 0 R] 2. 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. << << The next step is careful preparation before the temporary injunction hearing. This Court has the authority to grant the requested declaratory and injunctive relief pursuant to 28 U.S.C. /MediaBox [0 0 612 792] 1391, . /Filter /FlateDecode << /Type /Page /Resources 285 0 R << /Contents [314 0 R 315 0 R 316 0 R] /Rotate 0 The extension ofvote-by-mail options and other accommodations at polling places is necessary. 1 1 On February 7, 2023 and February 16, 2023, Plaintiff filed motions for preliminary 2 injunctive relief. 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). In these markets, Allied and Republic each account for a substantial share of MSW disposal capacity. "Augusta, GA area" means the City of Augusta, Richmond and Columbia counties, Georgia, and Aiken County, South Carolina. /MediaBox [0 0 612 792] endobj 2201 a nd 2202. >> hUN@h/%FT""Qy@Kbxw81FgfvEN.tF2AiP9?{"1zQ. >> /Parent 9 0 R /Resources 229 0 R /Parent 9 0 R /CropBox [0 0 612 792] 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. 88 0 obj 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. 0000001563 00000 n 4 0 obj /Resources 369 0 R endobj /Resources 269 0 R /Parent 13 0 R ( In the Macon, GA area, the acquisition would also combine the two largest firms that compete in roll-off waste collection service. 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. >> ( /Resources 105 0 R /Type /Page >> Federal, state and local safety, environmental, zoning, and permit laws and regulations dictate critical aspects of storage, handling, transportation, processing and disposal of MSW. /Annots [] >> /Parent 11 0 R This is a civil action brought by the United States of America to enjoin defendant . 29 0 obj /Parent 7 0 R /Annots [] 69 0 obj /Type /Page /Resources 125 0 R endobj In each of these markets, Allied and Republic each account for a substantial share of total revenues from commercial waste collection services. /Annots [] "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. 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). /Annots [] /Type /Page endobj >> /Contents [106 0 R 107 0 R 108 0 R] /S /D /CropBox [0 0 612 792] MSW is generally transported by collection trucks to landfills and transfer stations, and the availability of disposal sites close to a hauler's routes is a major element that determines a hauler's competitiveness and profitability. endobj What happens if the temporary injunction is not granted? 51. /Contents [254 0 R 255 0 R 256 0 R] /CropBox [0 0 612 792] 87 0 obj Small Container Commercial Waste Collection Service. >> /Rotate 0 /Rotate 0 "Memphis, TN area" means Shelby County, Tennessee; Desoto County, Mississippi, and Crittenden County, Arkansas. did not involve a claim for declaratory relief. /Resources 101 0 R ("MFS"), is a Florida corporation that has a principal place of . /Contents [222 0 R 223 0 R 224 0 R] If the major roll-off collection competitor in a market also controls the primary disposal site(s) therein, other roll-off competitors are at a large disadvantage and entry is difficult. 54 0 obj JURISDICTION AND VENUE 1. 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. >> 0000006750 00000 n Often businesses do not consider the implications for taking this action. In addition to differences in container size, other factors distinguish roll-off waste collection from small container commercial and other types of waste collection. 76 0 obj <> endobj >> The HHI increases both as the number of firms in the market decreases and as the disparity in size between those firms increases. hbbd`b`rfb`gb` # /Rotate 0 31 0 obj /Parent 4 0 R << /CropBox [0 0 612 792] >> ASSOCIATION OF FLORIDA, MIGRANT CLINICIANS NETWORK, PINEROS Y . On September 8, 2021, the Court, by consent, entered a preliminary injunction against Garcia. 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. /Rotate 0 0000001373 00000 n /Parent 12 0 R This form is a Complaint for Injunctive Relief and Damages. /Type /Page /CropBox [0 0 612 792] /Parent 4 0 R /Rotate 0 /Parent 13 0 R /Annots [] /Contents [110 0 R 111 0 R 112 0 R] /Resources 265 0 R /Annots [] endobj >> /Annots [] 44 0 obj ( 0000000016 00000 n /Annots [] endobj /Count 10 ( Does the injunction provide broad or limited relief? /CropBox [0 0 612 792] /CropBox [0 0 612 792] 5.) /Annots [] Roll-off waste haulers, therefore, generally establish garages and related facilities within each major local area served. 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. endobj /Parent 14 0 R The global coronavirus pandemic threatens to disrupt the Presidential Access to competitive disposal sites and reasonable disposal costs are important to providers of roll-off collection services. Z( relief pursuant to Chapter 86, Florida Statutes. >> /CropBox [0 0 612 792] /MediaBox [0 0 612 792] ( << << /Rotate 0 /Type /Page 23 0 obj 33. /Resources 325 0 R endobj 64. /Resources 305 0 R "Monmouth County, NJ area"means the City of Marlboro and Monmouth County, New Jersey. /Parent 10 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. /Type /Page In the Norfolk, VA area, the acquisition would reduce from three to two the number of significant firms competing in the collection of small container commercial waste. /Contents [154 0 R 155 0 R 156 0 R] stream endobj /MediaBox [0 0 612 792] 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. /MediaBox [0 0 612 792] stream h|VrH}Weo2)RXBr|:=%ts?mlteQG :C:+rl86#m0GcfFmMb`4&;|Xy|^Q(&Y Jf#mb!nDlpfIi QB*Mg< How long will the injunction be effective? /Resources 293 0 R In addition, be sure you have competent, knowledgeable and experienced counsel in your corner. ( << /Producer <4163726F6261742044697374696C6C65722032322E30202857696E646F7773293B206D6F646966696564207573696E67206954657874AE20372E312E3620A9323030302D323031392069546578742047726F7570204E56202841646D696E697374726174697665204F6666696365206F662074686520556E697465642053746174657320436F757274733B206C6963656E7365642076657273696F6E29> DECLARATORY AND INJUNCTIVE RELIEF* * Pursuant to Rule 15(a)(2), Florida files the Second Amended Complaint with the written consent of Defendants. 66. 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. 24 0 obj /Rotate 0 14 0 obj 0000000592 00000 n << /Creator (PScript5.dll Version 5.2.2) 59 0 obj /Type /Page 62. /Parent 9 0 R 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. REPUBLIC SERVICES, INC., 110 S.E. After the acquisition, Allied would control roughly 30 percent--and two firms about 66 percent--of the New York City, NY area MSW disposal market, which has annual revenues of about $40 million. /Annots [] /Annots [] << Official websites use .gov /Annots [] 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. << After the acquisition, Allied would control over 40 percent--and two firms would control over 80 percent--of the small container commercial waste hauling market, which has annual revenues of about $8 million. << <>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> /Annots [] In the Albany, NY area, the proposed acquisition would reduce from four to three the number of significant competitors in the collection of small container commercial waste. 0000003135 00000 n /Parent 11 0 R "Albany, NY area" means the City of Albany and Albany, Schenectady, Saratoga, and Rensselaer counties, New York. /Annots [] /MediaBox [0 0 612 792] /CropBox [0 0 612 792] /Annots [] The operator continues along the route, collecting MSW from each of the commercial accounts until the vehicle is full. ( >> endstream endobj 26 0 obj <> endobj 27 0 obj <>>>/Rotate 0/Type/Page>> endobj 28 0 obj <>stream /Rotate 0 Complaint for Emergency Injunctive Relief in Florida Primary The global coronavirus pandemic threatens to disrupt the Presidential Preference Primary election in Florida. 54. "New York City, NY area" means the Borough of Brooklyn, New York. 25 0 obj << endobj /Parent 12 0 R << 42. /Annots [] 0000001275 00000 n << 71 0 obj /Parent 7 0 R endobj /Parent 8 0 R /CropBox [0 0 612 792] >> /Annots [] /Parent 11 0 R /CropBox [0 0 612 792] /Resources 233 0 R /Rotate 0 /Type /Page Parties 13. /Annots [] << /Contents [378 0 R 379 0 R 380 0 R] endobj /MediaBox [0 0 612 792] >> << /Contents [306 0 R 307 0 R 308 0 R] 43 0 obj /Metadata 2 0 R 31. H*23430P AsKN$r{(s << /Type /Page /Annots [] << endobj /Contents [198 0 R 199 0 R 200 0 R] /MediaBox [0 0 612 792] 30. /Contents [142 0 R 143 0 R 144 0 R] judgment, and preliminary and permanent injunctive relief and damages. << /Annots [] /Resources 409 0 R >> /Resources 341 0 R Plaintiff complains and alleges as follows: 1. << /Type /Page To handle this high volume of MSW efficiently, haulers provide commercial customers with small dumpsters for storing the waste. /Count 10 28. PLAINTIFF'S COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF . 10. See Laws of Florida, Ch. 22408. 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. 36 0 obj /Type /Page /Resources 137 0 R 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. In the Macon, GA market, Allied and Republic each account for a substantial share of total revenues from roll-off waste collection services. Secure .gov websites use HTTPS endobj /MediaBox [0 0 612 792] /Resources 321 0 R /Rotate 0 /Parent 8 0 R /Annots [] /Contents [162 0 R 163 0 R 164 0 R] 0000002929 00000 n The Corps' environmental analysis for this project is based on the same assumptions and << Roll-off waste compactors are generally located at the site of the roll-off container, thereby permitting the customer to increase the container's on-site storage capacity. >> /MediaBox [0 0 612 792] 17 0 obj /MediaBox [0 0 612 792] ( /MediaBox [0 0 612 792] /Resources 317 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. 1 0 obj 0000003946 00000 n As a result, Austin begins the presentation by sharing some of the things you should think about before pursuing an injunction: There is a lot on the line. Republic is a Delaware corporation with its principal office in Ft. Lauderdale, Florida. >> 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. endobj endobj << Unless the twelve acquisitions are enjoined, consumers of waste collection and disposal services will likely pay higher prices and receive fewer services as a consequence of the elimination of the vigorous competition between defendants Allied and Republic. endobj /CropBox [0 0 612 792] >> /Contents [206 0 R 207 0 R 208 0 R] 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. 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. << /MediaBox [0 0 612 792] Filing fees $ 402.00 receipt number AFLSDC-16386893, filed by OMEGA SA.. (Attachments: #1 . 1 0 obj /CropBox [0 0 612 792] Managing Partner /CropBox [0 0 612 792] 53(b), to secure preliminary and permanent injunctive relief, rescission of contracts, restitution, disgorgement, and other . << /Contents [286 0 R 287 0 R 288 0 R] /Resources 345 0 R << endobj 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. 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. 21. /Resources 217 0 R "Norfolk, VA area" means the cities of Chesapeake, Suffolk, Virginia Beach, Norfolk, Poquoson, Newport News and Portsmouth, and York, Surry, James City, Southampton, and Isle of Wight counties, Virginia. Significant new entry into the disposal of MSW in the Anderson, IN and New York City, NY areas would be difficult and time-consuming. 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. << 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. << /Contents [322 0 R 323 0 R 324 0 R] Allied is the nation's second largest waste hauling and disposal company. 3. Allied and Republic are two of only a few providers of waste collection or disposal services in each of the identified areas. 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. Should you request a temporary injunction or push quickly for final permanent injunction. /Resources 193 0 R VERIFIED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF Introduction 1. /CropBox [0 0 612 792] 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 /Type /Page This is a lawsuit for declaratory and injunctive relief under 86.011, Fla. Stat. 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. >> /Annots [] << Complaint for Injunctive Relief and Civil Penalties (pdf) (1.93 MB) Contact Us to ask a question, provide feedback, or report a problem. A complaint for declaratory relief must allege the following: there is a bona fide dispute between the parties; the plaintiff has a justiciable question as to the existence or nonexistence of some right, status, immunity, power or privilege, or as to some fact upon which existence of such a claim may depend; <> >> << "Macon, GA area" means the City of Macon and Bibb, Peach and parts of Houston, Jones and Monroe counties, Georgia. startxref 7. /Parent 12 0 R /MediaBox [0 0 612 792] 86 0 obj 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. A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. /Type /Page Rule 1.610 of the Florida Rules of Civil Procedure governs requests for temporary injunctions. /Count 10 "0A149;>>>%.DIC; C << /Contents [138 0 R 139 0 R 140 0 R] Section 13(b) of the FTC Act, 15 U.S.C. /MediaBox [0 0 612 792] >> 12 0 obj Because of its characteristics (e.g. /Resources 185 0 R /CropBox [0 0 612 792] "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. 34. << /Rotate 0 /Rotate 0 ( /Rotate 0 3601, et seq. << 62 0 obj /Contents [394 0 R 395 0 R 396 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. ? 20. /CropBox [0 0 612 792] 6. /Rotate 0 endobj << >> /Count 79 42 0 obj >> /Type /Pages See also Chapter 224.08, Special Acts of Florida, 1943. See Merger Guidelines 1.51. /Resources 237 0 R /CropBox [0 0 612 792] /Type /Page 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. Very often courts do not grant injunctions if there is not a lot of specificity and practicality in the request for an injunction. 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. /Rotate 0 /Author (JacqmeinV) "Anderson, IN area" means the City of Anderson and Madison County, Indiana. /CropBox [0 0 612 792] /Type /Page /Type /Pages /Resources 385 0 R /Parent 12 0 R 70 0 obj /Type /Page /Resources 113 0 R >> endobj 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. /MediaBox [0 0 612 792] >> /MediaBox [0 0 612 792] Waiver recipients are entitled to continuation of services that they are currently receiving through the completion of the fair hearing /Type /Page 21 0 obj >> 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. << << << 80 0 obj Complaint for Injunctive Relief Case (s): U.S. v. Allied Waste Industries, Inc. and Republic Services, Inc. 83 0 obj % << Plaintiffs also seek temporary injunctive relief as stated in the accompanying Motion for Temporary Injunction. Plaintiff, The Second Amendment Foundation, is a Washington Not-For-Profit _______/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. 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. /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] /Subtype /XML endobj endobj Does the temporary injunction preserve the Status Quo or does it make a change? 91 0 obj 41 0 obj >> In 1998, for example, these three transfer stations disposed of over 85 percent of the MSW generated in the Anderson, IN area. /Resources 213 0 R /Annots [] /Rotate 0 56. That plaintiff recover the costs of this action. 22 and 28 U.S.C. /MediaBox [0 0 612 792] endobj IV. /Contents [362 0 R 363 0 R 364 0 R] endobj Plaintiff filed this action against defendant for breaching a non-competition agreement. 7 0 obj 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. endobj /Resources 161 0 R The City changed its name from "New 0000001852 00000 n The extension of vote-by-mail options and other accommodations at polling places is necessary. 94 0 obj /Type /Page 56 0 obj /Rotate 0 This action is brought to 24. In 1999, Allied reported total revenues of approximately $6 billion. endobj Jimerson Birr welcomes inquiries from the media and do our best to respond to deadlines. /Type /Page /Rotate 0 /CropBox [0 0 612 792] /Type /Page An individual commercial customer typically generates substantially more MSW than a residential customer. /Count 10 /Parent 4 0 R 37. /Contents [114 0 R 115 0 R 116 0 R] /Annots [] /Resources 189 0 R 10941 and Laws of Florida, Ch. Venue is proper in the Circuit Court of the Seventh Judicial Circuit, in and for /CropBox [0 0 612 792] Absent injunctive relief by this Court, Defendants are likely to continue to injure consumers, reap unjust enrichment, and harm the public interest. endobj /Contents [246 0 R 247 0 R 248 0 R] /Resources 373 0 R /Rotate 0 /CropBox [0 0 612 792] /Type /Pages %PDF-1.5 % /CropBox [0 0 612 792] /Rotate 0 endobj /Annots [] 15. D. P. et al., . "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. (ECF No. A .gov website belongs to an official government organization in the United States. 2 0 obj endobj "Louisville, KY/ Sellersburg, IN area" means the cities of Louisville, Kentucky and Sellersburg, Indiana; Jefferson County, Kentucky; and the parts of Floyd and Clark counties, Indiana abutting Jefferson County, Kentucky. /Parent 11 0 R /Rotate 0 2 0 obj << << /Annots [] /MediaBox [0 0 612 792] /Type /Page Charles B. Jimerson 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. /Parent 14 0 R /CropBox [0 0 612 792] 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 [338 0 R 339 0 R 340 0 R] >> 89 0 obj /Rotate 0 endobj 2320 0 obj<> endobj /Annots [] 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. endstream endobj 29 0 obj <>stream endobj 22. 6th Street Ft. Lauderdale, FL 33301 Defendants. /Length 10 >> 8 0 obj 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.