complaint for injunctive relief florida

The President of the United States and the Governor of Florida have each declared a state of emergency. 0000001469 00000 n /Contents [306 0 R 307 0 R 308 0 R] /Parent 9 0 R SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION In re: JOSE SANCHEZ Case No. This is an action for injunctive relief. 37 0 obj JFIF C /Rotate 0 endobj << Professional Services Industry Legal Blog>. 38 0 obj /Parent 14 0 R 65 0 obj /Rotate 0 /Contents [346 0 R 347 0 R 348 0 R] << /Parent 8 0 R 83 0 obj 8. /Type /Page /MediaBox [0 0 612 792] << 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. 51. /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] /Annots [] endobj On September 8, 2021, the Court, by consent, entered a preliminary injunction against Garcia. /Resources 97 0 R There are no good substitutes for MSW disposal. /Type /Page 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. /Parent 8 0 R .+p>hPhb4yiK=c`/XOv@|fe`iY /Rotate 0 /Rotate 0 6th Street Ft. Lauderdale, FL 33301 Defendants. xref /Type /Page EOs6~W\F3[_y7~r+W3nU>9YRpM/u"%1yK Ivp, Microsoft Word - 2022-08-24 - Complaint - FINAL. ( /CropBox [0 0 612 792] /Parent 4 0 R 21 0 obj >> /Type /Page 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. The likely effect of these acquisitions is to substantially lessen competition and to tend to create a monopoly in interstate trade and commerce in violation of Section 7 of the Clayton Act. ( /Annots [] 0000002992 00000 n endobj Very often courts do not grant injunctions if there is not a lot of specificity and practicality in the request for an injunction. /MediaBox [0 0 612 792] In its 1998 fiscal year, Republic reported total revenues of approximately $1.8 billion. endobj << 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. /Parent 13 0 R /Pages 4 0 R /Annots [] 0000001373 00000 n Defendants because the Amended Complaint seeks injunctive relief only for these Counts, to which qualified immunity does not apply. /Parent 13 0 R 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. MSW generated by residential customers, on the other hand, is often collected by either local governments or by private haulers pursuant to contracts bid by, or franchises granted by, municipal authorities. >> /Type /Page >> /Parent 11 0 R /Parent 11 0 R Waiver recipients are entitled to continuation of services that they are currently receiving through the completion of the fair hearing 62. >> Filing fees are due at the time a party files a pleading to initiate a proceeding or files a pleading for relief. 3 0 obj 22. The county court may issue a temporary and permanent injunction where appropriate for violation of ss. %PDF-1.3 % 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 27 0 obj endstream endobj 2333 0 obj<>/W[1 1 1]/Type/XRef/Index[246 2074]>>stream 45 0 obj 22408. /MediaBox [0 0 612 792] 43 0 obj 17 0 obj /Parent 7 0 R << 39 0 obj On residential routes, the crews generally hand-load the customer's MSW, typically by tossing garbage bags and emptying trash cans into the vehicle's storage section. 43. /Contents [338 0 R 339 0 R 340 0 R] CASE NO. endobj endobj << /Annots [] /Rotate 0 Small container commercial waste collection services are generally provided in highly localized areas because to operate efficiently and profitably, a hauler must have sufficient density in its commercial waste collection operations; i.e., a large number of commercial accounts that are reasonably close together. /Type /Page /Contents [406 0 R 407 0 R 408 0 R] 25. /CropBox [0 0 612 792] 0000000016 00000 n 70 0 obj 74 0 obj IV. 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. >> /Parent 9 0 R 15 0 obj >> /Type /Page /Type /Page 0000000817 00000 n 49 0 obj /Rotate 0 /Nums [0 6 0 R] 5. An individual commercial customer typically generates substantially more MSW than a residential customer. 35 0 obj /Parent 7 0 R To handle this high volume of MSW efficiently, haulers provide commercial customers with small dumpsters for storing the waste. 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. 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. /Annots [] After the acquisition, Allied would control over 50 percent--and two firms over 90 percent--of the small container commercial waste hauling market, which has annual revenues of about $31 million. 15. clearly appears from specific facts shown by affidavit or by verified complaint that immediate or Rule 1.610 of the Florida Rules of Civil Procedure governs requests for temporary injunctions. Complaint for purposes of Florida Statutes Sections 501.207(5) and 95.11(3). /Contents [214 0 R 215 0 R 216 0 R] << Filing 1 COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. /Parent 10 0 R This Court has the authority to grant the requested declaratory and injunctive relief pursuant to 28 U.S.C. /CropBox [0 0 612 792] ( ( << 94 0 obj /CropBox [0 0 612 792] /Annots [] /Contents [386 0 R 387 0 R 388 0 R] /Parent 13 0 R endobj /Type /Page 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. /Rotate 0 /Resources 209 0 R "Augusta, GA area" means the City of Augusta, Richmond and Columbia counties, Georgia, and Aiken County, South Carolina. /Type /Page /Contents [114 0 R 115 0 R 116 0 R] endobj Is the injunction prohibitory or mandatory? 3. << /Type /Page 53(b), to secure preliminary and permanent injunctive relief, rescission of contracts, restitution, disgorgement, and other . 90 0 obj 22 and 28 U.S.C. %&'()*456789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz w !1AQaq"2B #3Rbr 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. /Annots [] 22 0 obj 56 0 obj ( << /Annots [] Often businesses do not consider the implications for taking this action. % endobj /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] /Contents [102 0 R 103 0 R 104 0 R] >> << This action is brought to The global coronavirus pandemic threatens to disrupt the Presidential /Type /Page 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. /Contents [302 0 R 303 0 R 304 0 R] 1 0 obj /Contents [398 0 R 399 0 R 400 0 R] >> /PageLabels 3 0 R /Type /Page /Contents [370 0 R 371 0 R 372 0 R] 23. "Anderson, IN area" means the City of Anderson and Madison County, Indiana. Does the temporary injunction preserve the Status Quo or does it make a change? ]\q( $QSRP@=8`) $CC16 PI_ XL 18. << /Type /Page /Resources 205 0 R Z( endstream 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 . << : 01-42230-BKC-AJC . Plaintiff filed this action against defendant for breaching a non-competition agreement. /Type /Page ( /MediaBox [0 0 612 792] In order to obtain comparable operating efficiency, a new firm must achieve route density comparable to existing firms. << /MediaBox [0 0 612 792] /Parent 13 0 R /Contents [286 0 R 287 0 R 288 0 R] /MediaBox [0 0 612 792] 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. endobj Absent injunctive relief by this Court, Defendants are likely to continue to injure consumers, reap unjust enrichment, and harm the public interest. 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. endobj 25 0 obj 92 0 obj endobj (Compl . endobj /Rotate 0 ? /Parent 7 0 R << endstream /Annots [] 53 0 obj /Length 3282 >> Small Container Commercial Waste Collection Service. 14. 82 0 obj 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. 13(b) of the Federal Trade Commission Act ("FTC Act"), 15 U.S.C. endobj COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF . /Type /Page /MediaBox [0 0 612 792] >> 32. << endobj /Kids [55 0 R 56 0 R 57 0 R 58 0 R 59 0 R 60 0 R 61 0 R 62 0 R 63 0 R 64 0 R] /Rotate 0 /Annots [] /Resources 237 0 R 34 0 obj /Type /Page <> /MediaBox [0 0 612 792] 2322 0 obj<>stream 2018 to May 6, 2021. /Type /Pages endobj /CropBox [0 0 612 792] 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 [] (ECF No. << /Resources 381 0 R /Rotate 0 For example, for a market consisting of four firms with shares of thirty, thirty, twenty, and twenty percent, the HHI is 2600 (302 + 302 + 202 + 202 = 2600). ("MFS"), is a Florida corporation that has a principal place of . /Contents [110 0 R 111 0 R 112 0 R] and Florida Statute 86.011, et seq. 7 0 obj /Rotate 0 endobj /Type /Page Anderson, IN and New York City, NY are two such areas. << /Contents [374 0 R 375 0 R 376 0 R] 35. /Rotate 0 /MediaBox [0 0 612 792] endobj /Type /Page >> /Annots [] In addition to differences in container size, other factors distinguish roll-off waste collection from small container commercial and other types of waste collection. endobj trailer endobj /MediaBox [0 0 612 792] /CropBox [0 0 612 792] 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. /Contents [118 0 R 119 0 R 120 0 R] /CropBox [0 0 612 792] In the Macon, GA market, Allied and Republic each account for a substantial share of total revenues from roll-off waste collection services. /Resources 345 0 R /Contents [146 0 R 147 0 R 148 0 R] /Contents [378 0 R 379 0 R 380 0 R] 91 0 obj 18 0 obj 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. /Resources 113 0 R << endobj endobj 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. ( In these markets, Allied and Republic each account for a substantial share of MSW disposal capacity. %PDF-1.3 % << /Rotate 0 /Type /Page /CropBox [0 0 612 792] /MediaBox [0 0 612 792] INTRODUCTION . 46. << /MediaBox [0 0 612 792] The cost of transporting waste to a disposal site is often a substantial component of the cost of disposal. /MediaBox [0 0 612 792] /Resources 357 0 R /Parent 12 0 R For the Court's convenience, Florida has attached a redline, as Exhibit A, showing changes from the First Amended Complaint. /Parent 8 0 R 5 0 obj Security Personnel as Independent Contractors Part Ii: What Liability Is Incurred to the Company From Accidents Involving Independent Contractors? /Annots [] 18. endobj /CropBox [0 0 612 792] /Rotate 0 An official website of the United States government. /Annots [] << /Type /Pages %%EOF 0000001994 00000 n /CropBox [0 0 612 792] << /Parent 9 0 R /Resources 193 0 R /Rotate 0 45. /CropBox [0 0 612 792] This is an action for permanent injunctive relief, declaratory relief, and /Contents [138 0 R 139 0 R 140 0 R] endobj endobj /CropBox [0 0 612 792] /CropBox [0 0 612 792] xb```c``b`f`0gg@ ~G@|*{jd`q%T3e83:! @`HsXD|",e0`A 21. /Annots [] %PDF-1.5 % /Parent 13 0 R 30 0 obj /Rotate 0 >> /Resources 353 0 R Rather, these are some additional factors to consider while determining the feasibility of this action: Will the court be able to enforce the injunction, or will it require intensive court supervision? /Count 9 28 0 obj /Resources 189 0 R 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. Plaintiff, PRISON LEGAL NEWS ("PLN"), a project of the Human Rights Defense . /Type /Page Therefore, the video continues on this topic by explaining: A suit for injunction is an extraordinary remedy for businesses and individuals alike. "Macon, GA area" means the City of Macon and Bibb, Peach and parts of Houston, Jones and Monroe counties, Georgia. << /MediaBox [0 0 612 792] 64. << 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. >> 17. /Contents [238 0 R 239 0 R 240 0 R] /Annots [] A temporary injunction is sought to stop a party from engaging in certain conduct or to require a party to engage in certain conduct until a final decision may be made concerning the merits of the dispute. /Parent 11 0 R Complaint for Emergency Injunctive Relief in Florida Primary The global coronavirus pandemic threatens to disrupt the Presidential Preference Primary election in Florida. H*23430P AsKN$r{(s /Annots [] judgment, and preliminary and permanent injunctive relief and damages. /Rotate 0 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. /Rotate 0 /Annots [] /Resources 373 0 R /Parent 12 0 R << /MediaBox [0 0 612 792] 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. These differences mean that small container commercial waste collection firms can profitably increase their charges for small container commercial waste collection services without losing significant sales or revenues to firms engaged in the provision of other types of waste collection services. << D. P. et al., . /Contents [106 0 R 107 0 R 108 0 R] 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. /Type /Page /Count 10 endobj << 85 0 obj Section 13(b) of the FTC Act, 15 U.S.C. /Annots [] << << /Type /Page The acquisitions by Allied and Republic would remove a significant competitor in small container commercial waste collection service, roll-off waste collection service, and/or the disposal of MSW, in already highly concentrated and difficult-to-enter markets. 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. After the acquisition, Republic would control over 50 percent--and two firms over 80 percent-- of the small container commercial waste hauling market, which has annual revenues of about $29 million. >> << /Parent 13 0 R Transactions that increase the HHI by more than 100 points in highly concentrated markets presumptively raise antitrust concerns under the Horizontal Merger Guidelines issued by the U.S. Department of Justice and the Federal Trade Commission. This is a lawsuit for declaratory and injunctive relief under 86.011, Fla. Stat. /Type /Page 31 0 obj <>stream 1331 and 1337. /Annots [] Permit restrictions often impose severe limitations on the type and amount of waste that can be disposed of at landfills. 33 0 obj Federal, state and local safety, environmental, zoning, and permit laws and regulations dictate critical aspects of storage, handling, transportation, processing and disposal of MSW. 6 0 obj /Rotate 0 /MediaBox [0 0 612 792] "HHI" means the Herfindahl-Hirschman Index, a commonly accepted measure of market concentration. 68. xref Haulers, therefore, generally establish garages and related facilities within each major local area served. %PDF-1.5 3. 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. "Clarksville, TN area" means the City of Clarksville and Montgomery, Dickson, the northwestern part of Cheatham, and the western part of Robertson counties, Tennessee. /MediaBox [0 0 612 792] As such, following the process to the tee will help improve your chances for success. /CropBox [0 0 612 792] Should you request a temporary injunction or push quickly for final permanent injunction. endobj /Contents [182 0 R 183 0 R 184 0 R] >> << /Parent 10 0 R >> /Rotate 0 US District Court for the Southern District of Florida: Presiding Judge: Raag Singhal: Nature of Suit: Trademark: Cause of Action: 15 U.S.C. << 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] /MediaBox [0 0 612 792] relief pursuant to Chapter 86, Florida Statutes. /Parent 11 0 R /Rotate 0 THIS COURT'S POWER TO GRANT RELIEF 84. /Resources 197 0 R Page 3 of 15 7. "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. /CropBox [0 0 612 792] 64 0 obj /CropBox [0 0 612 792] 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. /CropBox [0 0 612 792] 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. MSW has physical characteristics that readily distinguish it from other liquid or solid waste. /Type /Page 0 /Contents [246 0 R 247 0 R 248 0 R] endobj /Resources 317 0 R "0A149;>>>%.DIC; C /Contents [242 0 R 243 0 R 244 0 R] The differences in the types and volume of MSW collected and in the equipment used in collection distinguish small container commercial waste collection from all other types of waste collection activities. /Producer <4163726F6261742044697374696C6C65722032322E30202857696E646F7773293B206D6F646966696564207573696E67206954657874AE20372E312E3620A9323030302D323031392069546578742047726F7570204E56202841646D696E697374726174697665204F6666696365206F662074686520556E697465642053746174657320436F757274733B206C6963656E7365642076657273696F6E29> A party seeking an injunction under general Florida case law must demonstrate: 1) irreparable harm; 2) a clear legal right; 3) an inadequate . /Length 10 87 0 obj >> /Contents [330 0 R 331 0 R 332 0 R] >> /CropBox [0 0 612 792] /Contents [134 0 R 135 0 R 136 0 R] >> 84 0 obj endobj 10 0 obj << /Resources 409 0 R endstream endobj 29 0 obj <>stream 66 0 obj /Type /Pages << xb```b``Ig`a`X @1V hdc [`&&v/>4427pHG(Og|sW(7_HPpXp'Skgu`.8!B=\2+".b4dh fZ!WHW3`W+.eP9(tb1P,%pX1EaSO6I)1] K,cMpl q m D@,"R:7S&`u@6j(LjfLT[D1,BPf:9= P1!$Ippa8fHNtD {,nPY 5 The customer's MSW is stored in much smaller containers (e.g., garbage bags or trash cans) and instead of FEL trucks, waste collection firms routinely use REL or side-load trucks, manned by larger crews (usually, two-or three-person teams). /CropBox [0 0 612 792] /Type /Page /CropBox [0 0 612 792] ( There are immediate expenditures necessary. Annotations: Subsection (b) of the rule extends the Small Claims Rules to all claims for money or property, even when expressed or coupled with a claim for equitable relief. /Annots [] 54. (2001). /Type /Page . ( In contrast to a commercial collection route, a residential waste collection route is significantly more labor intensive. /MediaBox [0 0 612 792] /Rotate 0 COMPLAINT FOR INJUNCTIVE RELIEF AND SANCTIONS Plaintiff, Donald F. Walton, United States Trustee for . /Annots [] Plaintiff complains and alleges as follows: 1. /Parent 8 0 R /Parent 14 0 R /Type /Page /Rotate 0 /Rotate 0 /Resources 329 0 R /Type /Page endobj >> /MediaBox [0 0 612 792] endobj /Type /Page endobj /Rotate 0 /Annots [] 75 0 obj /Annots [] 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. 28. 19 0 obj 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. /MediaBox [0 0 612 792] %PDF-1.4 % /Contents [230 0 R 231 0 R 232 0 R] /Contents [198 0 R 199 0 R 200 0 R] Does the injunction provide broad or limited relief? /MediaBox [0 0 612 792] /Parent 14 0 R 1391, . endobj ]Wx C1>*yvL#uR$=I$$WJQg%=ElRS3DE27y1 G. /CropBox [0 0 612 792] /Type /Page /MediaBox [0 0 612 792] 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. << 81 0 obj /Rotate 0 79 0 obj endstream endobj startxref /Annots [] /Parent 12 0 R . ASSOCIATION OF FLORIDA, MIGRANT CLINICIANS NETWORK, PINEROS Y . /CropBox [0 0 612 792] /Rotate 0 /CropBox [0 0 612 792] 57. /Contents [170 0 R 171 0 R 172 0 R] prescribed by these rules and by section 51.011, Florida Statutes, the statutory provision shall govern. Reopen fees are due at the time a party files a pleading to reopen a proceeding if at least 90 days have . /Parent 10 0 R >> /Resources 365 0 R 49. 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. /Type /Page Rather, its about dealing with the future, not something that happened in the past. /Parent 8 0 R 1114 Trademark Infringement . 48. 37. /Rotate 0 /Parent 7 0 R 0000000879 00000 n >> 42. /Type /Page Allied and Republic directly compete in roll-off waste collection service in a number of markets nationwide, including the Macon, GA area. 0000003868 00000 n /CropBox [0 0 612 792] >> 16. ( << The Anderson, IN and New York City, NY areas are therefore sections of the country, or relevant geographic markets, for purposes of analyzing the competitive effects of the acquisition under Section 7 of the Clayton Act. >> /Contents [270 0 R 271 0 R 272 0 R] /Rotate 0 Thus, small container commercial waste collection service is a line of commerce, or relevant service, for purposes of analyzing the effects of the acquisitions under Section 7 of the Clayton Act. /Filter /FlateDecode /Rotate 0 /Subtype /XML endobj Complaint for Injunctive Relief . /Resources 349 0 R 16 0 obj 2. << << Roll-off vehicles have no compaction system on board and are designed to carry only one large container at a time to a disposal site. << ( 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. 11 0 obj Because of the differences in the collection process, residential customers and commercial customers usually are organized into separate routes. /Type /Page Because of its characteristics (e.g. /Contents [390 0 R 391 0 R 392 0 R] /CropBox [0 0 612 792] For instance, in many states, most MSW is disposed of in landfills, which are permitted under and regulated by the state. After the acquisition, Republic would control over 60 percent of the roll-off hauling market, which has annual revenues of about $8 million. ( /Resources 169 0 R 0 61. /Resources 149 0 R endobj /Contents [294 0 R 295 0 R 296 0 R] Access to competitive disposal sites and reasonable disposal costs are important to providers of roll-off collection services. /MediaBox [0 0 612 792] /Rotate 0 /MediaBox [0 0 612 792] >> >> /Count 79 88 0 obj 0000006259 00000 n endobj 57 0 obj /Contents [254 0 R 255 0 R 256 0 R] /Resources 241 0 R /MediaBox [0 0 612 792] /Rotate 0 /Annots [] hbbd``b`@q=`v0012,I00"0 endstream endobj startxref 0 %%EOF 33 0 obj <>stream 47. /Contents [210 0 R 211 0 R 212 0 R] endobj ( << 41 0 obj

Did Maureen Maher Leave 48 Hours, John Fern Rgs Newcastle Illness, Articles C