/Resources 101 0 R x+ | >> /CropBox [0 0 612 792] /Type /Page H*23430P AsKN$r{(s /Rotate 0 << /Resources 241 0 R /Resources 189 0 R /Parent 12 0 R /MediaBox [0 0 612 792] /Rotate 0 endobj /Annots [] /Rotate 0 /Contents [230 0 R 231 0 R 232 0 R] trailer /Type /Page "Macon, GA area" means the City of Macon and Bibb, Peach and parts of Houston, Jones and Monroe counties, Georgia. /Type /Page 12. /Rotate 0 endobj /Type /Page 71 0 obj /Parent 12 0 R 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. endobj endobj /Type /Page /MediaBox [0 0 612 792] 62. /Contents [134 0 R 135 0 R 136 0 R] 47 0 obj 7. << /Resources 261 0 R Is the injunction prohibitory or mandatory? 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. /Resources 293 0 R 60 0 obj 55. The United States is entitled to injunctive relief under 26 U.S.C. 19 0 obj >> Significant new entry into the disposal of MSW in the Anderson, IN and New York City, NY areas would be difficult and time-consuming. /CropBox [0 0 612 792] >> /Annots [] Download the PDF of the Complaint IN THIS PUBLICATION Summary Issues COVID-19 For the Court's convenience, Florida has attached a redline, as Exhibit A, showing changes from the First Amended Complaint. /Type /Page 67. /Parent 14 0 R Therefore, the video continues on this topic by explaining: A suit for injunction is an extraordinary remedy for businesses and individuals alike. Therefore, it should not be a decision made lightly. %&'()*456789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz w !1AQaq"2B #3Rbr Plaintiff, Florida Carry, is a Florida Not-For-Profit Corporation with a principal place of business located at 1090 Wild Holly Drive, Port Orange, Florida, 32129. endobj /CropBox [0 0 612 792] The operator continues along the route, collecting MSW from each of the commercial accounts until the vehicle is full. 72 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. >> /CropBox [0 0 612 792] /Parent 7 0 R /Rotate 0 /Type /Page 89 0 obj >> /Parent 13 0 R /CropBox [0 0 612 792] << 13 0 obj /Contents [178 0 R 179 0 R 180 0 R] APPROPRIATENESS OF INJUNCTIVE RELIEF 26 . /MediaBox [0 0 612 792] /Type /Page 3. There are immediate expenditures necessary. 76 13 /Rotate 0 /Parent 13 0 R endobj The front-end load containers used by small container commercial collection customers cannot be serviced by roll-off trucks. The county court may issue a temporary and permanent injunction where appropriate for violation of ss. /Rotate 0 ( Republic is engaged in providing waste collection and disposal services throughout the United States. /Parent 11 0 R /Resources 369 0 R The length of the presentation is 46:09. competition generally in small container commercial waste collection service 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 will be lessened substantially; actual and potential competition between Allied and Republic in small container commercial waste collection service 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 will be eliminated; prices charged by 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 area markets will likely increase; competition generally in disposal of MSW in the Anderson, IN and New York City, NY area markets will be lessened substantially; actual and potential competition between Allied and Republic in disposal of MSW in the Anderson, IN and New York City, NY area markets will be eliminated; prices for disposal of MSW in the Anderson, IN and New York City, NY area markets likely will increase; competition generally in roll-off waste collection service in the Macon, GA area market will be lessened substantially; actual and potential competition between Allied and Republic in roll- off waste collection service in the Macon, GA area market will be eliminated; and. "New York City, NY area" means the Borough of Brooklyn, New York. /Rotate 0 /CropBox [0 0 612 792] 32 0 obj endobj 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 . On September 8, 2021, the Court, by consent, entered a preliminary injunction against Garcia. In its 1998 fiscal year, Republic reported total revenues of approximately $1.8 billion. /Resources 197 0 R /Annots [] The extension ofvote-by-mail options and other accommodations at polling places is necessary. /Resources 385 0 R How long will the injunction be effective? stream endobj /Contents [242 0 R 243 0 R 244 0 R] endobj endobj did not involve a claim for declaratory relief. The Court has jurisdiction over this action and over the parties pursuant to 15 U.S.C. << Federal, state and local safety, environmental, zoning, and permit laws and regulations dictate critical aspects of storage, handling, transportation, processing and disposal of MSW. 22 and 28 U.S.C. /Resources 317 0 R /MediaBox [0 0 612 792] /Rotate 0 /Annots [] /Parent 11 0 R /Rotate 0 /Rotate 0 } !1AQa"q2#BR$3br /Parent 13 0 R << "Clarksville, TN area" means the City of Clarksville and Montgomery, Dickson, the northwestern part of Cheatham, and the western part of Robertson counties, Tennessee. An MSW disposal facility must be located on approved types of land and operated under prescribed procedures. %PDF-1.3 % /Parent 13 0 R /Contents [322 0 R 323 0 R 324 0 R] << Rather, its about dealing with the future, not something that happened in the past. Small container commercial waste collection differs in many important respects from the collection of residential or other types of waste. /Nums [0 6 0 R] /MediaBox [0 0 612 792] /Contents [334 0 R 335 0 R 336 0 R] Last updated on November 21, 2022. /Annots [] 20 0 obj /Resources 205 0 R /MediaBox [0 0 612 792] 22408. As such, following the process to the tee will help improve your chances for success. 4. /Resources 409 0 R /Count 10 endobj ( /Contents [150 0 R 151 0 R 152 0 R] /Parent 4 0 R 48 0 obj 0000001275 00000 n /Type /Pages /Parent 9 0 R /Resources 129 0 R THIS COURT'S POWER TO GRANT RELIEF 84. /CropBox [0 0 612 792] << 41 0 obj /Annots [] 0000000817 00000 n 2. >> /Rotate 0 /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. /Resources 177 0 R /CropBox [0 0 612 792] 28. Plaintiff filed this action against defendant for breaching a non-competition agreement. /CropBox [0 0 612 792] 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. endobj /Type /Page 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). 33 0 obj << /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. /Parent 4 0 R /Rotate 0 << 3. /Resources 401 0 R >> /Rotate 0 /Type /Page /Annots [] 0000001994 00000 n Security Personnel as Independent Contractors Part Ii: What Liability Is Incurred to the Company From Accidents Involving Independent Contractors? The cost of transporting waste to a disposal site is often a substantial component of the cost of disposal. << ( /CropBox [0 0 612 792] Security Personnel as Independent Contractors Part I: What Makes an Individual an Independent Contractor Instead of an Employee? It is calculated by squaring the market share of each firm competing in the market and then summing the resulting numbers. /Parent 7 0 R /Parent 7 0 R >> /Count 9 /Contents [166 0 R 167 0 R 168 0 R] endobj /Type /Page /CropBox [0 0 612 792] >> In these markets, Allied and Republic each account for a substantial share of MSW disposal capacity. >> /Annots [] relief pursuant to Chapter 86, Florida Statutes. /Type /Page >> /Annots [] "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. 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. Filing fees $ 402.00 receipt number AFLSDC-16386893, filed by OMEGA SA.. (Attachments: #1 . /Parent 14 0 R /Resources 265 0 R /Rotate 0 ( /Type /Page /Contents [318 0 R 319 0 R 320 0 R] >> 45 0 obj ( >> Very often courts do not grant injunctions if there is not a lot of specificity and practicality in the request for an injunction. endobj /MediaBox [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. 50. 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. << /Parent 12 0 R /Contents [114 0 R 115 0 R 116 0 R] 6. clearly appears from specific facts shown by affidavit or by verified complaint that immediate or "Memphis, TN area" means Shelby County, Tennessee; Desoto County, Mississippi, and Crittenden County, Arkansas. /Rotate 0 /Parent 10 0 R /Contents [406 0 R 407 0 R 408 0 R] /Parent 13 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] >> 25. /MediaBox [0 0 612 792] >> Allied is the nation's second largest waste hauling and disposal company. endobj (ECF No. endobj >> endobj Page 3 of 15 7. /Type /Page This action is filed by the United States of America under Section 15 of the Clayton Act, 15 U.S.C. .t. << 78 0 obj /Type /Page endobj /Rotate 0 A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. /Resources 221 0 R . /Type /Page WEST PALM BEACH DIVISION . /Title (Microsoft Word - 2022-08-24 - Complaint - FINAL) /Annots [] 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. /MediaBox [0 0 612 792] /Type /Pages endobj The HHI increases both as the number of firms in the market decreases and as the disparity in size between those firms increases. 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 addition to differences in container size, other factors distinguish roll-off waste collection from small container commercial and other types of waste collection. >> /Resources 149 0 R 20. /Type /Page 8. /Contents [266 0 R 267 0 R 268 0 R] /Parent 13 0 R JFIF C 57. /CropBox [0 0 612 792] >> /Resources 193 0 R 61 0 obj >> /Parent 13 0 R endobj 60. >> >> /MediaBox [0 0 612 792] Reopen fees are due at the time a party files a pleading to reopen a proceeding if at least 90 days have . ( << /Type /Page /Rotate 0 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. 34 0 obj >> h|VrH}Weo2)RXBr|:=%ts?mlteQG :C:+rl86#m0GcfFmMb`4&;|Xy|^Q(&Y Jf#mb!nDlpfIi QB*Mg< ]\q( $QSRP@=8`) $CC16 PI_ XL /MediaBox [0 0 612 792] Access to competitive disposal sites and reasonable disposal costs are important to providers of roll-off collection services. /Resources 237 0 R /Filter /FlateDecode /Contents [370 0 R 371 0 R 372 0 R] endobj /Parent 12 0 R "Columbus, OH area" means the City of Columbus and Franklin and Delaware counties, Ohio. 42. 18. /Rotate 0 >> /Contents [182 0 R 183 0 R 184 0 R] /Annots [] 2 0 obj 3. /Type /Page endobj 31 0 obj <>stream /MediaBox [0 0 612 792] There could be a negative impact on the plaintiffs public image. /MediaBox [0 0 612 792] >> /Annots [] 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. endobj /Resources 249 0 R M`5`i`F{qZ
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