. The extension ofvote-by-mail options and other accommodations at polling places is necessary. endobj The significant share of the roll-off collection market which Republic would have, its control of the primary disposal sites in the area, and its frequent use of long-term, automatically renewing contracts with roll-off collection customers, would make entry into the Macon, GA roll-off waste collection market difficult, and unlikely to prevent market incumbents from significantly raising prices for the collection of roll-off waste following the acquisition. 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. /Contents [278 0 R 279 0 R 280 0 R] 8 0 obj 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. Thus, roll-off 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. 83 0 obj Complaint for Injunctive Relief Case (s): U.S. v. Allied Waste Industries, Inc. and Republic Services, Inc. << /Annots [] Defendant is defined as a "Public Accommodation" within meaning of Title III In addition, Wilson traveled at least twice to Florida for work-related trips in 2019, including once to Miami and Tampa in or around the spring of 2019 and once to Orlando in or around November or December 2019. 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. /Parent 12 0 R endobj >> It is calculated by squaring the market share of each firm competing in the market and then summing the resulting numbers. /Resources 101 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. >> /Rotate 0 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. 26 0 obj /Contents [98 0 R 99 0 R 100 0 R] /Rotate 0 19 0 obj After the acquisition, Republic would control over 85 percent of the small container commercial waste hauling market, which has annual revenues of about $5 million. The county court may issue a temporary and permanent injunction where appropriate for violation of ss. endobj /Resources 317 0 R /Annots [] /Type /Page (Compl . Annotations: Subsection (b) of the rule extends the Small Claims Rules to all claims for money or property, even when expressed or coupled with a claim for equitable relief. /Contents [110 0 R 111 0 R 112 0 R] /Resources 161 0 R >> 48 0 obj (PC) Carroll v. Vallejo Police Department, et al., No. 1:2023cv00004 /Parent 10 0 R D. Entry Into Commercial Waste Collection of MSW. endobj /Resources 209 0 R /Annots [] 21-81099-CIV-CANNON/Reinhart . /Resources 157 0 R /Type /Pages /MediaBox [0 0 612 792] 6th Street Ft. Lauderdale, FL 33301 Defendants. /MediaBox [0 0 612 792] Virtually all of the MSW generated in each of these areas is disposed of in transfer stations in each of their local areas. /Contents [270 0 R 271 0 R 272 0 R] /Resources 149 0 R << 45], filed on August 192021, . How to Obtain a Temporary (Preliminary) Injunction in Florida - Ewusiak Law >> /Type /Page << /Rotate 0 /Type /Page /CropBox [0 0 612 792] /Type /Page stream
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K,cMpl q m D@,"R:7S&`u@6j(LjfLT[D1,BPf:9= P1!$Ippa8fHNtD {,nPY 5 << /CropBox [0 0 612 792] "Anderson, IN area" means the City of Anderson and Madison County, Indiana. 0000001852 00000 n
2320 14
/MediaBox [0 0 612 792] /Annots [] << Complaint for Emergency Injunctive Relief in Florida Primary The global coronavirus pandemic threatens to disrupt the Presidential Preference Primary election in Florida. /Annots [] 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. 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] << The United States is entitled to injunctive relief under 26 U.S.C. /Annots [] 92 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. /Contents [370 0 R 371 0 R 372 0 R] >> /Annots [] 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. 43. /Subtype /XML /MediaBox [0 0 612 792] /Annots [] In its 1998 fiscal year, Republic reported total revenues of approximately $1.8 billion. 22. /Resources 113 0 R 0000001563 00000 n
88 0 obj /MediaBox [0 0 612 792] << /Resources 273 0 R ( Complaint for Injunctive Relief . Security Personnel as Independent Contractors Part Ii: What Liability Is Incurred to the Company From Accidents Involving Independent Contractors? ( /Kids [7 0 R 8 0 R 9 0 R 10 0 R 11 0 R 12 0 R 13 0 R 14 0 R] /Resources 373 0 R << /MediaBox [0 0 612 792] 39. /Parent 7 0 R .t. << endobj /CropBox [0 0 612 792] /CropBox [0 0 612 792] >> /Kids [15 0 R 16 0 R 17 0 R 18 0 R 19 0 R 20 0 R 21 0 R 22 0 R 23 0 R 24 0 R] What impact will it have on third-parties and employees? endobj
<< 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. /CropBox [0 0 612 792] The operator continues along the route, collecting MSW from each of the commercial accounts until the vehicle is full. 22408. /MediaBox [0 0 612 792] endobj /CropBox [0 0 612 792] endobj /Annots [] Does the injunction provide broad or limited relief? >> /Parent 8 0 R /MediaBox [0 0 612 792] 3 0 obj
hUN@h/%FT""Qy@Kbxw81FgfvEN.tF2AiP9?{"1zQ. /CropBox [0 0 612 792] 2. << /Type /Pages %&'()*456789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz w !1AQaq"2B #3Rbr The global coronavirus pandemic threatens to disrupt the Presidential 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. "Columbus, OH area" means the City of Columbus and Franklin and Delaware counties, Ohio. /Annots [] 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 Augusta, GA area, the acquisition would reduce from three to two the number of significant competitors in the collection of small container commercial waste. The cost of transporting waste to a disposal site is often a substantial component of the cost of disposal. /Resources 301 0 R /Contents [238 0 R 239 0 R 240 0 R] /Resources 189 0 R 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. 27 0 obj VERIFIED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF Introduction 1. << << >> /Type /Page In re Amendments to Florida Small Claims Rules, 123 So.3d 41 (Fla . /Type /Page 60 0 obj "Macon, GA area" means the City of Macon and Bibb, Peach and parts of Houston, Jones and Monroe counties, Georgia. 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. /Type /Pages /Type /Page << %PDF-1.6 52 0 obj /Contents [266 0 R 267 0 R 268 0 R] << 34. /Type /Page /Resources 241 0 R 4. /Parent 9 0 R endobj /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] ( /Kids [65 0 R 66 0 R 67 0 R 68 0 R 69 0 R 70 0 R 71 0 R 72 0 R 73 0 R 74 0 R] /Parent 10 0 R /Contents [254 0 R 255 0 R 256 0 R] In the Macon, GA area, the proposed acquisitions would result in Republic controlling more than 60 percent of the roll-off waste collection market at the same time it owns the two primary disposal options which any roll-off competitor would most likely use. /Contents [390 0 R 391 0 R 392 0 R] 35. /Parent 11 0 R
/Parent 9 0 R << /Rotate 0 /Parent 7 0 R Complaint for Declaratory Relief in Florida - Trellis >> /Annots [] 29 0 obj /Rotate 0 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. 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. /CropBox [0 0 612 792] The transactions likely will have the following effects, among others: 1. /Annots [] /Annots [] /Parent 10 0 R /CropBox [0 0 612 792] /Type /Page endobj /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] Often businesses do not consider the implications for taking this action. 4. have exclusive jurisdiction: (a) In all actions at law cognizable by the county . /Contents [194 0 R 195 0 R 196 0 R] 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. /Type /Page /Parent 4 0 R /Rotate 0 /CropBox [0 0 612 792]