>> /Rotate 0 /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] endobj On September 8, 2021, the Court, by consent, entered a preliminary injunction against Garcia. %PDF-1.6 >> /Resources 377 0 R 22. /Type /Page >> /Annots [] >> Filing fees $ 402.00 receipt number AFLSDC-16386893, filed by OMEGA SA.. (Attachments: #1 . /Rotate 0 PDF Complaint for injunction and declaratory relief 41. Plaintiffs Rural & Migrant Ministry, Alianza Nacional De Campesinas, El Comite . 24. endobj /CropBox [0 0 612 792] 68 0 obj That plaintiff receive such other and further relief as the case requires and the Court deems proper; and. endobj /Resources 337 0 R /Contents [146 0 R 147 0 R 148 0 R] endobj VERIFIED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF Introduction 1. /CropBox [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. 83 0 obj 64. << (2001). /Type /Page 49 0 obj APPROPRIATENESS OF INJUNCTIVE RELIEF 26 . /Parent 14 0 R /Contents [102 0 R 103 0 R 104 0 R] 88 0 obj /Count 10 0000000879 00000 n 2 0 obj ( The extension of vote-by-mail options and other accommodations at polling places is necessary. 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. 7.) /MediaBox [0 0 612 792] /Resources 397 0 R endobj /MediaBox [0 0 612 792] << /Count 10 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 $17 million. %PDF-1.5 /Resources 113 0 R ]Wx C1>*yvL#uR$=I$$WJQg%=ElRS3DE27y1 G. /Resources 273 0 R "Albany, NY area" means the City of Albany and Albany, Schenectady, Saratoga, and Rensselaer counties, New York. Complaint for Emergency Injunctive Relief in Florida Primary The global coronavirus pandemic threatens to disrupt the Presidential Preference Primary election in Florida. 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. PDF COMPLAINT FOR PERMANENT INJUNCTION - United States Department of Justice US District Court for the Southern District of Florida: Presiding Judge: Raag Singhal: Nature of Suit: Trademark: Cause of Action: 15 U.S.C. /CropBox [0 0 612 792] 2018 to May 6, 2021. 0000000592 00000 n endobj << << /Rotate 0 << } !1AQa"q2#BR$3br hUN@h/%FT""Qy@Kbxw81FgfvEN.tF2AiP9?{"1zQ. /Rotate 0 >> 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. After the acquisition, Republic would control over 60 percent of the roll-off hauling market, which has annual revenues of about $8 million. 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. 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. /Parent 7 0 R /Type /Page >> <<14CA263718F8354CB34DA495C0495A29>]>> << ( 56. Filing fees are due at the time a party files a pleading to initiate a proceeding or files a pleading for relief. /Resources 285 0 R /Type /Page 64 0 obj /CropBox [0 0 612 792] << /Annots [] << << /MediaBox [0 0 612 792] /Rotate 0 /Parent 10 0 R /CropBox [0 0 612 792] >> .+p>hPhb4yiK=c`/XOv@|fe`iY Small Container Commercial Waste Collection Service. 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. /Type /Page 95 0 obj /Resources 309 0 R 57. 27. /Pages 4 0 R 6. endobj /Rotate 0 trailer /MediaBox [0 0 612 792] stream /Rotate 0 /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] >> 21-81099-CIV-CANNON/Reinhart . /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] Small container commercial service vehicles routinely employ compaction systems on the truck to increase storage capacity, and can empty numerous small containers located on a scheduled route before being driven to a disposal site. /Contents [358 0 R 359 0 R 360 0 R] /Count 10 /Type /Page /Parent 8 0 R /Parent 13 0 R /Annots [] <<21a9e19eaa9d774d8bfb9315a3d3f5db>]>> Official websites use .gov D. P. et al., . /Contents [202 0 R 203 0 R 204 0 R] /MediaBox [0 0 612 792] Z( /Count 10 Therefore, its important to not consider it a tool for righting a wrong. %PDF-1.5 % /PageLabels 3 0 R endobj 12. /Parent 9 0 R /Type /Page /Rotate 0 << >> /Contents [294 0 R 295 0 R 296 0 R] /Resources 189 0 R << >> Permit restrictions often impose severe limitations on the type and amount of waste that can be disposed of at landfills. Anderson, IN and New York City, NY are two such areas. 79 0 obj /Subtype /XML << /Parent 14 0 R /Contents [218 0 R 219 0 R 220 0 R] /Type /Page ( ( endobj /CropBox [0 0 612 792] >> Local public opposition often makes it more difficult and costly, and increases the time and uncertainty of successfully permitting a facility. 47 0 obj /Type /Pages Contains legal complaint for injunctive releif and civil penalties against BCX facility Site, Jacksonville, Duval County, Florida, June 7, 2004. /Contents [138 0 R 139 0 R 140 0 R] << /Parent 8 0 R /Type /Page If the major roll-off competitor in a market likewise precludes significant competition through the use of long-term customer contracts which automatically renew, entry by new competitors and growth from existing ones are further hindered. /Contents [370 0 R 371 0 R 372 0 R] /Parent 13 0 R /Parent 9 0 R 24 0 obj 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 [274 0 R 275 0 R 276 0 R] 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. <>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> /Rotate 0 /Annots [] H*23430P AsKN$r{(s ( 76 0 obj <> endobj Florida has reported 149 confirmed cases of COVID-19 and four deaths to date, with every expectation that these numbers will rise. endobj /CropBox [0 0 612 792] Private waste haulers typically contract directly with customers for the collection of waste generated by commercial accounts. 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. 3. 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. /CropBox [0 0 612 792] 55 0 obj In the Anderson, IN area, almost all of the MSW generated is disposed of in one of three transfer stations. >> /Annots [] clearly appears from specific facts shown by affidavit or by verified complaint that immediate or endobj /Parent 8 0 R 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. /Contents [398 0 R 399 0 R 400 0 R] /MediaBox [0 0 612 792] /Contents [338 0 R 339 0 R 340 0 R] "Monmouth County, NJ area"means the City of Marlboro and Monmouth County, New Jersey. endobj ( <> /Type /Page /Type /Page 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. /Resources 297 0 R 31. 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. %%EOF In the Macon, GA market, Allied and Republic each account for a substantial share of total revenues from roll-off waste collection services. /Rotate 0 ( ( 22 and 28 U.S.C. 1391, . << /CropBox [0 0 612 792] A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. endobj /Parent 9 0 R endobj 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. 80 0 obj endobj endobj >> /Contents [226 0 R 227 0 R 228 0 R] << /Parent 7 0 R /Type /Catalog ( /Parent 14 0 R /Resources 357 0 R /Annots [] Jimerson Birr welcomes inquiries from the media and do our best to respond to deadlines. /CropBox [0 0 612 792] /Annots [] 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. 22408. /Resources 361 0 R 15. 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 . /MediaBox [0 0 612 792] /Rotate 0 /Parent 9 0 R >> 18 0 obj /CropBox [0 0 612 792] for the Middle Distrct of Florida, hereby files this complaint for permanent injunction and alleges as follows: 1. 46 0 obj 89 0 obj 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. /Type /Page /Annots [] /Resources 165 0 R 61 0 obj endobj << It is engaged in providing waste collection and disposal services throughout the United States. /CropBox [0 0 612 792] 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.
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