In its 1998 fiscal year, Republic reported total revenues of approximately $1.8 billion. /CropBox [0 0 612 792] /Contents [154 0 R 155 0 R 156 0 R] /Contents [174 0 R 175 0 R 176 0 R] /Contents [386 0 R 387 0 R 388 0 R] 61 0 obj /Type /Page hUN@h/%FT""Qy@Kbxw81FgfvEN.tF2AiP9?{"1zQ. << /Parent 7 0 R /Annots [] << /Type /Page /Resources 273 0 R >> In the Macon, GA market, Allied and Republic each account for a substantial share of total revenues from roll-off waste collection services. 22 and 28 U.S.C. /Type /Page /Length 3282 endobj /Contents [170 0 R 171 0 R 172 0 R] /Annots [] /Resources 101 0 R 83.40 et seq. /Contents [186 0 R 187 0 R 188 0 R] >> "Albany, NY area" means the City of Albany and Albany, Schenectady, Saratoga, and Rensselaer counties, New York. /MediaBox [0 0 612 792] /Parent 12 0 R /Rotate 0 /CropBox [0 0 612 792] << >> x+ |
Likewise, roll-off customers generate volumes of waste which are too large to be serviced by a FEL truck on a pre-scheduled commercial route. /Type /Page /Resources 377 0 R /Annots [] 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. The Court has jurisdiction over this action and over the parties pursuant to 15 U.S.C. >> /Rotate 0 /Rotate 0 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. The transactions likely will have the following effects, among others: 1. /MediaBox [0 0 612 792] /Annots [] endobj /Annots [] 41 0 obj stream
/Count 10 /Type /Page /Type /Page 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. /CropBox [0 0 612 792] /Type /Page /MediaBox [0 0 612 792] 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. /Parent 13 0 R endobj H*23430P AsKN$r{(s
That plaintiff recover the costs of this action. >> /Resources 293 0 R /CropBox [0 0 612 792] /MediaBox [0 0 612 792] 23 0 obj /Parent 10 0 R /Resources 137 0 R COMPLAINT FOR INJUNCTIVE RELIEF AND SANCTIONS Plaintiff, Donald F. Walton, United States Trustee for . 0000001563 00000 n
/Type /Page Local public opposition often makes it more difficult and costly, and increases the time and uncertainty of successfully permitting a facility. >> for the Middle Distrct of Florida, hereby files this complaint for permanent injunction and alleges as follows: 1. The proposed acquisition would reduce from three to two the number of significant competitors for the disposal of MSW in the Anderson, IN area. /Annots [] 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. JacqmeinV /Annots [] /Parent 14 0 R ( /Resources 373 0 R /Parent 14 0 R
Complaint for Declaratory Relief in Florida - Trellis This action is filed by the United States of America under Section 15 of the Clayton Act, 15 U.S.C. Plaintiff, The Second Amendment Foundation, is a Washington Not-For-Profit /Contents [126 0 R 127 0 R 128 0 R] In their waste collection and waste disposal businesses, defendants make sales and purchases in interstate commerce, ship waste in the flow of interstate commerce, and engage in activities substantially affecting interstate commerce. stream
<< 66. /Annots [] /Type /Pages /Rotate 0 Should you request a temporary injunction or push quickly for final permanent injunction. /CropBox [0 0 612 792] 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. /Parent 11 0 R /Contents [334 0 R 335 0 R 336 0 R] /MediaBox [0 0 612 792] /Type /Page /Rotate 0 /Parent 8 0 R /Parent 14 0 R 19 0 obj /CropBox [0 0 612 792] Charles B. Jimerson /Contents [358 0 R 359 0 R 360 0 R] /Parent 10 0 R /Type /Page /CropBox [0 0 612 792] /MediaBox [0 0 612 792] >> 0000001641 00000 n
endobj /Resources 405 0 R ( /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. /Contents [138 0 R 139 0 R 140 0 R] << 0000001187 00000 n
/Rotate 0 IV. 34 0 obj >> /Annots [] >> /Parent 11 0 R 69. << << That defendants' proposed sales of hauling assets 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, and defendants' proposed sales of MSW disposal assets in the Anderson, IN; Macon, GA and New York City, NY area markets be adjudged and decreed to be unlawful and in violation of Section 7 of the Clayton Act; 2. /Type /Page /MediaBox [0 0 612 792] /Resources 205 0 R /CropBox [0 0 612 792] .t. /Resources 125 0 R /Contents [294 0 R 295 0 R 296 0 R] In these markets, Allied and Republic each account for a substantial share of MSW disposal capacity. /Resources 201 0 R To handle this high volume of MSW efficiently, haulers provide commercial customers with small dumpsters for storing the waste. /MediaBox [0 0 612 792] "Monmouth County, NJ area"means the City of Marlboro and Monmouth County, New Jersey. 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). >> /CropBox [0 0 612 792] 53 0 obj Venue is proper in the Circuit Court of the Seventh Judicial Circuit, in and for /Resources 385 0 R 56 0 obj Plaintiff, PRISON LEGAL NEWS ("PLN"), a project of the Human Rights Defense . See also Chapter 224.08, Special Acts of Florida, 1943.
(PC) Carroll v. Vallejo Police Department, et al., No. 1:2023cv00004 61. /CropBox [0 0 612 792] /Parent 10 0 R /Type /Page endobj 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 . 76 0 obj 7. >> _l {:\! endobj << /Contents [242 0 R 243 0 R 244 0 R] endstream x1 04) F&`/MFWxC. hbbd``b`@q=`v0012,I00"0
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PDF COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF - NSB Anglers Yacht /CropBox [0 0 612 792] In this presentation, Jimerson Birr Associate Austin B. Calhoun covers Florida law on injunctive relief as a remedy, the process for seeking and obtaining injunctive relief through the judicial system, pre-litigation considerations, and enforcement of an injunction order once entered. <>>>
/Rotate 0 << /CropBox [0 0 612 792] 26 0 obj /Annots [] /CropBox [0 0 612 792] 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. /Resources 249 0 R In the Anderson, IN area, almost all of the MSW generated is disposed of in one of three transfer stations. /Parent 11 0 R 59. ( 2201 a nd 2202. endobj >> /Rotate 0 endstream
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EOs6~W\F3[_y7~r+W3nU>9YRpM/u"%1yK Ivp, Microsoft Word - 2022-08-24 - Complaint - FINAL. /Resources 221 0 R 60 0 obj endobj 25 0 obj
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/Parent 11 0 R 29 0 obj An MSW disposal facility must be located on approved types of land and operated under prescribed procedures. /Parent 9 0 R /Parent 4 0 R JURISDICTION AND VENUE 2. << >> 36 0 obj 28 0 obj endobj endobj /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. /CropBox [0 0 612 792] /Contents [314 0 R 315 0 R 316 0 R] endobj /Type /Page /Parent 13 0 R /Type /Page
Complaint for Emergency Injunctive Relief in Florida Primary PDF Complaint for Permanent Injunction, Monetary Relief, and Other Relief hb```f`` $V30 1;oO_Ia`sF!gbl!O| `
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#%$""!&+7/&)4)! In such areas, many of the problems associated with the permitting and construction of a landfill could make it difficult to permit and construct a transfer station. /Contents [214 0 R 215 0 R 216 0 R] /Parent 8 0 R 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. endobj /Rotate 0 /Parent 9 0 R >> /Contents [302 0 R 303 0 R 304 0 R] /Rotate 0 On September 8, 2021, the Court, by consent, entered a preliminary injunction against Garcia. /MediaBox [0 0 612 792] >> /Rotate 0 Markets in which the HHI is between 1000 and 1800 points are considered to be moderately concentrated, and those in which the HHI is in excess of 1800 points are considered to be highly concentrated. /CropBox [0 0 612 792] /Resources 233 0 R /Rotate 0 31 0 obj
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/Type /Page /Parent 10 0 R "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. >> endobj 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. /Rotate 0 endobj 35 0 obj THIS COURT'S POWER TO GRANT RELIEF 84. Obtaining a permit to construct a new disposal facility or to expand an existing one is a costly and time-consuming process, which typically takes many years to conclude. /Type /Page . /Parent 12 0 R /CropBox [0 0 612 792] 55. 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. Because of its characteristics (e.g. endobj 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. 68. /Rotate 0 ( /Rotate 0 . >> 47. >> /CropBox [0 0 612 792] << Republic is engaged in providing waste collection and disposal services throughout the United States. << SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION In re: JOSE SANCHEZ Case No. Noncompete Agreements: Protecting Referral Relationships as Legitimate Business Interests, Hiring for Florida Banks and Credit Unions: A Summary of Background Checks and Other Information Required to Comply With Various Regulatory Schemes. >> /Type /Pages 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.