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. /Resources 125 0 R /MediaBox [0 0 612 792] /Annots [] /MediaBox [0 0 612 792] /Resources 109 0 R >> In 1998, for example, these three transfer stations disposed of over 85 percent of the MSW generated in the Anderson, IN area. 0000006259 00000 n 49 0 obj 46 0 obj /MediaBox [0 0 612 792] >> 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. endstream /CropBox [0 0 612 792] judgment, and preliminary and permanent injunctive relief and damages. /CropBox [0 0 612 792] /CropBox [0 0 612 792] >> .+p>hPhb4yiK=c`/XOv@|fe`iY 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. 1 0 obj Defendants Allied and Republic collect municipal solid waste from residential, commercial, and industrial customers, and they own and operate transfer stations, landfills, and incinerators, which process and dispose of municipal solid waste. ( 83.40 et seq. Therefore, its important to not consider it a tool for righting a wrong. /Parent 9 0 R 26 0 obj /CropBox [0 0 612 792] The operator then drives the FEL truck to a disposal facility, such as a transfer station, landfill or incinerator, and empties the contents of the vehicle. /Count 9 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. That plaintiff recover the costs of this action. Does the temporary injunction preserve the Status Quo or does it make a change? ( endstream endobj 2333 0 obj<>/W[1 1 1]/Type/XRef/Index[246 2074]>>stream >> /CropBox [0 0 612 792] /Contents [158 0 R 159 0 R 160 0 R] 78 0 obj Allied and Republic are two of only a few providers of waste collection or disposal services in each of the identified areas. 67 0 obj >> /Type /Pages /Parent 14 0 R >> /Producer <4163726F6261742044697374696C6C65722032322E30202857696E646F7773293B206D6F646966696564207573696E67206954657874AE20372E312E3620A9323030302D323031392069546578742047726F7570204E56202841646D696E697374726174697665204F6666696365206F662074686520556E697465642053746174657320436F757274733B206C6963656E7365642076657273696F6E29> 70 0 obj 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. INTRODUCTION . /Rotate 0 64 0 obj >> Plaintiff filed this action against defendant for breaching a non-competition agreement. /CropBox [0 0 612 792] /Type /Catalog 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. 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. } !1AQa"q2#BR$3br /CropBox [0 0 612 792] << 2018 to May 6, 2021. endobj /CropBox [0 0 612 792] /Contents [278 0 R 279 0 R 280 0 R] ("MFS"), is a Florida corporation that has a principal place of . 2322 0 obj<>stream hUN@h/%FT""Qy@Kbxw81FgfvEN.tF2AiP9?{"1zQ. 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. /Type /Page An individual commercial customer typically generates substantially more MSW than a residential customer. 9. /Contents [350 0 R 351 0 R 352 0 R] >> <<21a9e19eaa9d774d8bfb9315a3d3f5db>]>> << 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. 24 0 obj Page 3 of 15 7. >> /Parent 9 0 R >> 2201-202, and . endobj /Parent 11 0 R /Rotate 0 /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 149 0 R 0 In 1999, Allied reported total revenues of approximately $6 billion. << /Type /Page /Parent 14 0 R the Florida Deceptive and Unfair Trade Practices Act, Chapter 501, Part II, Florida Statutes ("FDUTPA"), which authorizes the State of Florida to seek, and the Court to order, permanent injunctive relief, recission or reformation of contracts, consumer restitution, the refund of monies 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. >> /CropBox [0 0 612 792] /Parent 8 0 R 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. clearly appears from specific facts shown by affidavit or by verified complaint that immediate or /Parent 8 0 R /Annots [] /MediaBox [0 0 612 792] /Annots [] /Rotate 0 /Resources 401 0 R /CropBox [0 0 612 792] 82 0 obj /Length 1411 /Rotate 0 Florida has reported 149 confirmed cases of COVID-19 and four deaths to date, with every expectation that these numbers will rise. 0000006750 00000 n endobj /Contents [294 0 R 295 0 R 296 0 R] /Annots [] 0000003946 00000 n hb```f`` $V30 1;oO_Ia`sF!gbl!O| ` /Contents [270 0 R 271 0 R 272 0 R] /Rotate 0 >> /Resources 129 0 R U.S. v. Allied Waste Industries, Inc. and Republic Services, Inc. /MediaBox [0 0 612 792] 0000001187 00000 n << endobj /Parent 4 0 R endobj /Annots [] did not involve a claim for declaratory relief. /Rotate 0 /Parent 13 0 R endobj /CropBox [0 0 612 792] >> ( 50. 68. 12. /Parent 8 0 R /Resources 197 0 R /Resources 389 0 R 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. /Type /Page 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 Section 13(b) of the FTC Act, 15 U.S.C. 13(b) of the Federal Trade Commission Act ("FTC Act"), 15 U.S.C. 40. /Annots [] endobj endobj (ECF No. 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 . Professional Services Industry Legal Blog>. 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 . Less frequently, haulers may use more maneuverable, but less efficient, rear-end loader ("REL") trucks, especially in those areas in which a collection route includes narrow alleyways or streets. /Rotate 0 /Annots [] /MediaBox [0 0 612 792] endobj /CropBox [0 0 612 792] 8 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. In addition, be sure you have competent, knowledgeable and experienced counsel in your corner. /Parent 4 0 R /Resources 185 0 R The HHI takes into account the relative size and distribution of the firms in a market and approaches zero when a market consists of a large number of firms of relatively equal size. 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 /Rotate 0 /Resources 153 0 R %PDF-1.3 % Roll-off haulers typically deal with larger waste volumes from a single customer for which disposal costs constitute a greater percentage of the total revenue received for the service. /MediaBox [0 0 612 792] /Type /Page 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 15 0 obj /MediaBox [0 0 612 792] 25. /Contents [274 0 R 275 0 R 276 0 R] 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. Plaintiff LEAGUE OF WOMEN VOTERS OF FLORIDA ("LWVF" or the "League") is the Florida affiliate of the League of Women Voters of the United States.

St Rose Of Lima Catholic School Tuition, Articles C