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/CropBox [0 0 612 792] /Parent 13 0 R /CropBox [0 0 612 792] >> /Contents [114 0 R 115 0 R 116 0 R] /MediaBox [0 0 612 792] /Type /Page 80 0 obj WEST PALM BEACH DIVISION . endobj 45. 29 0 obj endobj /CropBox [0 0 612 792] 18 0 obj 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. >> 0000001187 00000 n
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/MediaBox [0 0 612 792] After the acquisition, Allied would be a monopolist controlling over 98 percent of the small container Commercial waste hauling market, which has annual revenues of about $5 million. /MediaBox [0 0 612 792]
(Compl . /Annots [] /Contents [330 0 R 331 0 R 332 0 R] 0000001469 00000 n
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K,cMpl q m D@,"R:7S&`u@6j(LjfLT[D1,BPf:9= P1!$Ippa8fHNtD {,nPY 5 The predictable result is the denial of the vote to untold numbers of Floridians who had planned to vote in person on Election Dayincluding those who are elderly or have health conditions and cannot get to the polls without tremendous risk, university students who are no longer present in their county of registration because their dorms have closed, and those who venture out but encounter long lines and confusion at the polls. ( /Resources 317 0 R /Annots [] /Parent 11 0 R 31. /MediaBox [0 0 612 792] /Parent 7 0 R Small container commercial waste collection services are generally provided in highly localized areas because to operate efficiently and profitably, a hauler must have sufficient density in its commercial waste collection operations; i.e., a large number of commercial accounts that are reasonably close together. << Does the temporary injunction preserve the Status Quo or does it make a change? 47. 25. ]Wx C1>*yvL#uR$=I$$WJQg%=ElRS3DE27y1 G. ( /Type /Page "Augusta, GA area" means the City of Augusta, Richmond and Columbia counties, Georgia, and Aiken County, South Carolina. 0000001149 00000 n
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/CreationDate (D:20220824140929-04'00') In its 1998 fiscal year, Republic reported total revenues of approximately $1.8 billion. /Parent 14 0 R /Rotate 0 /Parent 10 0 R /Contents [246 0 R 247 0 R 248 0 R] PLAINTIFF'S COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF . After the acquisition, Republic would control about 31 percent--and two firms over 80 percent--of the small container commercial waste hauling market, which has annual revenues exceeding $24 million. endobj /Parent 12 0 R A temporary injunction is sought to stop a party from engaging in certain conduct or to require a party to engage in certain conduct until a final decision may be made concerning the merits of the dispute. /Parent 7 0 R << 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. /CropBox [0 0 612 792] /Annots [] 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. 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. /Filter /FlateDecode Plaintiff filed this action against defendant for breaching a non-competition agreement. Alexdex. /Parent 11 0 R 5 0 obj
/Type /Page >> 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. /Type /Page There are immediate expenditures necessary. Transactions that increase the HHI by more than 100 points in highly concentrated markets presumptively raise antitrust concerns under the Horizontal Merger Guidelines issued by the U.S. Department of Justice and the Federal Trade Commission.
>> /Contents [150 0 R 151 0 R 152 0 R] endobj >> After the acquisition, Allied would control over 55 percent--and two firms over 90 percent--of the small container commercial waste hauling market, which has annual revenues of about $28 million.
(PC) Carroll v. Vallejo Police Department, et al., No. 1:2023cv00004 CASE NO. /Type /Page Does the injunction provide broad or limited relief?
PDF Complaint for injunction and declaratory relief << (ECF No. /Contents [346 0 R 347 0 R 348 0 R] /Annots [] endobj 0000001994 00000 n
Date: Wednesday, June 21, 2000 Document Type: Complaint This document is available in two formats: this web page (for browsing content) and PDF (comparable to original document formatting). >> /Type /Page /Parent 7 0 R >> /Annots [] 9 0 obj /Rotate 0 51 0 obj /Resources 169 0 R 12. /CropBox [0 0 612 792] /CropBox [0 0 612 792] 10941 and Laws of Florida, Ch. /Contents [134 0 R 135 0 R 136 0 R] /Contents [174 0 R 175 0 R 176 0 R] /MediaBox [0 0 612 792] /CropBox [0 0 612 792]
/Parent 11 0 R /Annots [] 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. >> /Annots [] ( /CropBox [0 0 612 792] /Annots [] D. P. et al., . 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. 7402(a) to prevent such conduct. 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. >> /Contents [390 0 R 391 0 R 392 0 R] >> >> << >> The operator continues along the route, collecting MSW from each of the commercial accounts until the vehicle is full. 0
>> After the acquisition, Allied would control roughly 69 percent--and two firms over 90 percent--of the small container commercial waste hauling market, which has annual revenues exceeding $25 million. "Clarksville, TN area" means the City of Clarksville and Montgomery, Dickson, the northwestern part of Cheatham, and the western part of Robertson counties, Tennessee. /CropBox [0 0 612 792] /Resources 365 0 R << endstream >>
PDF United States District Court Southern District of Florida Case No /CropBox [0 0 612 792] endobj << Anyone who fails to dispose of MSW in an approved facility can be subject to severe civil and criminal penalties. endobj /Rotate 0 /MediaBox [0 0 612 792] >> /Rotate 0 65 0 obj /Contents [314 0 R 315 0 R 316 0 R] /Annots [] The global coronavirus pandemic threatens to disrupt the Presidential >> /Rotate 0 34.
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/Parent 10 0 R 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. 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. /Contents [222 0 R 223 0 R 224 0 R] 89 0 obj >> These differences mean that roll-off waste collection firms can profitably increase their charges for roll-off waste collection services without losing significant sales or revenues to firms engaged in the provision of other types of waste collection services. /CropBox [0 0 612 792]
/Parent 4 0 R 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. 3.
In the United States District Court for The Southern District of New York The differences in the types and volume of MSW collected and in the equipment used in collection distinguish small container commercial waste collection from all other types of waste collection activities. 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.