/CropBox [0 0 612 792] /CropBox [0 0 612 792] /MediaBox [0 0 612 792] /Type /Page /MediaBox [0 0 612 792] /Rotate 0 After the acquisition, Republic would control about 40 percent--and three firms over 75 percent--of the small container commercial waste hauling market, which has annual revenues of about $18 million. /Type /Page /Type /Pages 40. 46 0 obj On a typical small container commercial waste collection route, an operator drives a FEL vehicle to the customer's container, engages a mechanism that grasps and lifts the container over the front of the truck, and empties the container into the vehicle's storage section, where the waste is compacted and stored. /Contents [190 0 R 191 0 R 192 0 R] H*23430P AsKN$r{(s /CropBox [0 0 612 792] /Resources 333 0 R Does the courts have ability to enforce what you are requesting? ( /Contents [298 0 R 299 0 R 300 0 R] 16 0 obj /Type /Page /Type /Page /Resources 317 0 R /CropBox [0 0 612 792] /Rotate 0 /Resources 149 0 R /Rotate 0 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. >> /Contents [314 0 R 315 0 R 316 0 R] 20. << /Type /Page Reopen fees are due at the time a party files a pleading to reopen a proceeding if at least 90 days have . /Rotate 0 /Resources 125 0 R /Rotate 0 << (ECF No. /CropBox [0 0 612 792] /Contents [306 0 R 307 0 R 308 0 R] /MediaBox [0 0 612 792] << >> And yet the State of Florida (the State) has failed to take reasonable emergency measures necessary for voter participation in the face of this crisis. /Annots [] U.S. v. Allied Waste Industries, Inc. and Republic Services, Inc. /Annots [] /Rotate 0 /MediaBox [0 0 612 792] /Count 10 /Type /Catalog 19 0 obj /Type /Page /Resources 105 0 R /Rotate 0 >> << 1 0 obj /Parent 12 0 R >> Microsoft Word - 2022-08-24 - Complaint - FINAL /Parent 12 0 R /Length 10 <<14CA263718F8354CB34DA495C0495A29>]>> /CropBox [0 0 612 792] endobj In the Anderson, IN area, almost all of the MSW generated is disposed of in one of three transfer stations. Plaintiff, The Second Amendment Foundation, is a Washington Not-For-Profit 0000003404 00000 n >> 1 0 obj Firms that compete in the disposal of MSW generated in the Anderson, IN or New York City, NY areas can profitably increase their charges for disposal of MSW generated in each area without losing significant sales to more distant disposal sites. 29 0 obj endobj /Annots [] endobj /Parent 4 0 R 51. endobj /Rotate 0 45. /Parent 14 0 R /Contents [186 0 R 187 0 R 188 0 R] endobj 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. /Resources 385 0 R >> not 93 0 obj 61. /Parent 12 0 R /Contents [142 0 R 143 0 R 144 0 R] /Rotate 0 >> /Type /Page 76 0 obj << /Annots [] The county court may issue a temporary and permanent injunction where appropriate for violation of ss. /Contents [242 0 R 243 0 R 244 0 R] The transactions likely will have the following effects, among others: 1. 1. /Type /Page /Rotate 0 /MediaBox [0 0 612 792] 24. /Annots [] /Parent 9 0 R /Contents [294 0 R 295 0 R 296 0 R] /Annots [] 2. /Rotate 0 Charles B. Jimerson << The extension of vote-by-mail options and other accommodations at polling places is necessary. /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] In re Amendments to Florida Small Claims Rules, 123 So.3d 41 (Fla . << %PDF-1.3 % /Resources 249 0 R /Type /Page /Contents [178 0 R 179 0 R 180 0 R] endobj ( /Resources 365 0 R /Rotate 0 for the Middle Distrct of Florida, hereby files this complaint for permanent injunction and alleges as follows: 1. /CropBox [0 0 612 792] /Resources 309 0 R 55 0 obj Venue is therefore proper in this district under Section 12 of the Clayton Act, 15 U.S.C. /CropBox [0 0 612 792] /Parent 12 0 R /CropBox [0 0 612 792] xYYoH~7"b` recB$hHjRbK6DQ]]WUMb8`}^^l,q8x1O,7~`[)gD,uq+sU+PP)>f90VY-^AEKS2t}g4 X!xH rTmvF4(,W`{kF$tC /Parent 13 0 R /Contents [94 0 R 95 0 R 96 0 R] /Type /Page /MediaBox [0 0 612 792] Entry would also be made more difficult by Republic's use of long-term, automatically renewing contracts for roll-off service. 52. What happens if the temporary injunction is not granted? /Parent 13 0 R /Annots [] 42. 54 0 obj /Type /Pages /Parent 11 0 R In such instances, the waste is brought to a nearby transfer station where it is compacted and combined with other waste and then transported to a more distant permanent disposal site. : 01-42230-BKC-AJC . /Annots [] /Resources 329 0 R 7. /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] /Contents [270 0 R 271 0 R 272 0 R] /Rotate 0 Haulers, therefore, generally establish garages and related facilities within each major local area served. 83.40 et seq. /Parent 13 0 R 88 0 obj<>stream After the acquisition, Allied would control over 50 percent--and two firms over 90 percent--of the small container commercial waste hauling market, which has annual revenues of about $31 million. /Type /Page Garcia is a resident of North Lauderdale, Fl orida. >> <>>> << /Length 3282 43. /Resources 189 0 R endobj /Type /Page 58. >> Private waste haulers typically contract directly with customers for the collection of waste generated by commercial accounts. 22 and 28 U.S.C. << /MediaBox [0 0 612 792] /CropBox [0 0 612 792] endobj /Rotate 0 /Resources 337 0 R /Contents [342 0 R 343 0 R 344 0 R] >> /Rotate 0 /Parent 7 0 R >> ASSOCIATION OF FLORIDA, MIGRANT CLINICIANS NETWORK, PINEROS Y . 0000006750 00000 n << endobj endstream endobj 26 0 obj <> endobj 27 0 obj <>>>/Rotate 0/Type/Page>> endobj 28 0 obj <>stream >> >> clearly appears from specific facts shown by affidavit or by verified complaint that immediate or 31 0 obj /Parent 11 0 R /Resources 145 0 R endobj prescribed by these rules and by section 51.011, Florida Statutes, the statutory provision shall govern. 12. (Compl . /MediaBox [0 0 612 792] In addition, a FEL or REL vehicle cannot be efficiently driven long distances without collecting significant amounts of MSW, which makes it economically impractical for a small container commercial waste collection firm to serve metropolitan areas from a distant base. /CropBox [0 0 612 792] /Parent 4 0 R 3. 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. "0A149;>>>%.DIC; C >> /MediaBox [0 0 612 792] /Type /Page In this presentation, Jimerson Birr AssociateAustin B. Calhouncovers 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. "Anderson, IN area" means the City of Anderson and Madison County, Indiana. << Jurisdiction is conferred on this Court by Chapters 26, 34, 86.011. /MediaBox [0 0 612 792] << 9. >> >> << Allied is a Delaware corporation with its principal office in Scottsdale, Arizona. /Contents [166 0 R 167 0 R 168 0 R] There are immediate expenditures necessary. /Parent 8 0 R >> endobj 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. /Resources 273 0 R /Type /Page << /Parent 8 0 R 4 0 obj endobj /Contents [266 0 R 267 0 R 268 0 R] Filing fees $ 402.00 receipt number AFLSDC-16386893, filed by OMEGA SA.. (Attachments: #1 . $4%&'()*56789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz r! 69 0 obj /Resources 137 0 R 45 0 obj /Annots [] /Rotate 0 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. 3601, et seq. Professional Services Industry Legal Blog>. 72 0 obj ( /MediaBox [0 0 612 792] /Rotate 0 In the Albany, NY area, the proposed acquisition would reduce from four to three the number of significant competitors in the collection of small container commercial waste. endobj /CropBox [0 0 612 792] 0000002992 00000 n .t. endstream endobj 2333 0 obj<>/W[1 1 1]/Type/XRef/Index[246 2074]>>stream /Contents [258 0 R 259 0 R 260 0 R] /CropBox [0 0 612 792] /Rotate 0 /Rotate 0 /Rotate 0 /Type /Page >> REPUBLIC SERVICES, INC., 110 S.E. /Contents [362 0 R 363 0 R 364 0 R] M`5`i`F{qZ /Annots [] /Type /Page << /Parent 11 0 R << Download the PDF of the Complaint IN THIS PUBLICATION Summary Issues COVID-19 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 the Anderson, IN and New York City, NY areas, entry by any new MSW disposal facility would be an extremely costly and time-consuming process, and unlikely to prevent market incumbents from significantly raising prices for the disposal of MSW following the acquisition. /Contents [402 0 R 403 0 R 404 0 R] 36 0 obj The HHI increases both as the number of firms in the market decreases and as the disparity in size between those firms increases. /CropBox [0 0 612 792] % hUN@h/%FT""Qy@Kbxw81FgfvEN.tF2AiP9?{"1zQ. << For a number of reasons, landfills may not be located close to where the waste is generated. /MediaBox [0 0 612 792] /Parent 7 0 R /Parent 12 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. /Resources 281 0 R /Contents [114 0 R 115 0 R 116 0 R] There are no good substitutes for MSW disposal. ( /Annots [] /Kids [85 0 R 86 0 R 87 0 R 88 0 R 89 0 R 90 0 R 91 0 R 92 0 R 93 0 R] endobj The United States Army Corps of Engineers ("Corps" or "Army Corps") has unlawfully approved a massive dredging project for Port Everglades in Fort Lauderdale, Florida. /CropBox [0 0 612 792] The operator continues along the route, collecting MSW from each of the commercial accounts until the vehicle is full. /CropBox [0 0 612 792] %PDF-1.6 /Parent 9 0 R /Rotate 0 On September 8, 2021, the Court, by consent, entered a preliminary injunction against Garcia. .+p>hPhb4yiK=c`/XOv@|fe`iY 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. << << 0000001275 00000 n In each of these markets, Allied and Republic each account for a substantial share of total revenues from commercial waste collection services. endobj /Contents [390 0 R 391 0 R 392 0 R] Z( Virtually all of the MSW generated in each of these areas is disposed of in transfer stations in each of their local areas. 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). >> << /Parent 8 0 R /CropBox [0 0 612 792] stores and restaurants). /Type /Page /MediaBox [0 0 612 792] endobj /Resources 213 0 R ( /CropBox [0 0 612 792] endobj Defendant is defined as a "Public Accommodation" within meaning of Title III In 1998, for example, these three transfer stations disposed of over 85 percent of the MSW generated in the Anderson, IN area. /Type /Page /Rotate 0 /Resources 377 0 R /Contents [354 0 R 355 0 R 356 0 R] Plaintiff, PRISON LEGAL NEWS ("PLN"), a project of the Human Rights Defense . /CropBox [0 0 612 792] The length of the presentation is 46:09. 61 0 obj Thus, small container commercial 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. 33. Does the injunction provide broad or limited relief? 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. /MediaBox [0 0 612 792] 95 0 obj /CropBox [0 0 612 792] /MediaBox [0 0 612 792] /Type /Page /Parent 4 0 R and Florida Statute 86.011, et seq. US District Court for the Southern District of Florida: Presiding Judge: Raag Singhal: Nature of Suit: Trademark: Cause of Action: 15 U.S.C. 87 0 obj "Norfolk, VA area" means the cities of Chesapeake, Suffolk, Virginia Beach, Norfolk, Poquoson, Newport News and Portsmouth, and York, Surry, James City, Southampton, and Isle of Wight counties, Virginia. /Contents [234 0 R 235 0 R 236 0 R] /Annots [] 76 0 obj <> endobj /CropBox [0 0 612 792] 6th Street Ft. Lauderdale, FL 33301 Defendants. /Resources 393 0 R stream /Type /Metadata /MediaBox [0 0 612 792] 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. CASE NO. >> /Resources 277 0 R <> >> << /Annots [] /MediaBox [0 0 612 792] 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. /Parent 13 0 R 74 0 obj What impact will it have on third-parties and employees? endobj The President of the United States and the Governor of Florida have each declared a state of emergency. /MediaBox [0 0 612 792] endobj 0000003645 00000 n /Annots [] ( >> >> 27. Preference Primary election in Florida. /MediaBox [0 0 612 792] A party seeking an injunction under general Florida case law must demonstrate: 1) irreparable harm; 2) a clear legal right; 3) an inadequate . /MediaBox [0 0 612 792] 41 0 obj /Contents [282 0 R 283 0 R 284 0 R] The cost of transporting waste to a disposal site is often a substantial component of the cost of disposal. /Contents [122 0 R 123 0 R 124 0 R] Very often courts do not grant injunctions if there is not a lot of specificity and practicality in the request for an injunction. /Type /Page IV. After the acquisition, Allied would control over 50 percent--and two firms more than 90 percent-- of the small container commercial waste hauling market, which has annual revenues of about $10 million. /MediaBox [0 0 612 792] /Contents [230 0 R 231 0 R 232 0 R] For instance, in many states, most MSW is disposed of in landfills, which are permitted under and regulated by the state. 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. /Rotate 0 /Type /Page /Resources 301 0 R << /Parent 9 0 R C. Reduction in Competition As a Consequence of the Acquisition. /Type /Page stream JURISDICTION AND VENUE 2. /CropBox [0 0 612 792] endobj 40 0 obj >> 49. /Contents [286 0 R 287 0 R 288 0 R] That plaintiff receive such other and further relief as the case requires and the Court deems proper; and. Republic would thus be in a position to raise the disposal costs at the landfill and transfer stations which it would own to any new or existing roll-off collection competitor in the Macon, GA area. 34 0 obj endobj _______/s/____________________ Donna E. Patterson Deputy Assistant Attorney General, _________/s/__________________ Constance K. Robinson Director of Operations and Merger Enforcement, ________/s/___________________ J. Robert Kramer II Chief, Litigation II Section, _________/s/__________________ Willie L. Hudgins Assistant Chief, Litigation II Section, ___________/s/________________ Arthur A. Feiveson IL Bar # 3125793, __________/s/_________________ Michael K. Hammaker DC Bar # 233684, __________/s/_________________ Chinita M. Sinkler MD Bar, U.S. Department of Justice Antitrust Division, Litigation II Section 1401 H Street, NW, Suite 3000 Washington, D.C. 20530 (202) 307-0924. After the acquisition, Republic would control over 50 percent--and two firms over 80 percent-- of the small container commercial waste hauling market, which has annual revenues of about $29 million. >> 20 0 obj /Nums [0 6 0 R] /Parent 9 0 R 94 0 obj This is a must-watch video before you consider whether to sue for injunction. 3 0 obj << Roll-off vehicles have no compaction system on board and are designed to carry only one large container at a time to a disposal site. << The City changed its name from "New >> 38 0 obj hbbd``b`@q=`v0012,I00"0 endstream endobj startxref 0 %%EOF 33 0 obj <>stream 68. 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. 0000003868 00000 n /CropBox [0 0 612 792] /Annots [] Absent injunctive relief by this Court, Defendants are likely to continue to injure consumers, reap unjust enrichment, and harm the public interest. /CropBox [0 0 612 792] 9 0 obj /MediaBox [0 0 612 792] /Resources 353 0 R /CreationDate (D:20220824140929-04'00') /Contents [334 0 R 335 0 R 336 0 R] << /Rotate 0 /Type /Pages See Merger Guidelines 1.51. Access to competitive disposal sites and reasonable disposal costs are important to providers of roll-off collection services. "Louisville, KY/ Sellersburg, IN area" means the cities of Louisville, Kentucky and Sellersburg, Indiana; Jefferson County, Kentucky; and the parts of Floyd and Clark counties, Indiana abutting Jefferson County, Kentucky. 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 [254 0 R 255 0 R 256 0 R] Page 3 of 15 7. endobj << /Count 10 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 haulers, therefore, generally establish garages and related facilities within each major local area served. /Resources 225 0 R /Annots [] Permit restrictions often impose severe limitations on the type and amount of waste that can be disposed of at landfills. /CropBox [0 0 612 792] /Resources 313 0 R /Type /Page As such, following the process to the tee will help improve your chances for success. In the Columbus, OH area, the proposed acquisition would reduce from four to three the number of significant firms that compete in the collection of small container commercial waste. << /Subtype /XML 0000001641 00000 n "Macon, GA area" means the City of Macon and Bibb, Peach and parts of Houston, Jones and Monroe counties, Georgia. /MediaBox [0 0 612 792] /Annots [] 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. >> 4. endobj /MediaBox [0 0 612 792] 17 0 obj /Rotate 0 endobj 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. /Rotate 0 endobj /Rotate 0 In 1999, Allied reported total revenues of approximately $6 billion. /Annots [] Federal, state and local safety, environmental, zoning, and permit laws and regulations dictate critical aspects of storage, handling, transportation, processing and disposal of MSW. Republic is a Delaware corporation with its principal office in Ft. Lauderdale, Florida. /CropBox [0 0 612 792] 35 0 obj 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. endobj /Type /Page >> 67 0 obj SOUTHERN DISTRICT OF FLORIDA . /Count 10 >> << Allied and Republic are two of only a few providers of waste collection or disposal services in each of the identified areas. 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. /Annots [] /Rotate 0 /Parent 13 0 R Republic is engaged in providing waste collection and disposal services throughout the United States. DECLARATORY AND INJUNCTIVE RELIEF* * Pursuant to Rule 15(a)(2), Florida files the Second Amended Complaint with the written consent of Defendants. /Parent 9 0 R /MediaBox [0 0 612 792] /Contents [378 0 R 379 0 R 380 0 R] endobj The proposed acquisition would reduce from four to three the number of significant firms that compete in small container commercial waste collection service in the Memphis, TN area. It is engaged in providing waste collection and disposal services throughout the United States. ( << /Type /Page << 89 0 obj 0000001469 00000 n Suitable landfills are difficult and time-consuming to obtain, and sometimes difficult to expand, because of the scarcity of suitable land, local resident opposition, environmental concerns, and government regulation. x1 04) F&`/MFWxC. x+ | 0000001373 00000 n /Annots [] hbbd`b`rfb`gb` # A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. /Resources 165 0 R /Annots [] The acquisitions by Allied and Republic would remove a significant competitor in small container commercial waste collection service, roll-off waste collection service, and/or the disposal of MSW, in already highly concentrated and difficult-to-enter markets. /Annots [] /Pages 4 0 R 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. /Resources 357 0 R /Parent 8 0 R endobj >> Because of the differences in the collection process, residential customers and commercial customers usually are organized into separate routes. MSW has physical characteristics that readily distinguish it from other liquid or solid waste. 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. Florida has reported 149 confirmed cases of COVID-19 and four deaths to date, with every expectation that these numbers will rise. /Annots [] /Rotate 0 /MediaBox [0 0 612 792] /Type /Page /Rotate 0 /Contents [250 0 R 251 0 R 252 0 R] /Resources 349 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. endobj However, the incumbents' use of price discrimination and long-term contracts prevents new entrants from winning a large enough base of customers to achieve efficient routes in sufficient time to constrain the post-acquisition firm from significantly raising prices after the transaction. Therefore, you should ask yourself these questions before proceeding: So, you answered the questions above, and you consider this to be the best approach to resolving your matter. In these markets, Allied and Republic each account for a substantial share of MSW disposal capacity. /Type /Page /Rotate 0 0000001994 00000 n /Type /Page >> Waiver recipients are entitled to continuation of services that they are currently receiving through the completion of the fair hearing /Contents [278 0 R 279 0 R 280 0 R] These differences mean that small container commercial waste collection firms can profitably increase their charges for small container commercial waste collection services without losing significant sales or revenues to firms engaged in the provision of other types of waste collection services. 15 0 obj /MediaBox [0 0 612 792] For example, for a market consisting of four firms with shares of thirty, thirty, twenty, and twenty percent, the HHI is 2600 (302 + 302 + 202 + 202 = 2600). /Annots [] ( /MediaBox [0 0 612 792] /CropBox [0 0 612 792] /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] However, temporary injunctive relief may be granted without the posting of a bond in the following situations: 1) injunctions entered "on the pleading of a municipality or the state or any officer, agency, or political subdivision thereof"; or 2) injunctions "issued solely to prevent physical injury or abuse of a natural person." endobj ( /Rotate 0 After the acquisition, Allied would control over 40 percent--and two firms would control over 80 percent--of the small container commercial waste hauling market, which has annual revenues of about $8 million. 4. /CropBox [0 0 612 792] 53(b), empowers this Court to grant injunctive and such other relief as the Court may deem appropriate to halt /CropBox [0 0 612 792] 56. /Resources 193 0 R /Rotate 0 /Annots [] 4 0 obj /Parent 8 0 R To handle this high volume of MSW efficiently, haulers provide commercial customers with small dumpsters for storing the waste. << >> >> /Type /Page /Rotate 0 /Type /Pages /Resources 321 0 R "Memphis, TN area" means Shelby County, Tennessee; Desoto County, Mississippi, and Crittenden County, Arkansas. /Contents [158 0 R 159 0 R 160 0 R] 6. 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. << The front-end load containers used by small container commercial collection customers cannot be serviced by roll-off trucks. /Type /Page /Parent 10 0 R << << /Contents [310 0 R 311 0 R 312 0 R] /CropBox [0 0 612 792] /CropBox [0 0 612 792] endobj /Annots [] /Annots [] 11. >> endobj /Count 10 /Resources 205 0 R /Resources 221 0 R After the acquisition, Republic would control over 60 percent of the roll-off hauling market, which has annual revenues of about $8 million. stream /Resources 409 0 R /Annots [] /Resources 97 0 R Rather, its about dealing with the future, not something that happened in the past. /Parent 9 0 R 7. ( Should you request a temporary injunction or push quickly for final permanent injunction. ( endobj /Rotate 0 /Annots [] /Type /Page "Burlington and Camden Counties, NJ area" means Burlington and Camden counties, New Jersey. 0000006259 00000 n D. Entry Into Commercial Waste Collection of MSW. << In contrast to a commercial collection route, a residential waste collection route is significantly more labor intensive. /Rotate 0 There may be disclosure of confidential information such as trade secrets. >> >> Complaint for Declaratory and Temporary and Permanent Injunctive Relief (the "Complaint"), which is incorporated herein by this reference.1 As shown in the Complaint, the HRO is null and void for failure to comply with Florida Statutes, the Jacksonville Ordinance Code, and the Rules of the Council of the City of Jacksonville.