/Rotate 0 2320 0 obj<> endobj /Rotate 0 /Resources 329 0 R 65 0 obj endobj /Count 10 Therefore, its important to not consider it a tool for righting a wrong. << /Parent 8 0 R /MediaBox [0 0 612 792] /Type /Page /Annots [] << $4%&'()*56789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz r! 0000003946 00000 n /Annots [] 3. 7.) /Count 79 0000002992 00000 n /Type /Page >> Plaintiff, PRISON LEGAL NEWS ("PLN"), a project of the Human Rights Defense . Allied and Republic directly compete in roll-off waste collection service in a number of markets nationwide, including the Macon, GA area. In the Macon, GA area, the acquisition would also combine the two largest firms that compete in roll-off waste collection service. /Type /Page /MediaBox [0 0 612 792] 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. /Rotate 0 >> >> /MediaBox [0 0 612 792] << >> 0000006750 00000 n For a number of reasons, landfills may not be located close to where the waste is generated. 17 0 obj /Resources 341 0 R This is an action for injunctive relief. An individual commercial customer typically generates substantially more MSW than a residential customer. /MediaBox [0 0 612 792] << >> /Contents [354 0 R 355 0 R 356 0 R] >> ( endobj >> 6. /CropBox [0 0 612 792] 20. Filing fees are due at the time a party files a pleading to initiate a proceeding or files a pleading for relief. /Rotate 0 /Resources 105 0 R /MediaBox [0 0 612 792] 0000000556 00000 n /MediaBox [0 0 612 792] /CropBox [0 0 612 792] /Title (Microsoft Word - 2022-08-24 - Complaint - FINAL) >> 0000003404 00000 n /Annots [] << Plaintiff seeks temporary, preliminary, and permanent injunctive relief pursuant to Rule 65 . /Resources 269 0 R 0000003868 00000 n >> /CropBox [0 0 612 792] /Annots [] PDF IN THE CIRCUIT COURT OF THE SECOND JUDICIAL - Florida Carry, Inc. endobj /Resources 389 0 R 10. In re Amendments to Florida Small Claims Rules, 123 So.3d 41 (Fla . VERIFIED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF Introduction 1. /Resources 361 0 R The county court may issue a temporary and permanent injunction where appropriate for violation of ss. The HHI increases both as the number of firms in the market decreases and as the disparity in size between those firms increases. Plaintiff, The Second Amendment Foundation, is a Washington Not-For-Profit Complaint for Emergency Injunctive Relief in Florida Primary /Annots [] "Gulf Coast, FL area" means Escambia, Santa Rosa, and Okaloosa counties, Florida. A new entrant into small container commercial waste collection service cannot provide a significant competitive constraint on the prices charged by market incumbents until it achieves minimum efficient scale and operating efficiencies comparable to existing firms. 39 0 obj /Annots [] /Parent 8 0 R /CropBox [0 0 612 792] 34. "Small container commercial waste collection service" means the business of collecting MSW from commercial and industrial accounts, usually in "dumpsters" (i.e., a small container with one to ten cubic yards of storage capacity), and transporting or "hauling" such waste to a disposal site by use of a front-or rear-end loader truck. >> The roll-off container, when filled, is picked up by roll-off trucks, which are uniquely well suited for roll-off waste collection, and driven to a nearby disposal site, where the container's contents are disposed. /Rotate 0 >> /Parent 11 0 R PDF In the Supreme Court of Florida Case No.: Sc11- Third District Case No 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] 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 $5 million. >> (ECF No. /CropBox [0 0 612 792] >> 3. /Resources 137 0 R % /Parent 11 0 R The significant share of the roll-off collection market which Republic would have, its control of the primary disposal sites in the area, and its frequent use of long-term, automatically renewing contracts with roll-off collection customers, would make entry into the Macon, GA roll-off waste collection market difficult, and unlikely to prevent market incumbents from significantly raising prices for the collection of roll-off waste following the acquisition. Plaintiff complains and alleges as follows: 1. This is an action for permanent injunctive relief, declaratory relief, and #%$""!&+7/&)4)! Complaint for Emergency Injunctive Relief in Florida Primary The global coronavirus pandemic threatens to disrupt the Presidential Preference Primary election in Florida. xYYoH~7"b` recB$hHjRbK6DQ]]WUMb8`}^^l,q8x1O,7~`[)gD,uq+sU+PP)>f90VY-^AEKS2t}g4 X!xH rTmvF4(,W`{kF$tC /MediaBox [0 0 612 792] clearly appears from specific facts shown by affidavit or by verified complaint that immediate or /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] /Type /Pages /Resources 385 0 R 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. /Contents [106 0 R 107 0 R 108 0 R] endobj >> Is the injunction prohibitory or mandatory? /CropBox [0 0 612 792] JFIF C /MediaBox [0 0 612 792] Allied is the nation's second largest waste hauling and disposal company. IV. /Annots [] /MediaBox [0 0 612 792] << /Parent 12 0 R h|VrH}Weo2)RXBr|:=%ts?mlteQG :C:+rl86#m0GcfFmMb`4&;|Xy|^Q(&Y Jf#mb!nDlpfIi QB*Mg< /MediaBox [0 0 612 792] /Type /Page PDF Verified Complaint for Declaratory and Injunctive Relief /Resources 121 0 R endobj /Annots [] 21 0 obj 0000006259 00000 n /Resources 201 0 R /Parent 4 0 R Complaint for Injunctive Relief and Civil Penalties (pdf) (1.93 MB) Contact Us to ask a question, provide feedback, or report a problem. endobj /Parent 10 0 R /Contents [230 0 R 231 0 R 232 0 R] 0 60 0 obj 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. not /Resources 181 0 R << /Kids [65 0 R 66 0 R 67 0 R 68 0 R 69 0 R 70 0 R 71 0 R 72 0 R 73 0 R 74 0 R] << 46 0 obj /Parent 11 0 R /Rotate 0 /Parent 13 0 R /Type /Page 69. endobj /CropBox [0 0 612 792] /Resources 373 0 R ( 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. endobj /Parent 4 0 R /Annots [] /Resources 397 0 R /MediaBox [0 0 612 792] The cost of transporting waste to a disposal site is often a substantial component of the cost of disposal. 50 0 obj /CropBox [0 0 612 792] 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. 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. /Rotate 0 See Laws of Florida, Ch. /CropBox [0 0 612 792] /Type /Page << /Rotate 0 ( >> WEST PALM BEACH DIVISION . Judgment for Permanent Injunctive Relief against MJ Taxes on October 1, 2021. /Resources 141 0 R "Clarksville, TN area" means the City of Clarksville and Montgomery, Dickson, the northwestern part of Cheatham, and the western part of Robertson counties, Tennessee. A complaint for declaratory relief must allege the following: there is a bona fide dispute between the parties; the plaintiff has a justiciable question as to the existence or nonexistence of some right, status, immunity, power or privilege, or as to some fact upon which existence of such a claim may depend; 32. /MediaBox [0 0 612 792] /Contents [154 0 R 155 0 R 156 0 R] 38 0 obj << << /Contents [350 0 R 351 0 R 352 0 R] 0000001317 00000 n 25. /Resources 197 0 R Plaintiff also contends that the harm suffered as a result of defendant's conduct is irreparable in nature and cannot be measured solely in terms of monetary damages. 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. /Annots [] /Rotate 0 /CropBox [0 0 612 792] Absent injunctive relief by this Court, Defendants are likely to continue to injure consumers, reap unjust enrichment, and harm the public interest. endobj endobj /Annots [] 94 0 obj 49 0 obj MSW has physical characteristics that readily distinguish it from other liquid or solid waste. %PDF-1.6 JacqmeinV "Burlington and Camden Counties, NJ area" means Burlington and Camden counties, New Jersey. /Rotate 0 /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] /Annots [] << /Resources 265 0 R /Parent 8 0 R /Resources 161 0 R 0000001373 00000 n 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. << /Resources 369 0 R As such, following the process to the tee will help improve your chances for success. /MediaBox [0 0 612 792] /Contents [382 0 R 383 0 R 384 0 R] To access the presentation, visit YouTube or click play on the embedded image below. /Parent 13 0 R /MediaBox [0 0 612 792] /Annots [] /Parent 12 0 R /MediaBox [0 0 612 792] /Annots [] The extension ofvote-by-mail options and other accommodations at polling places is necessary. "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 [206 0 R 207 0 R 208 0 R] 45 0 obj 72 0 obj ( 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. /Type /Page << ( /Rotate 0 /MediaBox [0 0 612 792] endobj Venue is proper in the Circuit Court of the Seventh Judicial Circuit, in and for 89 0 obj /MediaBox [0 0 612 792] 51 0 obj This is a civil action brought by the United States of America to enjoin defendant . 22 and 28 U.S.C. /Contents [314 0 R 315 0 R 316 0 R] Complaint for Injunctive Relief | ATR | Department of Justice 56 0 obj /Rotate 0 << endobj 0 83.40 et seq. <<21a9e19eaa9d774d8bfb9315a3d3f5db>]>> >> << 47. 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. 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] /Parent 11 0 R 1391, . 7 0 obj Florida has reported 149 confirmed cases of COVID-19 and four deaths to date, with every expectation that these numbers will rise. for the Middle Distrct of Florida, hereby files this complaint for permanent injunction and alleges as follows: 1. /MediaBox [0 0 612 792] /Type /Page 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. 95 0 obj endobj 67 0 obj >> << /Type /Page See Merger Guidelines 1.51. /MediaBox [0 0 612 792] Omega SA v. The Individuals, Business Entities, and Unincorporated INTRODUCTION . << 28 0 obj << /CropBox [0 0 612 792] /CropBox [0 0 612 792] xref /Annots [] /Rotate 0 /MediaBox [0 0 612 792] 41. Permit restrictions often impose severe limitations on the type and amount of waste that can be disposed of at landfills. /MediaBox [0 0 612 792] /CropBox [0 0 612 792] 42 0 obj 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. /Type /Page 92 0 obj THIS COURT'S POWER TO GRANT RELIEF 84. provide preliminary and permanent injunctive relief pursuant to Rules 57 and 64 of the Federal Rules of Civil Procedure and 28 U.S.C. /Rotate 0 76 0 obj endobj ( >> << The City changed its name from "New 19. /Annots [] << endobj /Annots [] /Contents [250 0 R 251 0 R 252 0 R] /CropBox [0 0 612 792] - All Rights Reserved, Community Advocacy & Social Responsibility, Traditional Contract Principles Impacting Enforcement of Noncompete Agreements in Florida. ( ? 70 0 obj /Rotate 0 1 1 On February 7, 2023 and February 16, 2023, Plaintiff filed motions for preliminary 2 injunctive relief. /CropBox [0 0 612 792] The global coronavirus pandemic threatens to disrupt the Presidential /Resources 285 0 R endobj This is a lawsuit for declaratory and injunctive relief under 86.011, Fla. Stat. /Contents [290 0 R 291 0 R 292 0 R] Alexdex. C. Reduction in Competition As a Consequence of the Acquisition. /Contents [342 0 R 343 0 R 344 0 R] endobj /Type /Page /CropBox [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. /Type /Page /Annots [] 66. /MediaBox [0 0 612 792] /Annots [] /Contents [202 0 R 203 0 R 204 0 R] /CropBox [0 0 612 792] 41 0 obj /Resources 229 0 R /Rotate 0 /Contents [170 0 R 171 0 R 172 0 R] /Type /Page /CreationDate (D:20220824140929-04'00') ( /MediaBox [0 0 612 792] >> 57 0 obj 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. 0000000817 00000 n 46. /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. 40. (ECF No. /Type /Page /Resources 149 0 R ;("(;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;; << endobj /Resources 345 0 R /Kids [25 0 R 26 0 R 27 0 R 28 0 R 29 0 R 30 0 R 31 0 R 32 0 R 33 0 R 34 0 R] 73 0 obj /Kids [45 0 R 46 0 R 47 0 R 48 0 R 49 0 R 50 0 R 51 0 R 52 0 R 53 0 R 54 0 R] 22 and 28 U.S.C. Accordingly, injunctive relief ordering the extension of vote-by-mail options and other accommodations at polling places is necessary to protect the fundamental right to vote. /Contents [398 0 R 399 0 R 400 0 R] /MediaBox [0 0 612 792] << 0000001149 00000 n /Resources 313 0 R 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. /Type /Page /MediaBox [0 0 612 792] /Parent 13 0 R 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. >> The extension of vote-by-mail options and other accommodations at polling places is necessary. endobj 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. /Type /Page 42. /Contents [294 0 R 295 0 R 296 0 R] /CropBox [0 0 612 792] /MediaBox [0 0 612 792] The next step is careful preparation before the temporary injunction hearing. /Type /Page ( /Parent 12 0 R 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. << /CropBox [0 0 612 792] endobj /Annots [] In 1999, Allied reported total revenues of approximately $6 billion. endobj /CropBox [0 0 612 792] /Type /Page 0000001641 00000 n "Transfer station" means an intermediate disposal site, often used in more densely populated areas, for the processing and temporary storage of solid waste before transfer, in bulk, to more distant facilities for final disposal. endobj << /Contents [126 0 R 127 0 R 128 0 R] (PC) Carroll v. Vallejo Police Department, et al., No. 1:2023cv00004 endobj endobj /Annots [] /Rotate 0 /Contents [222 0 R 223 0 R 224 0 R] /Parent 10 0 R /CropBox [0 0 612 792] 25, to prevent and restrain the violation by defendants of Section 7 of the Clayton Act, 15 U.S.C. >> Download the PDF of the Complaint IN THIS PUBLICATION Summary Issues COVID-19 << %PDF-1.5 48 0 obj /Type /Page >> 33 0 obj /Rotate 0 /Annots [] 85 0 obj /MediaBox [0 0 612 792] /Resources 409 0 R On August 20, . /Type /Catalog /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. "Nashville, TN area" means the City of Nashville and Davidson, Sumner, Williamson, Rutherford, Wilson, the southeastern part of Robertson, and the eastern part of Cheatham counties, Tennessee. 8 0 obj 0000001275 00000 n On February 10, 2023, the Court screened the 27 First Amended Complaint and dismissed it for failure to state a claim, with leave to amend within 28 thirty days. /CropBox [0 0 612 792] 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. << <<14CA263718F8354CB34DA495C0495A29>]>> /Annots [] /Rotate 0 /Resources 173 0 R Plaintiffs Rural & Migrant Ministry, Alianza Nacional De Campesinas, El Comite . "Augusta, GA area" means the City of Augusta, Richmond and Columbia counties, Georgia, and Aiken County, South Carolina. _l {:\! 16 0 obj /Annots [] This is a must-watch video before you consider whether to sue for injunction. Garcia is a resident of North Lauderdale, Fl orida. 5. 79 0 obj >> /CropBox [0 0 612 792] /CropBox [0 0 612 792] /Resources 205 0 R 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. Allied is a Delaware corporation with its principal office in Scottsdale, Arizona. The acquisition would reduce from three to two the number of significant firms that compete in the collection of small container commercial waste in the Burlington and Camden Counties, NJ area. /Annots [] /Type /Page >> /Type /Page /Rotate 0 Complaint for Declaratory Relief in Florida - Trellis << 37. >> 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. 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. /Parent 4 0 R /Type /Page >> Small Container Commercial Waste Collection Service. /Resources 157 0 R /Parent 10 0 R The United States is entitled to injunctive relief under 26 U.S.C. <>>> /Contents [166 0 R 167 0 R 168 0 R] >> /Type /Pages 4 0 obj /Resources 101 0 R 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. 15 0 obj The cost advantage of local landfills limits the areas where MSW can be economically transported and disposed of by haulers and creates localized markets for MSW disposal services. /Count 10 /Rotate 0 /Resources 393 0 R Charles B. Jimerson PDF Complaint for Injunctive and Other Relief and Demand for Jury Trial I 6th Street Ft. Lauderdale, FL 33301 Defendants. /Rotate 0 /Type /Pages >> MSW landfills can only accept waste up to their permitted daily capacity and have a finite life span. For instance, in many states, most MSW is disposed of in landfills, which are permitted under and regulated by the state. endobj In contrast to a commercial collection route, a residential waste collection route is significantly more labor intensive. %%EOF /Type /Page << Filing 1 COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. startxref In the United States District Court for The Southern District of New York /Contents [310 0 R 311 0 R 312 0 R] 25 0 obj endobj /MediaBox [0 0 612 792] 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. /Parent 14 0 R /Parent 14 0 R /Contents [262 0 R 263 0 R 264 0 R] << << /Rotate 0 GsYzQh50ee' /Contents [374 0 R 375 0 R 376 0 R] endobj Defendant is defined as a "Public Accommodation" within meaning of Title III endobj /Resources 337 0 R /Rotate 0 IV. /Rotate 0 endobj /Rotate 0 7. 52 0 obj "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. << << /Length 1411 << 0000003645 00000 n This form is a Complaint for Injunctive Relief and Damages. This action arises under Chapter 713 and 720, Florida Statutes, and under the Fair Housing Act of 1968, as amended, 42 U.S.C. APPROPRIATENESS OF INJUNCTIVE RELIEF 26 . 2322 0 obj<>stream /Contents [286 0 R 287 0 R 288 0 R] 13 0 obj ( /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] >> /Contents [298 0 R 299 0 R 300 0 R] /Rotate 0 /MediaBox [0 0 612 792] /Contents [274 0 R 275 0 R 276 0 R] /Resources 209 0 R << /Parent 8 0 R /MediaBox [0 0 612 792] /CropBox [0 0 612 792] ( hUN@h/%FT""Qy@Kbxw81FgfvEN.tF2AiP9?{"1zQ. PDF Complaint for Permanent Injunction and Other Equitable Relief /Annots [] Contains legal complaint for injunctive releif and civil penalties against BCX facility Site, Jacksonville, Duval County, Florida, June 7, 2004. endobj /MediaBox [0 0 612 792] 86 0 obj 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 [406 0 R 407 0 R 408 0 R] /Contents [366 0 R 367 0 R 368 0 R] 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. /Contents [178 0 R 179 0 R 180 0 R] /Rotate 0 /Resources 177 0 R /Author (JacqmeinV) Garcia controll ed the MJ Companies prior to their going into receivership. Rather, its about dealing with the future, not something that happened in the past. /Count 9 endobj x1 04) F&`/MFWxC. /Contents [234 0 R 235 0 R 236 0 R] /Type /Pages Reopen fees are due at the time a party files a pleading to reopen a proceeding if at least 90 days have . endstream endobj 29 0 obj <>stream /Annots [] 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. >> 1 0 obj >> /Type /Page The operator continues along the route, collecting MSW from each of the commercial accounts until the vehicle is full. /Resources 381 0 R On July 28 and October 7, 1999, in twelve (12) separate purchase agreements, defendants agreed to exchange assets of various subsidiary companies ('the acquisitions"). /Contents [190 0 R 191 0 R 192 0 R] << /Rotate 0 /Rotate 0 ( 51. >> /Rotate 0 0000002235 00000 n Last updated on November 21, 2022.