complaint for injunctive relief florida

Finally, prices for small container service are influenced principally by the density of the routes served by each vehicle; prices for roll-off services are influenced primarily by the distance of the customer's location from the hauler's location and the disposal site, the time required to travel those distances, and the cost of disposal at the disposal site. stream 3. 3 0 obj 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; hear the plaintiff's claim for declaratory and injunctive relief because the plaintiff alleged an amount in controversy in excess of $15,000; which obviously, is due to the fact that . 31 0 obj << /Parent 12 0 R /Contents [202 0 R 203 0 R 204 0 R] x1 04) F&`/MFWxC. /Annots [] endstream endobj 29 0 obj <>stream /Annots [] 53(b), empowers this Court to grant injunctive and such other relief as the Court may deem appropriate to halt /Rotate 0 /Resources 177 0 R << Reopen fees are due at the time a party files a pleading to reopen a proceeding if at least 90 days have . 24. Is the injunction prohibitory or mandatory? /Annots [] /Parent 11 0 R /Contents [282 0 R 283 0 R 284 0 R] /Type /Page 1391(c). ( %PDF-1.3 % /Parent 13 0 R /Resources 333 0 R 21-81099-CIV-CANNON/Reinhart . /Resources 209 0 R /Contents [198 0 R 199 0 R 200 0 R] ( /CropBox [0 0 612 792] /Parent 9 0 R /Annots [] 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. /Resources 221 0 R The cost of transporting waste to a disposal site is often a substantial component of the cost of disposal. 0000001994 00000 n 50 0 obj endobj /Annots [] >> /Parent 10 0 R /Rotate 0 /Rotate 0 /Contents [134 0 R 135 0 R 136 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. 52. /Metadata 2 0 R /Count 10 /Annots [] >> 0000000556 00000 n 9 0 obj /Rotate 0 /Parent 13 0 R << /Resources 293 0 R >> xref << ( 14 0 obj /Contents [150 0 R 151 0 R 152 0 R] 69. 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] Garcia controll ed the MJ Companies prior to their going into receivership. Defendant is defined as a "Public Accommodation" within meaning of Title III M`5`i`F{qZ /Parent 7 0 R 2. >> /Parent 12 0 R /Parent 9 0 R 76 0 obj <> endobj endobj >> /Type /Page /Annots [] >> /Count 10 endobj >> It is engaged in providing waste collection and disposal services throughout the United States. ( "Albany, NY area" means the City of Albany and Albany, Schenectady, Saratoga, and Rensselaer counties, New York. judgment, and preliminary and permanent injunctive relief and damages. /Contents [262 0 R 263 0 R 264 0 R] /Rotate 0 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 /Rotate 0 /Type /Page /Parent 8 0 R /Parent 8 0 R << ( /Parent 10 0 R 83.40 et seq. /Annots [] /Resources 249 0 R /Type /Page That plaintiff recover the costs of this action. Complaint for purposes of Florida Statutes Sections 501.207(5) and 95.11(3). PLAINTIFF'S COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF . See Merger Guidelines 1.51. ( /Parent 11 0 R /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] In addition to differences in container size, other factors distinguish roll-off waste collection from small container commercial and other types of waste collection. JFIF C "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. 1114 Trademark Infringement . /CropBox [0 0 612 792] <<21a9e19eaa9d774d8bfb9315a3d3f5db>]>> advance, Plaintiffs seek immediate declaratory and injunctive relief that directs Defendants to permit a designated representative of each affected candidate and political party into the recount room, as Florida law requires. /CropBox [0 0 612 792] endobj 42 0 obj /Contents [318 0 R 319 0 R 320 0 R] /Rotate 0 xb```c``b`f`0gg@ ~G@|*{jd`q%T3e83:! @`HsXD|",e0`A 21. ( /Parent 7 0 R /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] ? 0000000016 00000 n /CropBox [0 0 612 792] endobj << /MediaBox [0 0 612 792] /Type /Page /Rotate 0 Otherwise, there may be something missed or an unintended consequence when you sue for injunction, which can can bring about dissatisfaction, regardless of who prevails. /Resources 185 0 R Therefore, the video continues on this topic by explaining: A suit for injunction is an extraordinary remedy for businesses and individuals alike. << Significant new entry into small container commercial waste collection service is difficult and time-consuming 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. "Burlington and Camden Counties, NJ area" means Burlington and Camden counties, New Jersey. 21 0 obj Official websites use .gov The proposed transactions, identified below, would lessen competition substantially in waste collection and/or disposal services: (1) Allied's acquisition of hauling assets in Albany, New York; (2) Allied's acquisition of hauling assets in Augusta, Georgia; (3) Allied's acquisition of hauling assets in Memphis, Nashville and Clarksville, Tennessee; (4) Allied's acquisition of disposal assets in New York, New York; (5) Allied's acquisition of hauling assets in Norfolk, Virginia; (6) Allied's acquisition of hauling assets in Okaloosa, Escambia and Santa Rosa counties, Florida ("Gulf Coast, Florida"); (7) Republic's acquisition of disposal assets in Anderson, Indiana; (8) Republic's acquisition of hauling assets in Columbus, Ohio; (9) Republic's acquisition of hauling assets in Lakeland, Florida; (10) Republic's acquisition of hauling assets in Louisville, Kentucky and Sellersburg, Indiana; (11) Republic's acquisition of hauling and disposal assets in Macon, Georgia; and (12) Republic's acquisition of hauling assets in Monmouth, Burlington and Camden counties, New Jersey. /Annots [] The extension ofvote-by-mail options and other accommodations at polling places is necessary. /Rotate 0 endobj 30 0 obj 58. /Resources 181 0 R /Annots [] There are immediate expenditures necessary. >> 23. prices charged by roll-off waste collection firms in the Macon, GA area market will likely increase. endobj /Type /Metadata >> /Parent 8 0 R endobj endobj /CropBox [0 0 612 792] /Contents [382 0 R 383 0 R 384 0 R] /CropBox [0 0 612 792] >> ( 1 0 obj Venue is proper in the Circuit Court of the Seventh Judicial Circuit, in and for << 3 0 obj 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. /Type /Page The Court has jurisdiction over this action and over the parties pursuant to 15 U.S.C. /MediaBox [0 0 612 792] endobj /Annots [] This is an action for injunctive relief. 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. /Annots [] 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. . /Resources 353 0 R The county court may issue a temporary and permanent injunction where appropriate for violation of ss. /Parent 13 0 R /Parent 4 0 R 11 0 obj /Contents [174 0 R 175 0 R 176 0 R] /MediaBox [0 0 612 792] /Resources 337 0 R /CropBox [0 0 612 792] << /Rotate 0 Defendants because the Amended Complaint seeks injunctive relief only for these Counts, to which qualified immunity does not apply. 10 0 obj >> 1391, . /Contents [342 0 R 343 0 R 344 0 R] 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. 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. /Rotate 0 /MediaBox [0 0 612 792] 19. /MediaBox [0 0 612 792] 10. /MediaBox [0 0 612 792] /Parent 4 0 R /Contents [186 0 R 187 0 R 188 0 R] 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. 38 0 obj /MediaBox [0 0 612 792] /CropBox [0 0 612 792] /CropBox [0 0 612 792] /Parent 11 0 R /Contents [354 0 R 355 0 R 356 0 R] Allied is the nation's second largest waste hauling and disposal company. >> ( 45 0 obj 22 and 28 U.S.C. Does the temporary injunction preserve the Status Quo or does it make a change? << << endobj /Annots [] >> /Annots [] endobj 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. 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. 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. /Resources 285 0 R /Rotate 0 /Resources 377 0 R /Contents [122 0 R 123 0 R 124 0 R] /CropBox [0 0 612 792] 17. 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. 58 0 obj Filing fees are due at the time a party files a pleading to initiate a proceeding or files a pleading for relief. ( /Contents [238 0 R 239 0 R 240 0 R] /Resources 361 0 R /Resources 133 0 R 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. The global coronavirus pandemic threatens to disrupt the Presidential /Resources 117 0 R >> << /Annots [] "HHI" means the Herfindahl-Hirschman Index, a commonly accepted measure of market concentration. Federal, state and local safety, environmental, zoning, and permit laws and regulations dictate critical aspects of storage, handling, transportation, processing and disposal of MSW. << /Type /Page /Resources 197 0 R >> /CropBox [0 0 612 792] /Contents [102 0 R 103 0 R 104 0 R] /CropBox [0 0 612 792] 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. Jurisdiction is conferred on this Court by Chapters 26, 34, 86.011. >> /CropBox [0 0 612 792] /Type /Page 2322 0 obj<>stream /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. endobj >> endobj Local public opposition often makes it more difficult and costly, and increases the time and uncertainty of successfully permitting a facility. << /Annots [] xb```b``Ig`a`X @1V hdc [`&&v/>4427pHG(Og|sW(7_HPpXp'Skgu`.8!B=\2+".b4dh fZ!WHW3`W+.eP9(tb1P,%pX1EaSO6I)1] K,cMpl q m D@,"R:7S&`u@6j(LjfLT[D1,BPf:9= P1!$Ippa8fHNtD {,nPY 5 48. /Resources 113 0 R 37 0 obj /Annots [] /Type /Page /Parent 9 0 R /Type /Pages /Annots [] endobj /MediaBox [0 0 612 792] 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. ( /Resources 389 0 R << Rule 1.610 of the Florida Rules of Civil Procedure governs requests for temporary injunctions. /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] Filing fees $ 402.00 receipt number AFLSDC-16386893, filed by OMEGA SA.. (Attachments: #1 . /Parent 8 0 R << /Rotate 0 Small Container Commercial Waste Collection Service. /Contents [210 0 R 211 0 R 212 0 R] In 1999, Allied reported total revenues of approximately $6 billion. 36 0 obj << >> 61. US District Court for the Southern District of Florida: Presiding Judge: Raag Singhal: Nature of Suit: Trademark: Cause of Action: 15 U.S.C. 68. "Clarksville, TN area" means the City of Clarksville and Montgomery, Dickson, the northwestern part of Cheatham, and the western part of Robertson counties, Tennessee. /Contents [398 0 R 399 0 R 400 0 R] D. Entry Into Commercial Waste Collection of MSW. /Type /Pages /Rotate 0 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. ( 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. >> In the New York City, NY area, the acquisition would reduce from five to four the number of significant firms competing to dispose of commercial MSW. 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 [378 0 R 379 0 R 380 0 R] As such, following the process to the tee will help improve your chances for success. /Annots [] 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. /Type /Page /Annots [] /MediaBox [0 0 612 792] << /Parent 14 0 R ( /Resources 149 0 R << /MediaBox [0 0 612 792] Waiver recipients are entitled to continuation of services that they are currently receiving through the completion of the fair hearing /Contents [118 0 R 119 0 R 120 0 R] endobj >> /Annots [] /Resources 397 0 R endstream endobj 2333 0 obj<>/W[1 1 1]/Type/XRef/Index[246 2074]>>stream /Resources 213 0 R /Type /Page /Rotate 0 18. /MediaBox [0 0 612 792] endobj /Parent 9 0 R IV. << 43. 8. After the acquisition, Republic would control over 50 percent--and two firms about 90 percent--of the small container commercial waste hauling market, which has annual revenues exceeding $22 million. /CropBox [0 0 612 792] This action is brought to endobj << endobj /Contents [178 0 R 179 0 R 180 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. Complaint for Injunctive Relief Case (s): U.S. v. Allied Waste Industries, Inc. and Republic Services, Inc. 76 13 /Annots [] ( endobj >> /Annots [] %PDF-1.6 << /Parent 12 0 R REPUBLIC SERVICES, INC., 110 S.E. /Rotate 0 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. << /Contents [98 0 R 99 0 R 100 0 R] 7. Charles B. Jimerson 12. /Annots [] /Rotate 0 45. /Parent 11 0 R /Contents [266 0 R 267 0 R 268 0 R] ( /Rotate 0 On residential routes, the crews generally hand-load the customer's MSW, typically by tossing garbage bags and emptying trash cans into the vehicle's storage section. /Rotate 0 K.A%aut\@Uaa[pVWnOe >> /Type /Page _______/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. /Type /Page /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] /Parent 9 0 R 15 0 obj /Parent 7 0 R Suing for an injunction in Florida is all about preserving the status quo. /Rotate 0 /Parent 14 0 R /MediaBox [0 0 612 792] >> /Rotate 0 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. >> /Type /Page << 32 0 obj /Rotate 0 "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. 0000003868 00000 n After the acquisition, Republic would control over 60 percent of the roll-off hauling market, which has annual revenues of about $8 million. 0000001563 00000 n 20. 50. endobj 71 0 obj /Type /Page >> /MediaBox [0 0 612 792] /Annots [] 75 0 obj >> 48 0 obj /Parent 7 0 R /Parent 13 0 R %PDF-1.5 /Annots [] : 01-42230-BKC-AJC . << For the Court's convenience, Florida has attached a redline, as Exhibit A, showing changes from the First Amended Complaint. /Type /Pages /Type /Pages /Contents [242 0 R 243 0 R 244 0 R] /Contents [142 0 R 143 0 R 144 0 R] /MediaBox [0 0 612 792] endobj startxref /Resources 137 0 R MSW is generally transported by collection trucks to landfills and transfer stations, and the availability of disposal sites close to a hauler's routes is a major element that determines a hauler's competitiveness and profitability. /Resources 109 0 R endobj << /Contents [146 0 R 147 0 R 148 0 R] /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] /Type /Page /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] endobj /Contents [194 0 R 195 0 R 196 0 R] endobj INTRODUCTION . 67. 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. "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. /Type /Page 84 0 obj 51 0 obj >> /Resources 369 0 R THIS COURT'S POWER TO GRANT RELIEF 84. /Annots [] /Type /Page 51. endobj For instance, in many states, most MSW is disposed of in landfills, which are permitted under and regulated by the state. /Annots [] /Type /Page /Type /Page 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. 77 0 obj /Parent 12 0 R /Contents [250 0 R 251 0 R 252 0 R] /Type /Page /Count 9 15. 0000001187 00000 n endobj 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] /MediaBox [0 0 612 792] /CropBox [0 0 612 792] endobj /CropBox [0 0 612 792] /Contents [274 0 R 275 0 R 276 0 R] This is a lawsuit for declaratory and injunctive relief under 86.011, Fla. Stat. endobj /Resources 173 0 R endobj /Contents [246 0 R 247 0 R 248 0 R] COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF . A .gov website belongs to an official government organization in the United States. /Parent 9 0 R /Annots [] 10941 and Laws of Florida, Ch. 94 0 obj 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. /Parent 11 0 R 22 0 obj /Annots [] /Type /Pages ;,hn \ic6rZFi+|:GsL$KGqzed8;M+"N7i~4Dr?_1hHa:`R[B%Qm*?u9Lh=?y%x8;e$AD+xx /Rotate 0 To handle this high volume of MSW efficiently, haulers provide commercial customers with small dumpsters for storing the waste. provide preliminary and permanent injunctive relief pursuant to Rules 57 and 64 of the Federal Rules of Civil Procedure and 28 U.S.C. 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. /Rotate 0 endobj /Contents [362 0 R 363 0 R 364 0 R] D. P. et al., . /CropBox [0 0 612 792] endobj << 80 0 obj >> It is economically impractical for a roll-off waste collection firm to serve metropolitan areas from a distant base. 0000001275 00000 n /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] 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. On September 8, 2021, the Court, by consent, entered a preliminary injunction against Garcia. 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). Filing 1 COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. /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] Small container commercial service vehicles routinely employ compaction systems on the truck to increase storage capacity, and can empty numerous small containers located on a scheduled route before being driven to a disposal site. ( /Annots [] /Type /Page endobj /Rotate 0 /Annots [] endobj /Contents [294 0 R 295 0 R 296 0 R] /CropBox [0 0 612 792] /Contents [306 0 R 307 0 R 308 0 R] endobj endobj endobj /Type /Page endobj /Parent 14 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. >> This Court has jurisdiction to enter declaratory and injunctive relief pursuant to Florida Statute 86.011 and Article V, 20 of the Florida Constitution. 93 0 obj << 0 1331 and 1337. >> 0000001852 00000 n /CropBox [0 0 612 792] 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 2201-202, and . /ModDate (D:20220824143048-04'00') /Parent 13 0 R /CropBox [0 0 612 792] /CropBox [0 0 612 792] endobj This is an action for permanent injunctive relief, declaratory relief, and /Resources 105 0 R SOUTHERN DISTRICT OF FLORIDA . This is a civil action brought by the United States of America to enjoin defendant . Often businesses do not consider the implications for taking this action. 25 0 obj >> >> The front-end load containers used by small container commercial collection customers cannot be serviced by roll-off trucks. 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. An MSW disposal facility must be located on approved types of land and operated under prescribed procedures. /Resources 373 0 R /Rotate 0 ( 14. ( 88 0 obj<>stream stores and restaurants). 62. 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. 43 0 obj 70 0 obj 57. /Resources 189 0 R >> /CropBox [0 0 612 792] /Resources 169 0 R >> 35 0 obj 44 0 obj /CropBox [0 0 612 792] 6th Street Ft. Lauderdale, FL 33301 Defendants.