/Resources 269 0 R PDF Motion for Summary Judgment - Liberty Counsel 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. Republic is engaged in providing waste collection and disposal services throughout the United States. /Contents [246 0 R 247 0 R 248 0 R] 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. << << 0000001563 00000 n 0000003404 00000 n >> /CropBox [0 0 612 792] /Type /Page 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. /Annots [] >> "0A149;>>>%.DIC; C /CropBox [0 0 612 792] >> 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. >> /CropBox [0 0 612 792] 0 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. 54 0 obj ( /Parent 7 0 R /Parent 10 0 R >> /Parent 13 0 R << /Title (Microsoft Word - 2022-08-24 - Complaint - FINAL) Injunctive relief is considered an extraordinary remedy in both State and Federal court. /Type /Page 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. 1 0 obj endobj /Type /Page 41 0 obj 60. . endobj It is economically impractical for a roll-off waste collection firm to serve metropolitan areas from a distant base. x+ | /Resources 401 0 R After the acquisition, Allied would control over 40 percent and two firms would control over 65 percent of the small container commercial waste hauling market, which has annual revenues of about $5 million. << 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. /Annots [] /Creator (PScript5.dll Version 5.2.2) JURISDICTION AND VENUE 13. /Parent 9 0 R endobj 2320 14 /Contents [258 0 R 259 0 R 260 0 R] x1 04) F&`/MFWxC. /Type /Page /Type /Page /Rotate 0 19 0 obj /Annots [] /PageLabels 3 0 R /MediaBox [0 0 612 792] Allied and Republic are two of only a few providers of waste collection or disposal services in each of the identified areas. In exchange, pursuant to other agreements, Republic would acquire from Allied: disposal assets in Anderson, Indiana; hauling assets in Columbus, Ohio; hauling assets in Lakeland, Florida; hauling assets in Louisville, Kentucky and Sellersburg, Indiana; hauling and disposal assets in Macon, Georgia; and hauling assets in Monmouth, Burlington and Camden counties, New Jersey. /Count 10 /MediaBox [0 0 612 792] /Type /Page 22408. SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION In re: JOSE SANCHEZ Case No. /Contents [302 0 R 303 0 R 304 0 R] /Annots [] "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. /Resources 385 0 R >> 85 0 obj Therefore, it should not be a decision made lightly. 17. ( /Rotate 0 >> VERIFIED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF Introduction 1. /Type /Page 80 0 obj startxref >> %&'()*456789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz w !1AQaq"2B #3Rbr 50. >> 11. << /MediaBox [0 0 612 792] hbbd`b`rfb`gb` # << PDF Complaint for Injunctive Relief, Damages, Firms that compete in the disposal of MSW can profitably increase their charges to haulers of MSW without losing significant sales to any other firms. /CropBox [0 0 612 792] There are no good substitutes for MSW disposal. 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. In the Clarksville, TN area, the acquisition would reduce from five to four the number of significant firms competing in the collection of small container commercial waste. .t. 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. EOs6~W\F3[_y7~r+W3nU>9YRpM/u"%1yK Ivp, Microsoft Word - 2022-08-24 - Complaint - FINAL. /Type /Catalog /Rotate 0 endobj What happens if the temporary injunction is not granted? /Rotate 0 0000003135 00000 n /Contents [106 0 R 107 0 R 108 0 R] << /Contents [186 0 R 187 0 R 188 0 R] /Parent 7 0 R /Annots [] /Type /Pages endobj /CropBox [0 0 612 792] /MediaBox [0 0 612 792] Because of the differences in the collection process, residential customers and commercial customers usually are organized into separate routes. /Parent 12 0 R 47 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. /Parent 12 0 R /Annots [] << endobj 7 0 obj Official websites use .gov /Type /Page See also Chapter 224.08, Special Acts of Florida, 1943. /Annots [] /CropBox [0 0 612 792] /Count 9 << /Parent 13 0 R ( << /Rotate 0 /Parent 11 0 R 6th Street Ft. Lauderdale, FL 33301 Defendants. /Contents [166 0 R 167 0 R 168 0 R] /Type /Page endobj %PDF-1.5 94 0 obj endobj "Macon, GA area" means the City of Macon and Bibb, Peach and parts of Houston, Jones and Monroe counties, Georgia. 62. /CropBox [0 0 612 792] MSW has physical characteristics that readily distinguish it from other liquid or solid waste. /Parent 7 0 R 42. /Resources 381 0 R 3 0 obj /Resources 357 0 R /Rotate 0 /Resources 293 0 R /Resources 345 0 R >> /MediaBox [0 0 612 792] 92 0 obj /CropBox [0 0 612 792] In order to obtain comparable operating efficiency, a new firm must achieve route density comparable to existing firms. endobj H*23430P AsKN$r{(s 1. /Rotate 0 /Contents [314 0 R 315 0 R 316 0 R] /Kids [55 0 R 56 0 R 57 0 R 58 0 R 59 0 R 60 0 R 61 0 R 62 0 R 63 0 R 64 0 R] Rather, its about dealing with the future, not something that happened in the past. In these markets, Allied and Republic each account for a substantial share of MSW disposal capacity. 12. /Resources 225 0 R << % /Parent 11 0 R endstream /Parent 14 0 R 75 0 obj >> 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. 39 0 obj In 1999, Allied reported total revenues of approximately $6 billion. /Count 10 9. COMPLAINT FOR INJUNCTIVE, DECLARATORY RELIEF, AND DAMAGES Plaintiff, STATE OF FLORIDA, DEPARTMENT OF LEGAL AFFAIRS sues Defendant, TODD TEAL d/b/a WALTER A. SMITH, SNUFFY SMITH, (TEAL) and alleges: NATURE OF THE ACTION 1. << 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. 7. /MediaBox [0 0 612 792] /Parent 7 0 R /Parent 7 0 R /Parent 14 0 R >> /CropBox [0 0 612 792] endobj 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. 45 0 obj >> << ( /Contents [226 0 R 227 0 R 228 0 R] 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] IV. ( << /CropBox [0 0 612 792] 0000001149 00000 n 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. %PDF-1.5 % /Contents [134 0 R 135 0 R 136 0 R] 82 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. Haulers, therefore, generally establish garages and related facilities within each major local area served. 0000001536 00000 n /Resources 349 0 R Venue properly lies in the Southern Distri ct of Florida pursuant to 28 U.S.C. /CropBox [0 0 612 792] 0000001373 00000 n /CropBox [0 0 612 792] 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. << The President of the United States and the Governor of Florida have each declared a state of emergency. endobj /Resources 177 0 R /Type /Pages C. Reduction in Competition As a Consequence of the Acquisition. /MediaBox [0 0 612 792] JacqmeinV "New York City, NY area" means the Borough of Brooklyn, New York. 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. /Annots [] Professional Services Industry Legal Blog>. >> 20 0 obj Small Container Commercial Waste Collection Service. This document is available in two formats: this web page (for browsing content) and. /Parent 10 0 R >> /Annots [] ( << Garcia controll ed the MJ Companies prior to their going into receivership. 42 0 obj 62 0 obj "Augusta, GA area" means the City of Augusta, Richmond and Columbia counties, Georgia, and Aiken County, South Carolina. /Rotate 0 Plaintiffs Rural & Migrant Ministry, Alianza Nacional De Campesinas, El Comite . REPUBLIC SERVICES, INC., 110 S.E. hb```"FN%n010pKsg``Z ^^@Y"bL38/4F `} endstream endobj 24 0 obj <> endobj 25 0 obj <>/ProcSet[/PDF/Text]>>/Rotate 0/Type/Page>> endobj 26 0 obj <>stream 32 0 obj endobj endobj /Annots [] 6108, to obtain temporary, preliminary, and permanent injunctive relief, rescission or reformation of contracts, restitution, the refund of monies paid, disgorgement of ill-gotten . It is engaged in providing waste collection and disposal services throughout the United States. 29 0 obj 1 1 On February 7, 2023 and February 16, 2023, Plaintiff filed motions for preliminary 2 injunctive relief. << In contrast to a commercial collection route, a residential waste collection route is significantly more labor intensive. This Court has jurisdiction to enter declaratory and injunctive relief pursuant to Florida Statute 86.011 and Article V, 20 of the Florida Constitution. Jimerson Birr welcomes inquiries from the media and do our best to respond to deadlines. 19. Does the temporary injunction preserve the Status Quo or does it make a change? 76 0 obj <> endobj What impact will it have on third-parties and employees? endobj /Contents [142 0 R 143 0 R 144 0 R] 36. endobj /Resources 221 0 R /Parent 4 0 R Suing for an injunction in Florida is all about preserving the status quo. << /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 /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. /MediaBox [0 0 612 792] 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. "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. << /Parent 12 0 R (Compl . Waiver recipients are entitled to continuation of services that they are currently receiving through the completion of the fair hearing /CropBox [0 0 612 792] /Parent 7 0 R /Annots [] /Author (JacqmeinV) /Type /Page >> /Rotate 0 << /Annots [] provide relief to all the individuals affected by APD's action. << << /MediaBox [0 0 612 792] << /Parent 10 0 R 2322 0 obj<>stream provide preliminary and permanent injunctive relief pursuant to Rules 57 and 64 of the Federal Rules of Civil Procedure and 28 U.S.C. /Annots [] 13(b) of the Federal Trade Commission Act ("FTC Act"), 15 U.S.C. >> /MediaBox [0 0 612 792] Plaintiff is a Florida resident, lives in Miami- Dade County, is sui juris, and qualifies of a protected class under the ADA, 42 U.S.C. << The acquisition would reduce from four to three the number of significant firms that compete in the collection of small container commercial waste in the Louisville, KY/Sellersburg, IN area. /Type /Page "Memphis, TN area" means Shelby County, Tennessee; Desoto County, Mississippi, and Crittenden County, Arkansas. /MediaBox [0 0 612 792] Defendant is defined as a "Public Accommodation" within meaning of Title III /Rotate 0 40. endobj /Parent 8 0 R /Parent 13 0 R IV. /Contents [382 0 R 383 0 R 384 0 R] /Contents [338 0 R 339 0 R 340 0 R] /Rotate 0 /Resources 257 0 R for the Middle Distrct of Florida, hereby files this complaint for permanent injunction and alleges as follows: 1. 65 0 obj 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. /Contents [250 0 R 251 0 R 252 0 R] << /CropBox [0 0 612 792] /Rotate 0 /Rotate 0 /Contents [266 0 R 267 0 R 268 0 R] /CropBox [0 0 612 792] ( "Albany, NY area" means the City of Albany and Albany, Schenectady, Saratoga, and Rensselaer counties, New York. 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. ( 34 0 obj >> /Annots [] >> /Parent 4 0 R 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. ( Complaint for purposes of Florida Statutes Sections 501.207(5) and 95.11(3). >> 12 0 obj 22. 8 0 obj "Lakeland, FL area" means Polk County, Florida. endobj hUN@h/%FT""Qy@Kbxw81FgfvEN.tF2AiP9?{"1zQ. 7402(a) to prevent such conduct. >> >> <> /Resources 301 0 R Plaintiff, Florida Carry, is a Florida Not-For-Profit Corporation with a principal place of business located at 1090 Wild Holly Drive, Port Orange, Florida, 32129. 60 0 obj /CropBox [0 0 612 792] ( 45], filed on August 192021, . Local public opposition often makes it more difficult and costly, and increases the time and uncertainty of successfully permitting a facility. 4. endobj The United States is entitled to injunctive relief under 26 U.S.C. >> 0000002235 00000 n /Resources 153 0 R 67 0 obj 0 /Type /Page >> /Rotate 0 /Type /Page << /MediaBox [0 0 612 792] << For a number of reasons, landfills may not be located close to where the waste is generated. Temporary Injunction - Florida Litigation Guide /Annots [] /Length 10 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. /Parent 14 0 R /Parent 13 0 R stream endobj stream /Producer <4163726F6261742044697374696C6C65722032322E30202857696E646F7773293B206D6F646966696564207573696E67206954657874AE20372E312E3620A9323030302D323031392069546578742047726F7570204E56202841646D696E697374726174697665204F6666696365206F662074686520556E697465642053746174657320436F757274733B206C6963656E7365642076657273696F6E29> 47. endobj /Type /Page 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. 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 . endobj In re Amendments to Florida Small Claims Rules, 123 So.3d 41 (Fla . /Contents [346 0 R 347 0 R 348 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. /CropBox [0 0 612 792] /Parent 10 0 R ( 71 0 obj /Rotate 0 << 91 0 obj 69 0 obj << 0000001275 00000 n /Contents [98 0 R 99 0 R 100 0 R] /Parent 9 0 R 68. /MediaBox [0 0 612 792] /Contents [278 0 R 279 0 R 280 0 R] 28 0 obj endobj 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. << /MediaBox [0 0 612 792] endobj /CropBox [0 0 612 792] /CropBox [0 0 612 792] /CropBox [0 0 612 792] Amended Complaint "Motion") [ECF(the No. /Contents [230 0 R 231 0 R 232 0 R] 16. Small container commercial waste collection differs in many important respects from the collection of residential or other types of waste. xref endobj /Parent 4 0 R /Contents [150 0 R 151 0 R 152 0 R] &%e2#4DqB#K.tt.GYeMbN!uiW-C`oIynF,fD5c&a8|A!y%?ci6Ywo`aPT=Yz0Id Therefore, its important to not consider it a tool for righting a wrong. << In its 1998 fiscal year, Republic reported total revenues of approximately $1.8 billion. 0000006259 00000 n /Resources 361 0 R 43 0 obj /Rotate 0 Virtually all of the MSW generated in each of these areas is disposed of in transfer stations in each of their local areas. #%$""!&+7/&)4)! endobj 69. - All Rights Reserved, Community Advocacy & Social Responsibility, Traditional Contract Principles Impacting Enforcement of Noncompete Agreements in Florida. /Resources 101 0 R /Rotate 0 PDF United States District Court Southern District of Florida Case No 16 0 obj The extension of vote-by-mail options and other accommodations at polling places is necessary. >> /Annots [] << That plaintiff recover the costs of this action. << Plaintiffs also seek temporary injunctive relief as stated in the accompanying Motion for Temporary Injunction. 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. /Resources 97 0 R Omega SA v. The Individuals, Business Entities, and Unincorporated /Annots [] /Contents [374 0 R 375 0 R 376 0 R] 0000002929 00000 n /Resources 365 0 R /Type /Page /Resources 337 0 R 65. /Rotate 0 /Annots [] /Rotate 0 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. Jurisdiction is conferred on this Court by Chapters 26, 34, 86.011. 22 0 obj /Type /Page endobj xYYoH~7"b` recB$hHjRbK6DQ]]WUMb8`}^^l,q8x1O,7~`[)gD,uq+sU+PP)>f90VY-^AEKS2t}g4 X!xH rTmvF4(,W`{kF$tC endobj If the major roll-off collection competitor in a market also controls the primary disposal site(s) therein, other roll-off competitors are at a large disadvantage and entry is difficult. /Contents [222 0 R 223 0 R 224 0 R] /CropBox [0 0 612 792] 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. /CropBox [0 0 612 792] /Rotate 0 /CropBox [0 0 612 792] /Contents [206 0 R 207 0 R 208 0 R] /Resources 133 0 R >> /Resources 113 0 R 31. Allied is located in and transacts business in the District of Columbia, and Republic submits to the personal jurisdiction of the District of Columbia in this proceeding. That plaintiff receive such other and further relief as the case requires and the Court deems proper; and. 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!$Ippa8fHNtD {,nPY 5 not /Resources 317 0 R /Rotate 0 /Parent 8 0 R Typical commercial waste collection customers include office and apartment buildings and retail establishments (e.g. Microsoft Word - 2022-08-24 - Complaint - FINAL /Rotate 0 /Parent 4 0 R clearly appears from specific facts shown by affidavit or by verified complaint that immediate or /Contents [234 0 R 235 0 R 236 0 R] ]Wx C1>*yvL#uR$=I$$WJQg%=ElRS3DE27y1 G. endobj This is a lawsuit for declaratory and injunctive relief under 86.011, Fla. Stat. Judgment for Permanent Injunctive Relief against MJ Taxes on October 1, 2021. >> /Contents [322 0 R 323 0 R 324 0 R] 51. 0 << /MediaBox [0 0 612 792] /Type /Page /Parent 12 0 R /CropBox [0 0 612 792] The City changed its name from "New $4%&'()*56789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz r! Plaintiff, PRISON LEGAL NEWS ("PLN"), a project of the Human Rights Defense . In the Macon, GA area, the acquisition would also combine the two largest firms that compete in roll-off waste collection service. On July 28 and October 7, 1999, in twelve (12) separate purchase agreements, defendants agreed to exchange assets of various subsidiary companies ('the acquisitions"). 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. /MediaBox [0 0 612 792] 25. /Type /Pages The next step is careful preparation before the temporary injunction hearing. PDF Verified Complaint for Declaratory and Injunctive Relief 83.40 et seq. >> 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. 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. Alexdex. ( 21. 74 0 obj Venue is therefore proper in this district under Section 12 of the Clayton Act, 15 U.S.C. stores and restaurants). 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. /Contents [126 0 R 127 0 R 128 0 R] /MediaBox [0 0 612 792] Permit restrictions often impose severe limitations on the type and amount of waste that can be disposed of at landfills. endobj /Annots [] 67. 27. 25 0 obj <> endobj >> /Annots [] PDF Complaint for Emergency Injunctive and Declaratory Relief