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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA



UNITED STATES OF AMERICA,    

                  and

STATE OF FLORIDA, by and
through its Attorney General,

                  v.

REUTER RECYCLING OF FLORIDA,
INC., and
WASTE MANAGEMENT INC. OF
FLORIDA,

                  Defendant.


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CIVIL ACTION NO.:

Filed: [October 20, 1995]

STIPULATION

It is stipulated by and between the undersigned parties, by their respective attorneys, that:

1. The Court has jurisdiction over the subject matter of this action and over each of the parties hereto, and venue of this action is proper in the District of Columbia.

2. The parties consent that a Final Judgment in the form hereto attached may be filed and entered by the Court, upon the motion of any party or upon the Court's own motion, at any time after compliance with the requirements of the Antitrust Procedures and Penalties Act (15 U.S.C. § 16(b)-(h)), and without further notice to any party or other proceedings, provided that Plaintiffs have not withdrawn their consent, which they may do at any time before the entry of the proposed Final Judgment by serving notice thereof on the Defendants and by filing that notice with the Court; and

3. The parties shall abide by and comply with the provisions of the proposed Final Judgment pending entry of the Final Judgment, and shall, from the date of the filing of this Stipulation, comply with all the terms and provisions thereof as though the same were in full force and effect as an order of the Court.

4. This Stipulation shall become effective when, if and only if, defendant Waste Management Inc. of Florida acquires a majority of the outstanding shares of defendant Reuter Recycling of Florida, Inc. If the Plaintiffs withdraw their consent or if the proposed Final Judgment is not entered pursuant to this Stipulation, this Stipulation shall be of no effect whatsoever, and the making of this Stipulation shall be without prejudice to any party in this or in any other proceeding.

DATED this 20th day of October, 1995.

 

Respectfully submitted,

FOR THE PLAINTIFF THE UNITED STATES OF AMERICA:

_/s/______________________________
Anne K. Bingaman
Assistant Attorney General
Antitrust Division
U.S. Department of Justice

_/s/______________________________
Lawrence R. Fullerton
Deputy Assistant Attorney
    General

_/s/______________________________
Constance K. Robinson
Director of Operations

_/s/______________________________
Charles E. Biggio
Senior Counsel

_/s/______________________________
Anthony V. Nanni
Chief, Litigation I Section

_/s/______________________________
Willie L. Hudgins, Jr.

Attorneys
U.S. Department of Justice
Antitrust Division

_/s/______________________________
Nancy H. McMillen

Attorney
U.S. Department of Justice
Antitrust Division
City Center Building, Suite 4000
1401 H Street, N.W.
Washington, D.C. 20530
202/307-5777

FOR PLAINTIFF STATE OF FLORIDA:

_/s/______________________________
Robert A. Butterworth
Attorney General

_/s/______________________________
Patricia A. Conners
Assistant Attorney General

_/s/______________________________
Lizabeth A. Leeds
Assistant Attorney General

_/s/______________________________
H. Edward Burgess, Jr.
Assistant Attorney General

Office of Attorney General
State of Florida
The Capitol
Tallahassee, Florida 32399-1050
(904) 488-9105

 

FOR THE DEFENDANT REUTER RECYCLING OF FLORIDA, INC.:

_/s/______________________________
John H. Korns
(D.C. Bar No. 142745)
OPPENHEIMER, WOLFF & DONNELLY
1020 19th Street, N.W., Suite 400
Washington, D.C. 20036
(202) 293-6300
 

FOR THE DEFENDANT WASTE MANAGEMENT INC. OF FLORIDA:

_/s/______________________________
Michael Sennett
BELL, BOYD & LLOYD
Three First National Plaza
Chicago, Illinois 60602
(312) 372-1121

_/s/______________________________
Andrew N. Cook
(D.C. Bar No. 416199)
BELL, BOYD & LLOYD
1615 L Street, N.W.
Washington, D.C. 20036
(202) 466-6300