IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA,
REPUBLIC SERVICES, INC.
Civil Action No. 00-1469 RU
Date: November 30, 2004
Judge Ricardo M. Urbina
WHEREAS Petitioner the United States and Respondent Republic Services, Inc., having
filed a Joint Motion for Entry of Settlement Agreement and Enforcement Order on November 30,
AND WHEREAS the United States and Republic have agreed upon a resolution of this
matter without any admission or determination of wrongdoing by Republic and without any
findings or adjudication with respect to any issue of fact or law;
IT IS HEREBY STIPULATED AND AGREED by and between the undersigned parties
- This Court has jurisdiction over the subject matter of this action and each of the
parties to this action.
- A proposed Settlement Agreement and Enforcement Order in the form attached as
Exhibit A may be entered by the Court on the Court's own motion or the motion
of the United States at any time, and without further notice to any party or any
- From the signing of this Stipulation, Republic shall be bound by and comply with
the terms of the proposed Settlement Agreement and Enforcement Order as
though they were in full force and effect as an order of the court.
- The parties' execution of this Stipulation and entry of the proposed Settlement
Agreement and Enforcement Order discharges and settles any and all claims of the
United States against Republic arising out of any violation of Paragraphs XII.A
and B of the Final Judgment ("FJ") entered by this court on September 8, 2000, in
United States v. Allied Waste Industries, Inc. and Republic Services, Inc., Civil
Action No. 00-1469, in Columbus, OH; Lakeland, FL; Louisville,
KY/Sellersburg, IN; Macon, GA; Marlboro, NJ; and Mt. Laurel, NJ from
September 8, 2000 to the date of this Stipulation.
- Neither this Stipulation nor the proposed Settlement Agreement and Enforcement
Order shall be construed to preclude the United States from bringing an action
against Republic for any violation(s) of the FJ other than possible violations
described in Paragraph 4 above.
Dated: November 30, 2004
|REPUBLIC SERVICES, INC.
JOEL A. CHRISTIE (DC Bar#463343)
Counsel for Republic Services, Inc.
Akin Gump Strauss Hauer & Feld LLP
1333 New Hampshire Avenue, NW
Washington DC, 20036-1564
|UNITED STATES OF AMERICA
JOHN B. ARNETT, SR. (DC Bar #439122)
U.S. Department of Justice
Litigation II Section
1401 H Street, N.W., Suite 3000
Washington, D.C. 20530