On April 27, 2004, Allied Waste reported its financial results for the first quarter ended March 31, 2004. Accompanying this report was the statement, "We are pleased with the solid internal growth that we experienced during the first quarter through the combination of consistent volume increases in positive pricing…. the combination of our operating leverage in an improving economy and the financial leverage through our debt reduction strategy continues to provide a clear path for value creation for the owners of our business."

In fact, the lawsuits allege that the defendants’ statements were materially false and misleading because they failed to disclose the following, that: (1) the company's internal growth was lagging due to poor management execution and the loss of a large contract; (2) the defendants had failed to successfully implement the company's "best practices" initiatives because Allied Waste lacked adequate internal controls; (3) the defendants knew or recklessly disregarded the fact that much-anticipated cyclical volume pickup of trash was not materializing.

On July 27, 2004, Allied Waste reported its financial results for the second quarter ended June 30, 2004. Among other things, this report stated that, "However, contrary to our original expectations for 2004, the implementation of these [best practices] programs is costing more and we are not yet experiencing the economic driven improvement in our business. As a result, we are reducing our original expectation for our 2004 operating income before depreciation and amortization of $1.6 billion by three to four percent."

Following this announcement, J.P. Morgan cut Allied waste stock to "neutral" from "overweight." This news shocked the market, company shares falling $2.55 per share, or 20.83%, owned unusually high trading volume, to close at $9.69 per share. This was Allied Waste's biggest drop in five years.

If you purchased securities issued by Allied Waste during the applicable period, you may request appointment by the court as a lead plaintiff if you do so by October 12, 2004. A lead plaintiff is a representative party that acts on behalf of other class members in directing the litigation. In order to be appointed lead plaintiff, the court must determine that your claim is typical of the claims of other class members, and that you will adequately represent the class. Under certain circumstances, one or more class members may together serve as lead plaintiffs. Your ability to share in any recovery is not affected by the decision whether or not to serve as a lead plaintiff. You may retain any counsel of your choice to serve you in this action, or you may choose to do nothing, and remain in the class as a silent member.