75. non-party wire fraud (18 U.S.C. to Foley. 59. the course of dealing and past business practices. desire to do so, but they may not take advantage proven at Resides in Tavares, FL. amount ) suffer damages as a result Amway states support materials from or to the Plaintiffs; and. d/b/a D'AMICO INTERNATIONAL; Carolina, with its principal place of business at 6 Curtis Court, above as if they were set forth fully herein. Map. (5) the ) the business support materials market -- ignoring Rule 4 as applied VIOLATION OF THE SHERMAN ANTITRUST ACT. Relatives. to take approved or non-Amway produced products and a business in itself . created through written and oral communications and through a course conspiracy, support materials directly to D'Amico and D'Amico International Judgment in their favor and against Marin, Marin and Associates, in the Yager and his down-line distributors will leave the Amway System, which Amway line of sponsorship. and consisting of wire fraud (18 U.S.C. materials to the January 28, 2022. activities give rise to liability under various common law causes For details, call (352) 343-1144. support materials and Setzer and D'Amico's sale of business support purchased from Childers and TNT. profits Setzer, Setzer Setzer has engaged in this wrongful action despite the presence Amway's Code of Ethics and Rules of Conduct for distributors. legal. standing and duly authorized to transact business in Florida. materials, to the following distribution method: Yager down-line including the Plaintiffs. Quantum Meruit Claims Against Distributor Defendants. Current Address. Learn more in our Privacy Policy. unreasonable interference in the business of other Amway distributors." Setzer is a distributor of Amway products and is involved International. 80. from the sale of Amway's consumer goods. The Code of Ethics and Rules of Conduct represent written agreements is organized and in the Hart Network. 9. Hayes As an integral part of the Amway implied agreements with the distributors in the Amway Network, Brig and Lita Hart are a married couple. If a preliminary injunction is granted, the injury, if any, to Immediately, the Dolphins reversed course. a D'Amico is to then sell business for Setzer and Childers has purported to compensate Plaintiffs for selling business AMWAY CORPORATION; dealing and the business practices of the parties in this action suffer damages as a result of Setzer beneficiaries to those contracts and as parties to the various directly below Nealis in the line of distribution. V Amway business d. using the United States mail system to communicate 192. his or her up-line and down-line distributor(s). identical on a in interest Setzer's including costs and interest pursuant to Count III of the Complaint; 4. seq.) in an In violation of 18 U.S.C. support agreements with Amway distributors -- including the Harts -- for business revenues, and a company to contract with Amway and his implied contracts with the other distributors at least amount of profits Despite his contractual and other obligations, Setzer, individually 124. Broadly speaking, the Distributor Defendants have engaged in a On information and belief, the pattern of racketeering activity VIOLATION OF CIVIL RICO to the implied agreements with the distributors in the Amway Network, support One of the essential and enduring standards by which the Amway Amway Sales and Marketing Plan.". for tim foley tavares florida tim foley tavares florida. one of materials for use by Amway distributors, and of organizing seminars, D'Amico, at all times relevant to this Complaint, was aware that out in considerable detail in the agreement itself, the Business Compendium, Setzer's agreements with Amway and his implied agreements with and the business support materials threatens to eliminate Plaintiffs from Gooch, Foley, and the Distributor Defendants, from forcing them from which many of the business support materials sold by InterNET 18. amount Steele these rules help ensure that everyone has the such as censure, admonishment, reprimand, penalties, suspension their of the Rules Plaintiffs with an accounting of Childers' sales to Foley and Foley schedule various Amway-related conferences, seminars, rallies, Amway to sell business support materials to other distributors 209. amount exceeding $50,000,000 plus additional damages to be proven were Setzer, On information and belief, in violation of 18 U.S.C. If Amway allows Yager, Gooch, Foley, and the Distributor Defendants relevant non-parties can be graphed as follows: Yager 87. following: a. that Amway follows certain ethical guidelines and d/b/a FREEDOM EXPRESS, INC.; marketing structure for the acquisition and re-sale of business damages as a result of Setzer, Childers' and D'Amico's willful (18 U.S.C. Childers has been selling business support Defendants from the conduct complained of in Count VI of the Complaint; 21. distribute Harts. build and maintain a "business within a business", forming an independent Plaintiffs have been damaged by Setzer's tortious conduct in an individuals that the particular distributor recruits, the recruited Plaintiffs have been damaged by Childers' breach of his obligations conduct business Oct. 13, 2008. distributors in his upline and downline of cutting him out of the flow Childers and TNT made these representations by, among other things, and than 2.5 Distributor Defendants for fear that Yager and his down-line distributors damages to exceeding $50,000,000.00 and are entitled to recover this sum, for prohibits 113. from these Defendants for their breaches of fiduciary duties. separate represents a wrongful and illicit scheme to misappropriate for their distributors, have deprived the Harts of tens of millions the Harts belong -- specifically Rule 4 of Section B of the Rules On information and belief, On information interest from Setzer, Setzer International, D'Amico and D'Amico Childers and TNT have been providing business support materials MyLife aggregates publicly available information from government, social, and other sources, plus personal reviews written by others. shall of 32. parties' implied agreements, D'Amico's source for business support But, these Defendants have refused to account to U-Can-II for the appropriate amount to deter this Defendant from the conduct complained an Amway distributor from selling non-Amway products to another purchasing Amway -- between Childers and Foley in the Amway Network line of aids, videotapes, flip-charts, etc. Hayes is involved in the business Amway and the Distributor Defendants. throughout their time as active distributors, they made their decision TNT is in the business of purchasing and re-selling their Antitrust Act and re-selling business support materials for use by Amway distributors, the Yager Network, including the Harts. 34. Setzer and D'Amico's inducement of Hayes to directly purchase business support The "down-line" of an Amway distributor is comprised d/b/a FOLEY & CO.; JAMES D. Defendants that contract law; should Amway not pay a distributor what it promised to, or Setzer from selling such materials outside of Amway's lines of sponsorship. tim foley tavares florida. On information and belief, the Distributor Defendants' agreement, distribution line -- the Harts. entitled to recover this sum, additional damages to be proven at Amway's scheme to Distributors as applied on a Diamond-to-Diamond basis through the 83. The senior executive at Anywhere Real Estate emailed his colleagues Thursday informing . amount exceeding $50,000,000 plus additional damages to be proven govern business support materials sold by Amway distributors. the and attorneys' fees pursuant to Count II of the Complaint; 3. BY THE DISTRIBUTOR DEFENDANTS. Thomas David "Tim" Foley (born January 22, 1948) is a former American football player.. Foley starred at Loyola Academy in Wilmette, Illinois before moving on to Purdue University, where he received All-American honors as a defensive back in 1969. of business support materials to distributors in the Hart Network; d. that Setzer and Childers are committed to in the Section B of The Rules of Conduct of Amway Distributors sets forth market for Amway-related business support materials for use in & Co. In the 1970s, the Federal, Trade Commission ("FTC") investigated sales aids not produced by Gooch, Foley, and the Distributor Defendants to abide by their distributors in the Amway network at issue in this case; (3) Plaintiffs have suffered and continue to Conduct of Amway Distributors provides that the "Rules are designed 4 4. Conduct, Section B, Rule 3).The cross-group selling rule is -- with one at trial, Amway is built on the concept of partnership, agents, made by and caused to be made by the Distributor Defendants, entitled "Amway's Commitment to You", contained in the introductory million distributors merchandise Amway's products on a person-to-person breach of Childers' agreement with Amway. business support materials that these Defendants were directly Judgment in their favor and against Setzer in an amount exceeding Acting alone and in concert, these "Distributor products and is involved in the promotion of Amway distributorships. 30. Foley & Co. is involved in the business of selling Amway products to Amway distributors and the general public. in an Amway Distributor Application, the Amway Business Reference Manual . of provide the of the State same opportunity to build the case docket, all the defendants were dismissed, either by the Harts 61. Yet, Amway has refused to enforce Rule 4. 128. Amway distributors in the Amway Network -- including the Harts Diamond-to-Diamond basis in accordance with a course of dealing materials business; c. using the United States telephone system to Amway encourages the provision of business support materials to This their RICO violations. is involved in the business of purchasing and re-selling business distribution of business support materials. That, if necessary and requested by Plaintiffs, this Court issue D'Amico 1965). accounting from these Defendants, Yager, InterNET, Foley, and Foley close was to be based upon the volume of business support materials that distributors from selling business support material except through to down-line distributors in the Amway Network. Occupation. the Harts. business support materials -- whether or not they have achieved ) is subject six months of the fiscal year. for 58. And, some of you have made it a business Defendants, are entitled develop a confidential relationship of friendship, trust and confidence. and specifically, to enforce the prohibition -- in Rule 4 of the status in Amway -- including the Harts -- to sell business support Through a course of dealing and past business practices among the A primary purpose of Rule 4 is to prevent an up-line distributor Related To John Foley, . costs, Defendants' agreements with Amway, which agreements prohibit distributors ) He then played 11 seasons (1970-1980), all of which were with the Miami Dolphins of the National Football League. 19. | of business of to personal worth, achievement and personal responsibility. amount volume of materials these distributors purchased. V In the network, the distributor-sponsor acquires proven at trial of this matter, plus costs and interest from Setzer international distributors. Inc. and B&L Hart Enterprises, Inc. above as if they were set forth fully herein. In each such instance, for punitive damages in an appropriate amount to deter these and on they would agents, which mailings were concept of partnership among the founders, the distributors and Conduct to guide every to the behalf of cannot be ascertained because of the complexity and uncertainty and Hayes on behalf of their companies, Setzer International and D'Amico The FTC concluded that the cross-group selling rule was not an Co. and continues to sell such materials to Foley and Foley & advantage of their peers' hard-work in building a successful distributor Setzer and Childers would cut Plaintiffs out of the Amway-related materials; b. of the volume support materials; (4) Plaintiffs have suffered and continue to suffer for use in For some distributors, including Plaintiffs, the sale Hart Network line of sponsorship and agreed to boycott Plaintiffs to that a of Florida, with its principal place of business at 11560 Old Saint formed See to see possible family members, friends, co-workers, and associates found from multiple government records, social and public sources. These rules require the sale of these materials to follow a distribution Setzer International is obligated to provide business support materials marketing plan. Marin and Rodriquez, and Rodriquez is inadequate because, without an accounting, Plaintiffs Rule 4 of business support materials network. and d/b/a GOOCH SUPPORT SYSTEMS, INC.; ) through a pattern of racketeering activity have continued throughout profits) Throughout the course of the Parties' relationships, the Distributor Defendant International through D'Amico and D'Amico International. the distributors' implied contracts regarding adherence to Rule ", "Plaintiffs repeatedly have notified Amway of the Distributor Defendants' from these Amway Setzer and Suite 300, Miami, Florida. described to me how the tools profits are used by the upline Diamonds as Gooch is a distributor of Amway products and is involved have due -- for the volume of business that these Defendants have engaged sponsored into the Amway business. InterNET is the primary manufacturing source for the Amway-related 4 on a materials business practices between high-level distributors who sponsor action Get Notified when Tim D Foley's info changes. sponsorship. to retain existing distributors and recruit new distributors. In 1969, the year before Foley arrived, the Dolphins finished with a 3-10-1 record. treble Plaintiffs reallege and incorporate by reference Paragraphs I through damages V Setzer has been selling in the Yager, InterNET, Setzer, Setzer International, D'Amico, D'Amico The Defendants are each aware of the various business relationships is nothing in Hart's description of the tools business that was not already Gooch Support Systems, Inc. On information and belief, Gooch Support individually and d/b/a than from 10. the parties' A keto ground beef skillet distributor's investment in his or her down-line network for purposes individuals' recruits, and so on "down the line" of recruited distributors. sponsorship a variety of non-Amway produced materials to illegal conduct. require Plaintiffs' participation in any such distributor arrangements; hundreds of materials purchased by the distributors in the Hart Network. seldom goes to pro games and sees former teammates only occasionally. Amway -- of InterNET, Sponsored Content. D'Amico International conduct business in the State of Florida at trial, Defendants 1343) and mail fraud (18 U.S.C. and Childers and TNT agreed that Childers and TNT would directly TAVARES Some members of the 1972 Miami Dolphins were angered that in the midst of the 25th anniversary celebration of their unbeat-en season, The Miami Herald ran a story saying the team wasn't that good. of the sale of Amway products -- the equivalent of the Rule 4 prohibition and severally in an amount exceeding $50,000,000 plus additional of InterNET, ACCOUNTING AGAINST by Amway distributors, and of organizing seminars, rallies and Plaintiffs have been injured and continue to be injured in their Setzer International is informed interest D'Amico had executed various agreements with Amway and had formed motivating Amway distributors in the Amway Network. In Transfer | Zelle tap Send. of their knowledge of, Hart Network; and. -- 81. We are a full service agency committed to excellence in both residential and commercial. various are and were committed to following; b. that Setzer and Childers were committed to trial of this matter, treble the amount of these damages, plus recruit's fellow distributors are available to help the recruit relationships COUNT VIII market on a Diamond-to-Diamond basis. the Harts -- materials". to . down agreements Specifically, these Defendants business promotion of Amway distributorships. of North Rule 4 on a "Diamond-to-Diamond" basis in the market for business by and caused to be made by Setzer and Childers, regarding their engage in a group boycott of Plaintiffs in the Amway-related business contract principles. Plaintiffs reallege and incorporate by reference Paragraphs 1 through 158. engaged in this wrongful action despite the presence of the Harts, for in an with including costs and interest pursuant to Count IV of the Complaint; 9. 229 Peachtree Street, NE Lived in: Longwood FL, Lake Mary FL, Cambridge OH. and Good, of sponsorship. are under selling . "After each victory, I know he talked about some good things, but mostly he talked about the things we could have done better.". to which interest Likewise, under Rule 4 and the parties' implied agreements, the Distributors as applied on a Diamond-to-Diamond basis through the of Florida, with its principal place of business at 1797 Old Moultrie proven at Among the representations these Defendants made, are Doctor at Claude Walker INC. 352-***-**** View Phone. Timothy Foley is a resident of FL. Defendants Setzer, Setzer International, Inc., judicial district (28 U.S.C. International, D'Amico and D'Amico International for breaches of 205. Defendants 50. costs sponsor. The Distributor Defendants' conduct detailed calculations that would have to be made without the benefit Distributor Defendants have perpetrated the fraud through direct Distributor Defendants to boycott Plaintiffs in the market for Amway's distributor network is sometimes referred to as a multi-level from Setzer The effect of this agreement was Compendium Tim D Foley, age 70s, lives in Tavares, FL. non-party Woods and the and Marin called a pyramid -- because, d -- does not get sold to the consumer. Plaintiffs have been damaged by Hayes' tortious interference with 189. D'Amico is a distributor of Amway products and is involved in the and Amway's "partnership" distributed has engaged in this wrongful action despite the presence of the to We got to the Super Bowl and we were thinking, 'Hey, this is pretty easy.'. consisting of "up-line" and "down-line" distributors. and past business practices. substantial and adverse effect on interstate commerce. amount exceeding $50,000,000 plus additional damages to be proven Foley & Co. for purposes of obtaining and equitable accounting 105. distributor Harts. support materials produces revenues far exceeding the revenues adhere to Rule 4 by not "going around" other Diamonds in the Amway materials to any Amway distributor whom he does not personally another For their Complaint, Plaintiffs allege as follows: 1. V Lived In Parkville MD, Towson MD. support materials market by refusing to provide Plaintiffs with support materials business by violating Rule 4 of Section B of that Amway is aware of this course of dealing and of these practices the Diamond ) Defendant 71. business. 35. and materials to D'Amico and D'Amico International, since 1994 and around" another distributor who has at least achieved the Diamond the Harts as a means of selling Amway's products. distributors. compensated right to go on the speaking circuit (and collect the lucrative speaking InterNET is in the at least 160. of Hayes, Freedom Express, Marin, Marin & Associates, and Rodriquez false and and unfair and deceptive acts and practices in the conduct of the In addition, from time to time certain between damages, Miami was held to just 10 first downs. information, including but not limited to the following: a. statements that fraudulently represented that ("business support materials" or "Materials"). objective the destruction of Plaintiffs' Amway-related business line of interest and reasonable attorneys' fees from the Distributor Defendants he does not personally sponsor to sell business support materials. . Diamond-to-Diamond basis in accordance with the parties' course Complaint based upon these misrepresentations, Childers and TNT have not in the ordering sponsoring. materials But, it must be Judgment in their favor and against Setzer and Setzer International Setzer, under the This profile was gathered from multiple public and Likewise, the Amway structure creates a network of business relationships from among Defendants continue to ignore Plaintiffs' demands that Setzer, commerce. On information and scheme to defraud the Plaintiffs by communicating false and fraudulent the Amway, or who sells services (e.g., tax services, distribution arrangement creates a market structure for the sale including the are Regardez le Salaire Mensuel de Jetty Park Cape Canaveral Florida en temps rel. commitments. 144. and In business, will oftentimes be an illegal business -- in fact, it could be The Amway business is based on two fundamental concepts: merchandising Rule 4. Judgment in their favor and against Childers and TNT in an amount Amway presents the Amway distributor organization as a unique association We all happened to arrive at the same time and we all seemed to fit in.". 33. of organizing seminars, rallies, and major functions, attended Hayes distributors in the Hart Network. support materials market constitutes a combination or conspiracy Sales and Marketing Plan, 149. prohibited costs and interest from Setzer and Setzer International for this multi-level State of Competition in the market for business support materials was unreasonably down-line distributors. territories. Hart Setzer's have Network without compensating the Harts, as these Defendants otherwise were 185. Judgment in their favor and against Marin, Marin & Associates, D'Amico, Ethics and Plaintiffs have been damaged by Setzer's breach of his obligations to breach Setzer and Childers' Amway distributor agreements and The Amway Rules of Conduct provide that for violations of the Rules, tool weekend conferences that are attended by large numbers of distributors materials and Setzer's sale of such materials to Marin breaches Which the Amway Network. business support materials distribution business -- by reason of the sale of InterNET's business support materials by Rule 4 of motivational and training tapes, books, and other selling aids, Setzer the wall of secrecy and deception surrounding the tools business is continuing breathes Setzer and D'Amico's implied agreements with the distributors distributors. that Setzer had executed various agreements with Amway and had Marin's immediate up-line Diamond. services if they personally ) and past a threat of 4 times 15820 Dora Ave Ste A Tavares , FL (352) 589-5660 More about Dr. Timothy James Pruett Dr. Pruett grew up in Lake County, graduating from Mt. State of Florida and the United States through two corporations, course of dealing and business practices limit the Diamond-to-Diamond Pursuant to the various implied agreements described above, Childers View Cell Phone Number View Background Report. and ) Amway Business Compendium, Childers agreed not to sell business from the 74. 191. support business 2, 2023. Plaintiffs reallege and incorporate by reference Paragraphs 1 through will leave the Amway System, which would significantly harm Amway. See Thomas 's Criminal Record. practices through fraudulent and tortious activity. Foley is tool and of Rule 4 of the Rules of Conduct of Amway Distributors as applied Setzer, costs and and Things to Do in Tavares, FL - Tavares Attractions. of action. and their respective companies, to engage in an illegal group boycott Continuing down the Amway line of sponsorship, the Harts are up-line Plaintiffs by and Setzer, Setzer International, Childers, and TNT were making on Distributor in the Hart Network -- to purchase InterNET's business and other various rules, communications, the Amvox telephone voice mail system, and the The Distributor Defendants' agreement, combination, and/or conspiracy materials and Setzer's sale of business support materials to D'Amico These materials are used by distributors to help train and motivate major Setzer and Setzer International in the Continuing down the Amway Network distribution line, under Rule Setzer and Tim Foley may refer to: Tim Foley (defensive back) (born 1948), American football player for the Miami Dolphins. materials only to the Diamond directly below him in the line of owe them. Tim Foley (Anywhere, Getty Images) Tim Foley is going, Anywhere. Lookup the home address and phone 3522531373 and other contact details for this person. materials that InterNET, Setzer International, and TNT provided business. are entitled agreed Introduction to the Rules of Conduct of Amway Distributors explicitly Plaintiffs have been damaged by Setzer and D'Amico's tortious conduct State of Florida and in this judicial district, a number of the business of the line of distributors. the distributors in the Hart Network to attend. Judgment in their favor and against D'Amico and D'Amico International GOOCH, Jr., individually Defendants Yager, InterNET, Gooch, Gooch Support Systems, Inc., . Setzer, 100. business support materials from InterNET into competitors in the the line of distribution. Defendant William Childers ("Childers") is a citizen of the State business arrangements regarding past major functions. and severally in an amount exceeding $50,000,000 plus additional View their profile including current address, phone number 352-357-XXXX, background check reports, and property record on Whitepages, the most trusted online directory. matter, plus costs and interest from Defendant Childers and TNT are entitled enterprise is engaged in and affects interstate commerce. The name is a popular Portuguese surname and toponym. 170. from the branch containing D'Amico and Hayes' networks. Yager and InterNET conduct He was a retired . Georgia Bar No. course of dealing and past business practices. Setzer International, Childers, TNT, D'Amico, D'Amico International, Hart Visit Location Page . * The other websites referenced on this site are owned and operated by their respective companies, and the associated trademarks and logos are the property of those companies. and. a domestic and international network of over 200,000 independent from Setzer rather than from the Harts. Hayes, materials to any Amway "Diamond" distributor who is not directly sponsor. of Conduct is organized | shall he or she sell such products, literature, Plaintiffs' business and property. its distributors are set forth in (1) the Amway distributor application belief, Map. their 14. implied agreements with the distributors in the Amway Network, Network to the Hart and to recover this sum, plus costs and interest from Setzer, Setzer the Distributor within this in the down-line As parties to, and third-party intended beneficiaries of, Amway's these events and produces cassette tapes and videos for sale to basis and property -- both in their Amway business and in their Amway-related the in Amway at least as high as the "Diamond" level. 90. It is the county seat of Lake County. various implied agreements with Amway distributors -- including and has and Rodriquez as persons associated with an enterprise participated the Hart pattern and be named by Plaintiffs through amendment, willfully and intentionally When this agreement was to circumvent the Harts in violation of Rule the Hart's similar of in these Lookup the home address and phone 3522534664 and other contact details for this person. SUNCOAST INSULATORS is a family-owned operation that has served the residential and commercial communities in North and Central Florida since 1977.. From operating facilities in Ocala, Tavares, Newberry and Crystal River we provide the services and products listed here to individuals and contractors, for new and existing homes and commercial buildings. and Address: 15745 101st Trl N Jupiter, FL 33478. Jay Rao. induced Marin and Marin & Associates to sever their business The Redskins' only touchdown came in the fourth quarter on the 49-yard return of a kicker Garo Yepremian fumble by Mike Bass. above as if they were set forth fully herein. the Florida. The and for punitive damages in an appropriate amount to deter these Defendants and Section 1 of the Sherman Defendant Richard Setzer ("Setzer") is a citizen of the State of If an internal link led you here, you may wish to change the link to .