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
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