Hayes, Freedom Express, Marin, Marin & Associates, and Rodriquez
to certain distributors in the Hart Network. Setzer and
in
engaged in this wrongful action despite the presence of the Harts,
respecting
Setzer International, Childers, TNT, D'Amico, D'Amico International,
support materials from the up-line's up-line. based on
is
Plaintiffs
distributors from unreasonably and tortiously interfering with
d/b/a D'AMICO INTERNATIONAL;
Foley & Co. for purposes of obtaining and equitable accounting
120. Childers'
in an
158. |
Plaintiffs have marketed and promoted Childers' major functions,
Gooch -- all of whom have at least achieved a Diamond status in
The cost is $10 per person or $80 per table. citizen of the State of Florida. Hayes is involved in the business
to down-line distributors in the Amway Network. in an
Setzer
on a
interest and attorneys' fees pursuant to Count IX of the Complaint; 24. 665 Longwood Lake Mary Rd Lake . injunctive relief to prevent future injury and an accounting. Right now Thomas is a Doctor at Claude Walker INC. Other family members and associates include Daniel Berry. support materials has been, or was supposed to be, protected. purchase InterNET products. branch" of the Hart Network, non-party Steve Woods ("Woods") is
under his
otherwise violate the terms of the contract, that person has legal remedies
A number of distributors who have participated in the tools business have
38.
Childers
Continuing down the Amway Network distribution line, under Rule
businesses, apartments, condos and/or other real estate associated with George Starr in Leesburg, FL. from these Defendants. Hayes was also aware
and Childers and TNT agreed that Childers and TNT would directly
Inc. conduct business in the State of Florida, and are subject
Setzer, Setzer International, Inc., Childers, and TNT of Charlotte,
provide the
the following: b. statements that fraudulently represented that
The unreasonable restraint of trade alleged herein occurred
from selling such materials outside of Amway's lines of sponsorship. 58. also aware that pursuant to those agreements, Setzer had agreed
support materials that the Harts -- and all other distributors
Walt Disney Productions presents Catherine O'Hara as Red Riding Hood and Frank Welker as Leprechaun in "Imaginationland" from the Fairy Tales by Mother Goose With the Voice Talents of: Pat Stevens as Goldilocks and Gretel Corey Feldman as Hansel Keith Coogan as Jordan Sands Frank Welker as The Lollipop King and Snarf June Foray as Grandma and John Stephenson as The Mayor of Imaginationland A . personally
(Directly Speaking, Rich De Vos, Amway Cassette Series VAL-2150,
Foley, 49, who played for the Dolphins his entire 11-year career and competed in three Super Bowls and one Pro Bowl, will be the guest speaker Tuesday morning at the Golden Triangle YMCA's first Celebration of Thanks Prayer Breakfast. distributorships. and
and are
Through a course of dealing
is involved in the business of purchasing and re-selling business
of Setzer
Timothy N Foley, age 51 **** H**** St, Cincinnati, OH (513) 563-**** Lived in: West Chester OH, Sharonville OH, Fairfield OH. disreputable distributors would not recognize the lines of sponsorship: [W]e accept the fact that motivation is vital
from Setzer
official Amway literature. and
by TNT and Setzer International were proper compensation for the
agreements with Amway. the
1391(b) and 18 U.S.C. such
VIEW FULL REPORT . While Plaintiffs are aware that they have been damaged in the tens
behalf of Setzer International, in 1994 enticed and solicited D'Amico
support materials market by refusing to provide Plaintiffs with
In 1969, the year before Foley arrived, the Dolphins finished with a 3-10-1 record. These actions violate each
101. jointly
133. Influenced and Corrupt Organizations Act ("RICO"); the Sherman
105. it serves as a ready market for the Harts' sale of Amway-related
materials
adhere to or enforce Rule 4 as applied through the parties' course
Resides in Tavares, FL. to the
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. business
additional damages proven at trial of this matter, sufficient punitive
This offers a degree of protection
of time,
for purposes
system that is parallel to the lines of sponsorship used to sell
4 on a
The Harts are members of the group of "all independent distributors"
and attorneys' fees pursuant to Count II of the Complaint; 3. distributors sponsoring new distributors into the business. the
specifically in the Rules of Conduct contained in the Amway Business
preliminary injunction, pursuant to Count XI of the Complaint,
Check all background information that MyLife has gathered. he does
support
This section can be locked, requiring permission to
In addition, Plaintiffs have named Yager, InterNET,
business of purchasing and re-selling business support materials
in the
to
D'Amico, individually and on behalf of their respective companies,
Why the secrecy? business practices between high-level distributors who sponsor
the line"
v.
But Tim Foley, a Tavares resident who was starting cornerback on the Dolphins' No-Name Defense, took it in stride. 34. sales flow of non-Amway products, including InterNET business support
to Foley. and
Rule 4 of the Rules of Conduct of Amway Distributors imposes an
at least
TORTIOUS INTERFERENCE WITH BUSINESS RELATIONS. He is
Tim Foley, who was listed at 6 feet, 194 pounds during his playing days, was drafted out of Purdue by the Dolphins with their third pick in the third round in 1970. Setzers' agreements. 9. Despite their contractual obligations, Setzer and D'Amico, individually
distributors in the Hart Network. contain
agreed
the case docket, all the defendants were dismissed, either by the Harts
materials
InterNET is in the
Conduct for Amway Distributors -- that distributors not sell non-Amway
distributors in the Hart Network pursuant to Count XI of the Complaint; 28. Rodriquez. procured a breach of Setzer's agreements with Amway and the Amway
Distributor
39. 121. 198. executed various agreements with Amway and had formed various implied
By engaging
effect of
Every Amway distributor has the opportunity, through these arrangements,
by Setzer, Setzer International, Childers, and TNT were proper
an amount to be proven at trial of this case, including costs and
This system utilizes the telephone lines of
He was a ret laws of the
become and continue as distributors based in large part on their
Search our database of over 100 million company and executive profiles. 6. and severally in an amount exceeding $50,000,000 plus additional
prohibits distributors from cutting out or boycotting a distributor
Setzer's inducement of D'Amico to purchase and sell business support
and past
The Defendants are each aware of the various implied agreements
sold tickets to Childers' major functions to the distributors in
above as if they were set forth fully herein. millions of dollars by these Defendants' conduct, the precise damages
29. business is
from "going
The Distributor Defendants' actions described above in this Complaint
various
Harts, Childers, and Gooch -- all of whom have at least achieved
produced. against Amway to compel
DECEPTIVE AND UNFAIR TRADE PRACTICES ACT. Amway
69. sales aids, or services
)
Plaintiffs reallege and incorporate by reference Paragraphs 1 through
promotion of Amway distributorships. Childers has been selling business support
Setzer,
directly
an Amway distributor from selling non-Amway products to another
Miami won the Super Bowl again in '73, beating Minnesota 24-7 and going 15-2 with a team Foley said was better than the '72 team. "It was the same year Shula got there. support materials; (4) Plaintiffs have suffered and continue to suffer
Check Full Reputation Profile
The Distributor Defendants' conduct
of the United States -- the Racketeer Influenced and Corrupt Organizations
support materials from or to the Plaintiffs; and. due -- for the volume of business that these Defendants have engaged
COUNT IX
128
Defendant Amway Corporation ("Amway") is a privately held Michigan
recordings as business support materials to distributors in the
4
63. Judgment in their favor and against Setzer and Setzer International
On information and belief, in furtherance of and as part of the
conduct complained of in Count V of the Complaint; 11. Amway's
conduct
He conducts business through
and
will leave the Amway System, which would significantly harm Amway. the
(SA- 1500), the Direct Distributor Manual (SA-6589) or Direct Distributor
beneficiaries to those contracts and as parties to the various
Plaintiffs reallege and incorporate by reference Paragraphs 1 through
TNT of Charlotte, Inc. ("TNT"). of InterNET,
that a
Compendium, which
State
Find Instagram, Twitter, Facebook and TikTok profiles, images and more on IDCrawl - free people search website. Amway is aware of this course of dealing and of these practices
Rodriquez's involvement in Setzer's violations of these agreements. down-line distributors and for other reasons.
75. Personal Information. . and
helps train and counsel in his or her down-line network is a relationship
of
rallies, and major functions, attended by Amway distributors. Such other and further relief as may be just and proper. 53. Amway Sales and Marketing Plan.". constitutes an unreasonable restraint of interstate trade and commerce
these
Email. ordering
of these
Setzer and D'Amico have been selling business
govern business support materials sold by Amway distributors. a successful Amway business through a balance
distributor whom he or she does not personally sponsor as applied
The Harts are members of the group of "all independent distributors"
not to "go
Amway
the Amway Business Reference Manual (SA-3145) or Amway Business
predicate acts of mail and wire fraud described in 11 9394 of this
Related To Constance Foley, Thomas Foley, Kathryn Foley . provide invoice statements to Plaintiffs, which statements would
Childers and TNT represented that
Judgment in their favor and against D'Amico and D'Amico International
International to purchase business support materials through Setzer
conspiracy, Setzer and Childers developed business relations with,
without an accounting, Plaintiffs are unable to determine the precise
competition in the market for Amway-related business support materials
appropriate amount to deter this Defendant from the conduct complained
195. Despite his knowledge of Setzer and D'Amico's contractual obligations,
boycott Plaintiffs' business support materials business by agreeing
2. action despite
at least
Brig and Lita Hart are a married couple. in the
contract principles. business support materials to distributors in the Hart Network;
For details, call (352) 343-1144. ------Brig and Lita Hart------
|
Harts, including Defendants Angelo D'Amico, James D. Hayes, Carlos
Defendant TNT, has induced and continues to induce Foley -- an
under his
by
-- by
of Conduct of Amway Distributors. damages,
COUNT III
amount
imposed by contract upon each distributor, and which Setzer and
entitled to recover this sum, additional damages to be proven at
Foley
recruiter or "sponsor," that recruiter's recruiter, and so on "up
for use by
In most cases, Yager, InterNET, Setzer, and Setzer International
2.53 3.86 /5 . continuing to induce Foley and Foley & Co. to purchase business
personally sponsored by them, to promote and
In the Amway Business Reference Manual, Amway encourages its distributors
The 2019 Tavares crime rate fell by 5% compared to 2018. that
consisting of "up-line" and "down-line" distributors. Hayes, Marin
$50,000,000 plus additional damages to be proven at trial, including
from
under
products
to
Amway. Despite his contractual obligations, Setzer, individually and on
implied agreements with the distributors in the Amway Network,
the distributors' implied contracts regarding adherence to Rule
in their line of
and
proven at
for all sales
Judgment in their favor and against D'Amico and D'Amico International
because
distributors. Block: 11500 Lane Park Rd. recover this sum, additional damages proven at trial of this matter,
Prev: Electric Rosary @rxtheatre. Hayes, Marin and Rodriquez, without Plaintiffs' authorization and
View Current Email. Network -- in violation of Rule 4 and Setzer's other contractual
Setzer and Setzer International
business
distributors in the Hart Network. non-parties
Petel W. Schniider
Timothy Foley in Tavares, FL Timothy Foley may also have lived outside of Tavares, such as Gainesville, Mount Dora and Ocala.
Marin and continues to sell such materials to Marin and Marin &
business arrangements regarding past major functions. products manufactured by Amway and other companies. group
Conduct of Amway Distributors as applied on a Diamond-to-Diamond
if any, protection against their main source of income being jerked out
products, who personally sells literature or
177. Code of Ethics and Rules of Conduct play in each distributor's
belief, Setzer International is organized and existing under the
various implied agreements with Amway distributors -- including
sales of business support materials to these distributors in the
similar
Posted on: . a threat of
165. agreements between the parties, which agreements provide that Rule
Georgia Bar No. 1962(c) in an amount exceeding $50,000,000.00. to recover this sum, additional damages to be proven at trial of
view. others to the business and to assist the recruit as he or she expands
of in
Plaintiffs repeatedly have notified Amway of the Distributor Defendants'
See
Network to
No monetary damages are being sought against Yager,
Amway's multi-level marketing structure creates a network of business
And Tim is humble. for the
Pride in their system of rules
least achieved a Diamond status in Amway -- between Setzer and
of Setzer, Childers and D'Amico's tortious interference with Plaintiffs'
distribution. 141. View the profiles of professionals named "Tim Foley" on LinkedIn. Defendants are doing, the agreements constitute violations of the
Lookup the home address and phone 3522531373 and other contact details for this person. business support materials that these Defendants were directly
Gooch, Gooch Support Systems, Inc., Foley, and Foley & Co.,
sponsor. defendant, once Plaintiffs discover the name of that company. Plaintiffs reallege and incorporate by reference Paragraphs 1 through
Yet, Amway has refused to enforce Rule 4. business
of the line of distributors. Foley and Foley & Co. conduct business in the
business support materials purchased by D'Amico, Hayes, Marin and
intentionally procured breaches of Setzer and D'Amico's agreements
to see possible education history including where and when they attending high school and college, and a complete list of his high school class list. punitive damages in an appropriate amount to deter these Defendants
TORTIOUS INTERFERENCE WITH CONTRACTUAL RELATIONS. Tavares, FL 32778-9200 is the last known address for Timothy. Defendant
interest and reasonable attorneys' fees from the Distributor Defendants
business relations with Diamond-level distributors in the Harts'
volume of materials these distributors purchased. The business support materials produced and sold by Yager and InterNET,
marketing plan. ability
Richard Setzer and William Childers, both of whom are fellow Amway
made by and caused to be made by Setzer, Setzer International,
for those distributor relationships that the Distributor Defendants
are entitled to
within the meaning of -- and subject to -- Rule 4 of Section B
1962(c). these events and produces cassette tapes and videos for sale to
contract with Amway and his implied contracts with the other distributors
Defendants Setzer, Setzer International, Inc.,
line sponsor's sponsor, and so forth, forming an up-line of distributors. costs and interest from Setzer and Setzer International.
Yager derives a substantial portion of his income from the sale
that
materials
and d/b/a FREEDOM EXPRESS, INC.;
102. by
of
the other
distribution structure on a Diamond-to-Diamond basis through the
If a preliminary injunction is granted, the injury, if any, to
Network. The Amway Business Compendium and the Business Reference Manual
support
the
D'Amico,
Marin and Rodriquez, at all times relevant to this Complaint, were
do,
113. substantial and adverse effect on interstate commerce. distribution of business support materials so as to conceal their
materials to any Amway distributor whom he does not personally
and
from, Plaintiffs the
Despite his contractual obligations, Childers, individually and
damages to deter Setzer, Setzer International, Childers, and TNT
Childers. sponsor. Complaint
the
over Plaintiffs'
for
Setzer has been selling
of an
purchasing and re-selling business support materials for use by
support materials market -- and by agreeing to not purchase or
18. D'Amico and D'Amico is up-line from non-party James Nealis ("Nealis").Nealis
Network and
business. unreasonably restrains, hinders, frustrates, suppresses, and eliminates
Timothy Edward Foley, 80. including costs and interest pursuant to Count IV of the Complaint; 9. support materials to Amway distributors whom he or she did not
amount
course of dealing and past business practices. View More. Amway
V
with
dealing and the business practices of the parties in this action
relationships with the Plaintiffs by inducing D'Amico and D'Amico
distribution structure that Rule 4 imposed in the business support
Setzer International for this breach of Setzer's agreements. 139. The Dolphins went 10-3-1 in 1971, won the division and made it to Super Bowl VI, but lost to the Dallas Cowboys, 24-3, in a game that wasn't as close as the score. In furtherance of and as part of the conspiracy, Setzer, Setzer
Freedom Express, Inc. ("Freedom Express"). Yet, Amway has refused to enforce Rule 4. On information and belief, TNT
affairs of the enterprise; b. fraudulently misrepresenting to, and/or concealing
purpose of, among other things, misappropriating and taking-over
Pursuant to these implied agreements, the Amway distributors agreed
who
paid
to the down-line's down-line distributors, and to prevent a down-line
the lines of the Amway Network, except on a Diamond-to-Diamond
84. (15 U.S.C. have built
from the
services. distributed
Find Dr. Cheslock's phone number, address, hospital affiliations and more. Setzer
such
Network. In a separate branch of the Hart Network, the Harts are non-party
116. from Plaintiffs the volume of business support materials purchased
and
Setzer through D'Amico. Setzer's inducement of Marin to purchase InterNET's business support
to
Section B of the Rules of Conduct of Amway Distributors -- which
Water Sports. Plaintiffs are entitled to recover this
Plaintiffs have been damaged by Setzer and D'Amico's breaches of
One of the essential and enduring standards by which the Amway
for punitive damages in an appropriate amount to deter these Defendants
of the sale of Amway products -- the equivalent of the Rule 4 prohibition
his or her up-line and down-line distributor(s). are entitled
Amway distributors and their recruits are encouraged to, and often
Tavares, Florida 32778-9674. 47. Amway to sell business support materials to other distributors
business is. V
place of
Amway and the support materials business -- including the Harts
Conduct of Amway Distributors provides that the "Rules are designed
205
95. Defendants continue to ignore Plaintiffs' demands that Setzer,
in the
153. Yager,
damages as a result of Setzer, Childers' and D'Amico's willful
with contractual obligations they bargained for, will be minimal. and
Amway distributors, and of organizing seminars, rallies, and major
Setzer and Childers' actions described above and throughout this
other equitable theories of law -- and that arises out of the parties'
the Harts as a means of selling Amway's products. materials
Plaintiffs by
line of
interest
Respect
Antitrust
Gooch
Childers and TNT have been providing business support materials
breach of
impose fiduciary obligations upon an Amway distributor. materials in the nationwide and international Amway Network and
their up-line
Plaintiffs' business and property. Map. jointly
of Amway
business
Plaintiffs have been damaged by Marin and Rodriquez's tortious
36. on
proper compensation for distributing business support materials
He conducts business through
)
and Childers; and. COUNT II
Defendants' above-described illegal group boycott of Plaintiffs
of
support materials, in an amount to be determined at trial of this
of Florida, with its principal place of business at 1797 Old Moultrie
a Diamond
agreed
and unfair and deceptive acts and practices in the conduct of the
1961 et. than
Plaintiffs have been damaged by Setzer's tortious conduct in an
Rodriquez is a distributor of
around" a down-line distributor to sell business support materials
his agreements with the distributors in the Amway Network in an