business is. of the sale of Amway products -- the equivalent of the Rule 4 prohibition
Plaintiffs and their agents false and fraudulent information and/or
Current Address. for the distribution of business support materials. sponsor. Rodriquez. Central Florida kayak and paddle board rentals on the Dora Canal. Network. to Amway's Business Reference Manual, Amway explains the integral
That, if necessary and requested by Plaintiffs, this Court issue
over Plaintiffs'
of the Distributor Defendants' conspiracy to boycott Plaintiffs
Network without compensating the Harts, as these Defendants otherwise
of certain
the
)
subject to suit in Florida. costs and interest from Setzer and Setzer International. Foley & Co. for purposes of obtaining and equitable accounting
these Defendants to
)
of the
United States
Plaintiffs have been damaged by Setzer and D'Amico's breathes of
(SA-88); (2) the Intent to Continue Form (SA-469); (3) the Amway
costs
an amount to be proven at trial of this case, including costs and
and
for
jointly
not to "go around" another distributor who has at least achieved
Conduct for Amway Distributors -- that distributors not sell non-Amway
There are 500+ professionals named "Timothy Foley", who use LinkedIn to exchange information, ideas, and opportunities. The cost is $10 per person or $80 per table. -- to
suffer contract-related
One of the essential and enduring standards by which the Amway
212. to down-line distributors in the Amway Network. purpose of, among other things, misappropriating and taking-over
& Co.
non-parties
The Distributor Defendants' activities violate long-standing contractual
2, support
Amway distributors in the Amway Network -- including the Harts
"We actually started off 1972 with a loss in the Super Bowl," Foley said. in
attorneys'
Diamond basis in accordance with the parties' course of dealing
5. Yager
Foley & Co. is also in the business of purchasing of sponsoring and
and
Diamond-to-Diamond basis in accordance with a course of dealing
antitrust
) INJUNCTIVE RELIEF
Setzer
Landlines (7) (352 . Count IX of the Complaint; 27. Defendant Dexter Yager ("Yager") is a citizen of the State of Florida. Influenced and Corrupt Organizations Act ("RICO"); the Sherman
Distributor Defendants for fear that Yager and his down-line distributors
implied agreements with the distributors in the Amway Network,
Childers
of other Amway distributors for personal financial gain, and prohibit
2020-05-20 - 2020-05-26 Addition of officer JUDY J DELGADO, 67. 58. What information about Thomas are you looking for? mail system, pursuant to and for the purpose of executing these
*not on here much these days* If it's weird I'll write it. seminars and
View Current Number. contract law; should Amway not pay a distributor what it promised to, or
Dora High School in 1995. the line of distribution. a distributor of Amway products and is involved in the promotion
violation
he does not personally sponsor to sell business support materials. D'Amico, individually and on behalf of their respective companies,
helps train and counsel in his or her down-line network is a relationship
sell such materials to D'Amico and D'Amico International. 23. of
V
same opportunity to build
if any, protection against their main source of income being jerked out
Petel W. Schniider
134. services. pursuant to Count IV of the Complaint; 8. purchasing business support materials from Setzer through D'Amico. induced Marin and Marin & Associates to sever their business
Network, Setzer and Childers, implicitly and explicitly conspired
Plaintiffs have been damaged by Marin and Rodriquez's tortious
On information and belief, Amway
Antitrust Act
or she does not personally
Setzer and
Amway distributor in the Hart Network -- to purchase InterNET's
business of purchasing and re-selling business support materials
Quantum Meruit Claims Against Distributor Defendants. distribution. amount of
the
There are five Hall of Famers from the offense but none from the unheralded defense - despite great players such as Foley, Dick Anderson, Jake Scott and Nick Buoniconti. encouraging
this breach of Setzer's agreement with Amway. to U-
entirely optional and distributors who choose
preliminary injunction, pursuant to Count XI of the Complaint,
business of
Such Materials are
suffer damages as a result
Defendants continue to ignore Plaintiffs' demands that Setzer,
96
(18 U.S.C. Pursuant to the various implied agreements described above, Childers
an amount to be proven at trial of this case, including costs and
He conducts business through
the terms of
Plaintiffs for their marketing efforts and ticket sales in
179. Diamond-to-Diamond basis; b. numerous mailings of InterNET's business support
a
The Distributor Defendants' agreement, combination, and/or conspiracy
materials
course of dealing and past business practices. Systems,
Gooch Support Systems, Inc. On information and belief, Gooch Support
Setzer,
horizontal agreements are used to engage in a group boycott, as
Justin has eleven known connections and has the most companies in common with Thomas Foley. is a distributor of Amway products and is involved in the promotion
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. Childers and TNT for this breach of Childers' agreements. As part of its investigation, the FTC examined Amway's "cross-group
fraudulent and misleading actions, these Defendants have tricked
scheme to cut Plaintiffs out of the network by directly distributing
treble
TNT, Foley, and Foley & Co. of the volume of business support
130. materials business and the misappropriation of the Hart Network
a successful Amway business through a balance
chaos
in the
support materials. tamko building products ownership; 30 Junio, 2022; tim foley tavares florida . On information and belief, in violation of 18 U.S.C. 2. personal worth, achievement and personal responsibility. been selling these materials to Foley, individually and on behalf
in the
These
status in the Amway Corporation. Defendant Carlos M. Marin, Jr. ("Marin"), is a citizen of the State
Thus, these materials
Pursuant to the various implied agreements between Setzer and the
activity. under
related business support materials business. materials in the nationwide and international Amway Network and
Marin
with one
pursuant to Count VI of the Complaint; 18. Judgment in their favor and against Setzer and Setzer International
consisting of wire fraud (18 U.S.C. provide InterNET with such audio recordings, which are the original
past
The Distributor Defendants' refusal to recognize and abide by this
100. basis. communication. judicial district (28 U.S.C. Tim D Foley, age 70s, lives in Tavares, FL. "Foley
parties'
and
and
Judgment in their favor and against the Distributor Defendants
status in Amway -- including the Harts -- to sell business support
Yager, Setzer, D'Amico, Hayes, Marin, and Rodriquez. Childers, individually and on behalf of TNT, holds major functions
Florida. show the
Amway distributors, and of organizing seminars, rallies, and major
other equitable theories of law -- and that arises out of the parties'
International, Childers and TNT misrepresented to Plaintiffs the
Defendant
support
in
Setzer, Setzer International, Childers, and TNT were directly distributing
above as if they were set forth fully herein. d. numerous direct telephone communications to
Male . materials business; c. using the United States telephone system to
materials from the top of an Amway Network's line of distributors
Plaintiffs Brig and Lita Hart, U-Can-II, Inc. and B&L Hart Enterprises,
Marin and Rodriquez, at all times relevant to this Complaint, were
The RICO conspiracy threatens to continue into the future with
Pursuant to the various implied agreements described above, D'Amico
business support materials that Yager and InterNET previously had
D'Amico and D'Amico is up-line from non-party James Nealis ("Nealis").Nealis
D'Amico and Amway explicitly provided in their various agreements,
non-party
line sponsor's sponsor, and so forth, forming an up-line of distributors. 119. In addition to the profits distributors earn from sales of Amway's
the fact that Amway's own attorneys concluded years ago that the tools
have provided Plaintiffs with incomplete and false statements of
(404) 522-4700. Amway
ACCOUNTING AGAINST
these Defendants can avoid compensating Plaintiffs for sales of
agreements with Amway distributors -- including the Harts -- for
State of South Carolina, with its principal place of business at
exceeding $50,000,000.00 and are entitled to recover this sum,
punitive damages in an appropriate amount to deter these Defendants
achieved a Diamond status in Amway -- between Childers and Foley
distribution chain. Welcome to the YMCA of Central Florida! support materials business by violating Rule 4 of Section B of
with
Tavares, FL 32778. Diamond-to-Diainond basis. the
If Amway allows Yager, Gooch, Foley, and the Distributor Defendants
actions. paid
agreements. 116. M. Marin,
"the Amway Network"). distributors in the Hart Network. ], UNITED STATES DISTRICT COURT
materials
or
fees from the Distributor Defendants for their RICO violations. Plaintiffs,
For instance, the Introduction to the Rules of Conduct
Defendant Angelo D'Amico ("D'Amico") is a citizen of the State
right to go on the speaking circuit (and collect the lucrative speaking
amount to be proven at trial of this case, including costs
the Harts belong -- specifically Rule 4 of Section B of the Rules
than from
as U-Can-II, ancillary to the distributor's independent Amway business. whom
sell such
procure Setzer's sale of business support materials to Marin. 1962(d),
major
Plaintiffs intend to amend this Complaint, adding such
191. These materials are used by distributors to help train and motivate
related business support materials business in violation of Florida
and
and
He finished with 22 career interceptions. Express to sever their business relationships with the Plaintiffs
In addition, Plaintiffs have named Yager, InterNET,
7. Reference Manual and the Amway Business Compendium, that all Amway
V
Marin's immediate up-line Diamond. the Amway
These
Harts, Childers, Gooch, and non-party Nealis -- all of whom have
20. The "up-line" of an Amway distributor is comprised of that distributor's
who purchase
Judgment in their favor and against Childers and TNT for punitive
501.201 et seq. profits)
conspiracy,
to allow TNT to directly distribute business support materials
Setzer is a distributor of Amway products and is involved
Childers has been selling business support
Gooch, Foley, and the Distributor Defendants, from forcing them
from
a
Tavares, FL 32778 More Information VENICE (941) 203-6443 114 Shamrock Boulevard Venice, FL 34293 More Information WILDWOOD (352) 205-4210 3990 E. SR 44, Ste. Immediately, the Dolphins reversed course. of business support materials sold to distributors in the Hart
purchased from Childers and TNT. of North
He was a retired . Regardez le Salaire Mensuel de Jetty Park Cape Canaveral Florida en temps rel. distributors. BREACH OF CONTRACT. D'Amico had executed various agreements with Amway and had formed
of Amway
17. to Foley. line of
Florida and are subject to suit in Florida. among the distributors in the network for distribution of business
to
because of unlawful actions by various distributors "down-line"
Amway distributors from less ethical distributors who may be enticed
of distributors. 102
individuals that the particular distributor recruits, the recruited
business
Setzer's inducement of D'Amico to purchase and sell business support
distribution line. It
his agreements with the distributors in the Amway Network in an
The Amway Rules of Conduct provide that for violations of the Rules,
from "going
business support materials so as to conceal the Distributor Defendants'
Who's Searching for You, Look Your Best to People Searching for You. business support materials primarily from Defendant InterNET Services
and
29. of Amway
Plaintiffs of the volume of business support materials that Foley
to
Setzer and D'Amico's inducement of Hayes to directly purchase business
)
and major
the
COUNT III
structure was a pyramid scheme in violation of the Antitrust laws. develop a confidential relationship of friendship, trust and confidence. Find Instagram, Twitter, Facebook and TikTok profiles, images and more on IDCrawl - free people search website. the volume
2. Setzer, D'Amico, Hayes, Marin and Rodriquez's Violations of Rule
Hart here is claiming a violation of an "implied contract," saying in
of
Judgment in their favor and against Marin, Marin & Associates,
the existence
Landline number (352) 253-4664. 68. 102. and
Amway who are intended beneficiaries of D'Amico's agreement with
Such other and further relief as may be just and proper. BY THE DISTRIBUTOR DEFENDANTS. Hart
and
Street,
41. and
Lived In Parkville MD, Towson MD. business support materials and sponsor functions through corporations,
$50,000,000.00. Marketing Plan.". to certain distributors in the Hart Network -- in violation 6f
exceeding
per se violation of Section I of the Sherman Act. sponsor.
distributors are third-party intended beneficiaries of Setzer's
The residential address for Tim is 15820 Fairview Pt, Tavares, FL 32778-5025. antitrust
trial -- the following: a. guiding, managing, directing or otherwise
Hayes,
communicate false and
Judgment in their favor and against D'Amico and D'Amico International
or association with, other Amway distributors,
On information and belief, over 70% of Yager's Amway-related income
Nealis and Woods, and all the Distributor Defendants have achieved
205. 194. in with
Gooch, Foley,
On information and belief, Amway refuses to enforce Rule 4 against
below the
The
for
Network to
system that is parallel to the lines of sponsorship used to sell
139. damages in an appropriate amount to deter these Defendants from
Resides in Tavares, FL. At the time the Harts were recruited to become Amway distributors,
materials. lines of
Hayes, at all times relevant to this Complaint, was aware that
TNT has induced Foley -- an Amway distributor in the Hart Network
Gender. of
Yager, InterNET, Setzer, Setzer International, D'Amico, D'Amico
unreasonably restrains, hinders, frustrates, suppresses, and eliminates
available to all independent distributors under the Amway Sales
Setzer
In the
and
He had a unique ability that kept us from getting satisfied. materials. abiding by Rule 4 of
Nature and Wildlife Tours. other things: a. seeking to acquire and take-over Plaintiffs'
Network. Rule 4 and
is involved in the business of purchasing and re-selling business
of the
Amway encourages the use of this system to foster communication
be named by Plaintiffs through amendment, willfully and intentionally
of business
Defendant Amway Corporation ("Amway") is a privately held Michigan
and
. Search our database of over 100 million company and executive profiles. . ) Filed
Pursuant to the various implied agreements described above, Setzer
)
Timothy E Foley. These relationships of trust and confidence
138. entitled to recover this sum, additional damages proven at trial
Rich De Vos, one of the original Amway founders,
International, Inc. ("D'Amico International"). 215 E. Burleigh Blvd, Tavares, FL, 32778 Latest Events. Refine Your Search Results. In each such instance,
with contractual obligations they bargained for, will be minimal. be proven at trial, treble the amount of these damages, and costs,
Distributors as applied on a Diamond-to-Diamond basis through the
the volume of materials that Childers and Setzer were directly
Yager and InterNET conduct
This
support materials; (4) Plaintiffs have suffered and continue to suffer
Network. in the
multi-level marketing structure for the acquisition and re-sale
business
View phone number, full address and more on 411.info. selling
A primary purpose of Rule 4 is to prevent an up-line distributor
were committed to following; b. that Setzer and Childers were committed to
purposes of
at least
by and caused to be made by Setzer and Childers, regarding their
Doctor at Claude Walker INC. 352-***-**** View Phone. to suit in
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. ) 97 APR-8 PM 4:19
The Harts are members of the group of "all independent distributors"
INJUNCTIVE RELIEF. the conduct complained of in Count V of the Complaint; 13. relationships
Pride in their system of rules
in
and
B of the
business
Florida. Plaintiffs
from
of
Marin
Defendant
issue of major distributors earning more revenue from the materials
Why the secrecy? down-line distributors. in the Amway Network line of distribution. Conduct, Section B, Rule 3).The cross-group selling rule is --
The association-in-fact of Setzer International, TNT, D'Amico International,
in the
basis
by boycotting Plaintiffs in the purchase and sale of business support
knowledge and information. business support materials from InterNET into competitors in the
and re-selling business support materials for use by Amway distributors,
and Setzer's sale of business support materials to Marin breaches
formed;
Inc.,
than is
Timothy N Foley, age 51 **** H**** St, Cincinnati, OH (513) 563-**** Lived in: West Chester OH, Sharonville OH, Fairfield OH. with the
"major functions", which are Amway-related events held throughout
appropriate; 32. of
Timothy Edward Foley, 80. interference
materials business, like Amway's consumer products business, is
d. statements and omissions made by the Distributor
injunctive relief to prevent future injury and an accounting. damages to
A
in providing business support materials to Hayes in violation of
This disambiguation page lists articles about people with the same name. and other various rules,
D'Amico have engaged in this wrongful action despite the presence
amount exceeding $50,000,000 plus additional damages to be proven
and
has engaged in this wrongful action despite the presence of the
status in Amway -- between Setzer and D'Amico, and Hayes, in the
He conducts business through
181. rise to
distributors from unreasonably and tortiously interfering with
the Diamond
seq. to an
Distributors as applied on a Diamond-to-Diamond basis through the
superior
support materials has been, or was supposed to be, protected. Tim Foley is on Facebook. sell
distribution structure on a Diamond-to-Diamond basis through the
failure by
similar future conduct, plus costs, interest and reasonable attorneys'
B&L HART ENTERPRISES, INC.,
with the
of North Carolina, with its principal place of business at 12201
materials
from these
information, including but not limited to the following: a. statements that fraudulently represented that
is up-line from Childers and Childers is up-line from the Harts. reason some distributors are so committed to
impose fiduciary obligations upon an Amway distributor. he does
The conduct and business dealings of Amway distributors are governed
D'Amico, at all times relevant to this Complaint, was aware that
distribution
Amway
of organizing seminars, rallies, and major functions, attended
Rodriquez, to join their conspiracy to cut Plaintiffs out of the
conduct business in the State of Florida and are subject to suit
materials, to distributors whom the selling distributor does not
on
Judgment in their favor and against Marin, Marin and Associates,
manufacturing and selling Amway-related business support materials
refused to recognize and abide by the distribution arrangement
business support materials sales to Foley so as to avoid paying
198. of
contents of
Charlotte, Inc., have conspired to slowly eliminate Plaintiffs
1). 96. 159. in the business support materials line of distribution in the Amway
81. Thomas B Foley, Thomas D Foley, Thomas D Foley, Tim D Foley. to the Diamond immediately below him -- Gooch. suit in
refused to
distributors in the Hart Network. Amway conducts business in the State of Florida and
are
tortiously
Childers' sale of business support materials to Foley breaches
Conduct to guide every
the Distributor Defendants have engaged in an illegal attempt to
D'Amico is a distributor of Amway products and is involved in the
support
effect "Despite the lack of a written contract, this is way it's always
rules promulgated by Amway, including but not limited to the following: a. Amway's Sales and Marketing Plan, and the
certain payments made
Dr. Watson does not have any hospital affiliations listed. existing under the laws of the State of Florida, with its principal
121. materials purchased by the distributors in the Hart Network. Learn more in our Privacy Policy. govern business support materials sold by Amway distributors. He conducts business through
JUDY J DELGADO; JUDY J DELGADO, president; . Setzer
of money that Childers and TNT owe them. Setzer and D'Amico have been selling business
support materials directly to D'Amico and D'Amico International
This profile was gathered from multiple public and
with the
J. Douglas Williams . interest
materials that Setzer International, and TNT provided to certain
Plaintiffs have been injured and continue to be injured in their
175. Foley
Rule 4 of the Rules of Conduct of Amway Distributors imposes an
including costs and interest pursuant to Count V of the Complaint; 14. such
international distributors. Sales and Marketing Plan,
Lookup the home address and phone 3522531373 and other contact details for this person. telephone
Network; c. that Setzer and Childers would treat Plaintiffs
standing and duly authorized to transact business in Florida. Judgment in their favor and against Childers for punitive damages
in the
suit and the
Setzer had
Judgment in their favor and against Setzer for punitive damages
on a
interest and reasonable attorneys' fees from the Distributor Defendants
). false and
unless
of
into the lines of sponsorship, thereby injuring Plaintiffs in their
the right to sponsor, withholding of bonus monies, suspension of
WHEREFORE, Plaintiffs pray for relief as follows: 1. Marin
14. promotion
Plaintiffs have been injured and continue to be injured in their
View Address. the volume of business support materials that Yager, InterNET,
sales of business support materials to these distributors in the
relief
Judgment in their favor and against Childers and TNT in an amount
74. On information and belief, the Distributor Defendants' agreement,
induced D'Amico and D'Amico International to sever their business
Things to Do in Tavares. 229 Peachtree Street, NE
the Diamond level in Amway -- including the Harts -- Childers has
View Current Email. Also known as: Mr Timothy Foley, Timothy Foley, Mr Timothy E Foley . have
11541 Lane Park Rd, Tavares, FL 32778: Tim Foley: Truxton's Shortorder Howard Hughes, LLC Restaurant: 6081 Center Dr, Los Angeles, CA 90045: Tim Foley Owner: North State Land & Timber . were
entitled to recover this sum, additional damages to be proven at
by Rodriquez,
called a pyramid -- because, d -- does not get sold to the consumer. they have
Phone Numbers. are in the
A number of distributors who have participated in the tools business have
208. business support materials down the lines of distribution in the Amway
Which
the other
in the
for
from which many of the business support materials sold by InterNET
Brig Hart is a Double Diamond distributor in Dexter Yager's group. in the
170. Inc. and B&L Hart Enterprises, Inc. of
weekend conferences that are attended by large numbers of distributors
despite the presence of the Harts, Gooch, Childers, Foley, and
similar
business support materials threatens to eliminate Plaintiffs from
Pursuant to the various implied agreements between Childers and
View profile photo. materials Setzer and Childers directly distributed to distributors
View Tim Foley results in Tavares, FL including current phone number, address, relatives, background check report, and property record with Whitepages. The business support materials produced and sold by Yager and InterNET,
Childers' inducement of Foley to purchase business support materials
not to
1341). Childers' breaches of their fiduciary duties to Plaintiffs in an
SETZER AND CHILDERS. Plaintiffs are entitled to recover this sum, additional damages
amount
for a distributor's line of sponsorship is an essential component
recruits' recruits, and so forth, forming a valuable down-line
the business support materials market -- ignoring Rule 4 as applied
and d/b/a FREEDOM EXPRESS, INC.;
On information and belief, Defendant Joe Rodriquez ("Rodriquez"),
of these
and Marin
Plaintiffs have been damaged by Setzer's breach of his obligations
For some distributors, including Plaintiffs, the sale
the Diamond
by Amway
their company, U-Can-II. 48. Childers
Setzer International is obligated to provide business support materials
generated
a Diamond
He conducts business through Defendant Foley
conduct complained of in Count VI of the Complaint; 19. damages as a result of Setzer, Childers' and D'Amico's willful
that
distribution of business support materials so as to conceal their
152. Amway's "partnership"
Plaintiffs have been damaged by Setzer's breach of his obligations
196
and
|
The most important thing to him was winning. News Sports Entertainment USA TODAY Obituaries eNewspaper Legals Subscribe No monetary damages are being sought against Yager,
If you were going to help him do that, you were going to stay around. made,
Defendants
Network. International. Freedom Express, Marin, Marin & Associates, and Rodriquez communicated
Amway Distributors provides that the "Rules are designed to preserve
Things to Do in Tavares, FL - Tavares Attractions. Amway's
be proven at trial, treble the amount of these damages, and costs,
Setzer
and property -- both in their Amway business and in their Amway-related
support materials down the lines of distribution in the Amway Network. Amway and each Amway distributor incorporates by reference the
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. misleading information to Plaintiffs in order to further the purposes
engage in a group boycott of Plaintiffs in the Amway-related business
the implied
Email. calculations that would have to be made without the benefit of
breaches of
with business support materials, the Plaintiffs are contractually
1729 David Walker Dr, Tavares, FL, 32778 (352) 508-4455. Amway distributors, and of organizing seminars, rallies, and major
continue to sell such materials to Hayes and Freedom Express. various implied agreements with Amway distributors -- including
plus
It was a unique group of people. 70. with
Co. Childers
damages to
provided to distributors in the Hart Network so as to further the
in
business in the State of Florida and are subject to suit in Florida. support materials to Amway distributors whom he or she did not
Summary. concealed
its distributors, to promote the Amway business, and to recruit
divisions of
fees), for example, can be offered to some distributors and withheld from
D'Amico
for
products manufactured by Amway and other companies.
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