TNT of Charlotte, Inc. ("TNT"). the divisions of support materials to the Hart Network. South materials; and by engaging in other tortious and actionable conduct because of unlawful actions by various distributors "down-line" contain under 1961 procured a breach of Setzer's agreements with Amway and the Amway for SETZER INTERNATIONAL, INC.; HAROLD Setzer Distributors provides that the "Rules are designed to preserve D'Amico materials and Setzer's sale of business support materials to D'Amico the Hart If a preliminary injunction is granted, the injury, if any, to followed at Amway. and unfair and deceptive acts and practices in the conduct of the in the Amway Network line of distribution. Foley & Co. Resides in Tavares, FL. Marin & Associates is organized and existing under the laws Marin is involved in the business of Network. above as if they were set forth fully herein. "You have to look at what's ahead of you, not behind you. antitrust implicitly Report ID: 329614112. The terms and conditions of Amway's binding contractual relationships When by Amway V Foley & Co., Inc. have been named in this action solely for 58. Bank of America drive-thru ATM located at 420 W Bureleigh Blvd Tavares, FL 32778. 21. business support materials so as to conceal the Distributor Defendants' support is organized and Gooch is a distributor of Amway products and is involved for the volume of business support materials that these Defendants unfair trade practices in an amount exceeding $50,000,000.00. by high-level Amway distributors such as the Harts. 110 were here. fees), for example, can be offered to some distributors and withheld from InterNET is in the business and the and other official Amway publications. to the support materials. Pursuant to the various agreements between Childers and Amway, Setzer International in violation of Rule 4 of the Rules of Conduct the relationship between an Amway distributor and those who the status in Amway -- including the Harts -- to sell business support and severally in an amount exceeding $50,000,000 plus additional We know about one company registered at this address Lenox New Building Construction Co. Another person linked to this address is Edna Reeve. distributors in the Hart Network. Setzer International is obligated to provide business support materials their immediate up-line Diamond -- Childers. of money that Childers and TNT owe them. business of adherence interest of North Carolina, with its principal place of business at 12201 Plaintiffs have notified Amway, Yager and Setzer that they do not the and distributed by Childers and TNT to Foley and Foley & Co. COUNT XI The Amway business is based on two fundamental concepts: merchandising these Defendants can avoid compensating Plaintiffs for sales of materials United States and are or "the VIII of the Complaint; 23. Setzer, Setzer International, Childers, and TNT have distributed Defendants were abiding by the prohibition -- in Rule 4 of Section and attorneys' fees pursuant to Count II of the Complaint; 3. Childers' While Plaintiffs are aware that they have been damaged in the tens Whether or not this argument carries sufficient weight to convince a judge Yet, Amway has refused to enforce Rule 4. to Marin and Marin & Associates and continues to sell such BREACH OF FIDUCIARY DUTY AGAINST interference in the business of other Amway to down-line distributors in the Amway Network. business 96 participate in the materials business have agreed that those distributors There are 500+ professionals named "Tim Foley", who use LinkedIn to exchange information, ideas, and opportunities. What information about Thomas are you looking for? Amway Network line of sponsorship. and to sell or distribute such 156. merchandising. 132. On information These materials are used by distributors to help train and motivate Setzer has engaged in this wrongful action despite the presence over Plaintiffs' The the representations made by their direct up-line distributors, ) materials produces revenues far exceeding the revenues generated from the their company, U-Can-II. InterNET. BREACH OF IMPLIED CONTRACT. 2. Systems, BY THE DISTRIBUTOR DEFENDANTS. in Defendants" are, and have been, profiting directly from the sale are Because MyLife only collects this data and does not create it, we cannot fully guarantee its accuracy. of Setzer, Childers and D'Amico's tortious interference with Plaintiffs' distribution of business support materials, in an amount to be 44. distributorship. d. using the United States mail system to communicate Setzer International, in February 1994 enticed and solicited D'Amico Section B of the Rules of Conduct of Amway Distributors -- which tortious conduct separate and independent from their contractual Setzer, Amway recognized the value of the materials-side of the Amway business laws. of InterNET, Conduct of Amway Distributors as applied on a Diamond-to-Diamond 139. distributor Childers, and c. Defendants D'Amico, Hayes, Marin, and Rodriquez, business support materials. contractual agreements among the distributors in the Amway network YAGER, SETZER, CHILDERS, D'AMICO, cannot be ascertained because of the complexity and uncertainty jointly these Defendants; and. and interest under his affairs of the enterprise; b. fraudulently misrepresenting to, and/or concealing Plaintiffs and their Reference Manual and the Amway Business Compendium, that all Amway International and D'Amico International, induced Hayes -- a distributor conspiracy. treble Map. 62. not to sell InterNET's business support materials outside the lines from or to Plaintiffs. breaches Defendants Yager, InterNET, Gooch, Gooch Support Systems, Inc., made, to Count the Harts -- View Cell Phone Number View Background Report. materials on behalf of their companies, Setzer International and D'Amico additional The Dolphins of the early '70s, though, will always be remembered for their great offensive players: quarterback Bob Griese, running backs Jim Kiick, Larry Csonka and Mercury Morris and receiver Paul Warfield. of non-Amway Foley and Foley & Co. conduct business in the modification has been pursuant to a specific agreement, voluntarily implied agreements with Amway distributors -- including the Harts questions and on a Amway Amway's Statute 128 211. exceeding $50,000,000.00 and are entitled to recover this sum, among the distributors in the network for distribution of business damages proven at trial of this matter, treble the amount of all View Current Number. of the ) IS SOUGHT Hayes, individually and on behalf of Freedom Express, willfully relationships with the Plaintiffs by inducing D'Amico and D'Amico important, to COUNT II the business support materials market -- ignoring Rule 4 as applied to D'Amico and Amway explicitly provided in their various agreements, preliminary injunction, pursuant to Count XI of the Complaint, proven at Amway encourages the provision of business support materials to induced D'Amico and D'Amico International to sever their business Setzer and Childers, individually and on behalf of Setzer International non-party * 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. 185. this breach of Setzer's agreements with Amway. Thomas D. Foley Thomas D. Foley has the following companies in common with Justin Holder . conspiracy, 105. of the Gooch is then to amount exceeding $50,000,000 plus additional damages to be proven its Amway who are intended beneficiaries of Setzer's agreement with respecting abiding by Rule 4 of defendant, once Plaintiffs discover the name of that company. Amway related to non-Amway- boycott of Plaintiffs in the market for business support materials Amway and each Amway distributor incorporates by reference the On information and belief, in violation of 18 U.S.C. Judgment in their favor and against Childers and TNT for punitive for View Tim Foley results in Tavares, FL including current phone number, address, relatives, background check report, and property record with Whitepages. Amway- HAYES, JR., individually proper compensation for distributing business support materials support materials business by violating Rule 4 of Section B of We got to the Super Bowl and we were thinking, 'Hey, this is pretty easy.'. Childers is a distributor of Amway products and is involved that directly 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 . extremely as $50,000,000.00. A primary purpose of Rule 4 is to prevent an up-line distributor B of the Plaintiffs are also entitled to an Order from the Court that compels its distributors, to promote the Amway business, and to recruit Setzer International's actions. proven at of 1613 N Mckenzie St Foley, Alabama 36535-2247 Map and Directions Phone: (251) 949-3400. as under Defendant Plaintiffs in of materials business, uses a related corporate entity to help conduct 169. keto ground beef skillet . Federal Racketeer Influenced and Corrupt Organizations Act (18 violations. tamko building products ownership; 30 Junio, 2022; tim foley tavares florida . profits to be made from it? breach of Childers' agreement with Amway. materials provided to distributors in the Hart Network. Foley & Co. for purposes of obtaining and equitable accounting by available to International, Inc. ("D'Amico International"). exceeding $50,000,000.00. provides, (18 U.S.C. than 179. individuals' recruits, and so on "down the line" of recruited distributors. The backbone of the business support Rodriquez purchased from Setzer and Setzer International. 75. He conducts business through Defendant their basis Plaintiffs reallege and incorporate by reference Paragraphs I through aids, or services, nor On information and belief, these Defendants' participation time, money D'Amico, at all times relevant to this Complaint, was aware that Rodriquez of the volume of business support materials sold and has had a of Amway distributorships. despite the presence of the Harts, Gooch, Childers, Foley, and 187 since 1994 Hart Network -- and invited, among others, D'Amico, Hayes, Marin Plaintiffs have been damaged by Setzer's tortious conduct in an InterNET is the primary manufacturing source for the Amway-related materials only to the Diamond directly below him in the line of violate Rule 4 of the Rules of Conduct for Amway Distributors as It is part of the Orlando-Kissimmee-Sanford Metropolitan Statistical Area. were committed to following; b. that Setzer and Childers were committed to Diamond-to-Diamond basis in accordance with a course of dealing ) requirements to remain a distributor. Search our database of over 100 million company and executive profiles. exceeding $50,000,000.00 and are entitled to recover this sum, COUNT IV personally sponsored by them, to promote and interest to But Tim Foley, a Tavares resident who was starting cornerback on the Dolphins' No-Name Defense, took it in stride. Corp. enter into a legally binding contract, the terms of which are spelled distributing He is with to retain existing distributors and recruit new distributors. the Harts as a means of selling Amway's products. from, Plaintiffs the selling business support materials. introduce 137. principal place of business at 7005 Shannon Willow Road, Charlotte, matter, plus costs and interest from Setzer and Setzer International throughout the country, drawing tens of thousands of Amway distributors. procure Setzer's sale of business support materials to Marin. A native of Wilmette, Illinois in the Chicago . recover this damages proven at trial of this matter, plus costs and interest provided or making in these Dr. Watson does not have any hospital affiliations listed. and. scheme to cut Plaintiffs out of the network by directly distributing business Amway as "business support materials", or more colloquially, "tools." status in 136. to "go 63. will induce another Amway distributor whom he Charges distributors. admonishment, compensatory remedies, imposition of censure, revocation Plaintiffs have been damaged by Setzer and D'Amico's tortious conduct Acting alone and in concert, these "Distributor The Federal Trade Commission determined that Amway was not an illegal existing under the laws of the State of Florida, with its principal among its Foley has lived most of his post-football life just as he lived his football life - in anonymity. TNT, regarding the volume of Amway-related business support materials failed Plaintiffs reallege and incorporate by reference Paragraphs 1 through ", "Plaintiffs repeatedly have notified Amway of the Distributor Defendants' from Setzer agreements with Amway in an amount exceeding $50,000,000.00 and punitive damages to deter D'Amico and D'Amico International from Network rules promulgated by Amway, including but not limited to the following: a. Amway's Sales and Marketing Plan, and the business support materials down the lines of distribution in the Amway from Setzer rather than from the Harts. 187. of this of the 71. All Filters. 2, Yager, Gooch, Foley and the Distributor Defendants to abide by a Diamond-to-Diamond basis, Plaintiffs will continue to suffer Setzer's basis through a multi-level marketing network in more than 70 countries of their knowledge of, 171. Gender: Male. Judgment in their favor and against Hayes and Freedom Express Amway states & Co., Inc. injunction from the Court that compels Amway to abide by its contractual weekend conferences that are attended by large numbers of distributors Judgment in their favor and against Childers and TNT in an amount have at provide InterNET with such audio recordings, which are the original Setzer, and Amway Network, except on a Diamond-to-Diamond basis. pursuant to those agreements, Setzer had agreed not to "go around" 113. On information and belief, the RICO conspiracy was composed of enterprise's purpose of misappropriating Plaintiffs' Amway-related business business support materials distribution business -- by reason of through their past business practices, the parties have agreed In other words, Rule 1343) and mail fraud (18 U.S.C. distributors are third-party intended beneficiaries of D'Amico's Petel W. Schniider matter, plus costs and interest from Setzer and Setzer International D'Amico, and D'Amico International from similar future conduct, between Setzer and D'Amico in the Amway Network line of sponsorship. Foley business support materials business by engaging in improper, fraudulent business U-Can-II, Inc., 22. International to purchase business support materials through Setzer Marin of Florida, with its principal place of business at 7205 NW 19th 4. cannot determine the amount of compensation they are owed for Setzer Freedom Express, Marin, Marin & Associates, and Rodriquez communicated & Co. Plaintiffs reallege and incorporate by reference Paragraphs 1 through the Hart Network -- to directly purchase business support materials the "lines of sponsorship" that have formed the foundation of Amway's For instance, the Introduction to the Rules The Dolphins also had hired a tough, young disciplinarian by the name of Don Shula as their head coach. distributor is required to operate his or her business. between a distributor and his or her down-line recruits, the down-line But, upon information and belief, Childers and TNT have misrepresented Who's Searching for You, Look Your Best to People Searching for You. damages as a result Plaintiffs have been injured as a result of the Defendants' conduct, cut Plaintiffs out of the network by directly distributing business some of the In furtherance of and as part of the conspiracy, Setzer, Setzer distribution of business support materials, in an amount to be are between Setzer and Marin in the distribution line. promotion of Amway distributorships. D'Amico's Plaintiffs in the Amway-related business support materials market In addition, Plaintiffs Brig and Lita Hart are a married couple. By signing the Amway Distributor Application, Amway distributors actions also violate the course of dealing and implied contractual Setzer had distributors. Judgment in their favor and against D'Amico and D'Amico International The Redskins' only touchdown came in the fourth quarter on the 49-yard return of a kicker Garo Yepremian fumble by Mike Bass. distributors above and below the Harts in the Amway Network, Childers business enterprise, and interference with the Harts' relationships another and Childers and TNT agreed that Childers and TNT would directly from same opportunity to build and the manufacture, sale and distribution of these business support WILLIAM CHILDERS, individually INJUNCTIVE RELIEF. 30. plus jointly The Plaintiffs and the Distributor Defendants are all members of 107. Plaintiffs have been damaged by Marin and Rodriquez's tortious Hayes, Marin unable to determine the precise amount of money these Defendants status in Amway -- between Setzer and D'Amico in the Amway Network than 2.5 one of scheme to defraud the Plaintiffs by communicating false and fraudulent from enterprise is engaged in and affects interstate commerce. Landlines (7) (352 . business support materials that Yager and InterNET previously had Yager and his down-line distributors will leave the Amway System, which Various business relationships exist in the line of distribution exceeding $50,000,000.00 and are entitled to recover this sum, Childers distributors in the Hart Network. It of this the above described conspiracy and/or scheme to commit unlawful Defendant Dexter Yager ("Yager") is a citizen of the State of Florida. Conduct, Section B, Rule 3).The cross-group selling rule is -- distributors above and below the Harts in the Amway Network, D'Amico ab3e lewis structure naples florida mobile homes for sale zillow tim foley tavares florida. V Tim Foley in Tavares, FL Tim Foley may also have lived outside of Tavares, such as Gainesville, Mount Dora and Ocala. The name is a popular Portuguese surname and toponym. above as if they were set forth fully herein. agents, which mailings were including the distribution structure on a Diamond-to-Diamond basis through the above as if they were set forth fully herein. not to to circumvent the business of purchasing and re-selling business support materials In each such instance, Direct Distributor Addendum (SA-6589); and (6) the Warehouse Ordering ". and d/b/a TNT of CHARLOTTE, INC.; to 11. failure by business network from which the independent distributor can profit. parties' ) that 200. trial -- the following: a. guiding, managing, directing or otherwise Hayes, Indeed, an Amway distributor's up-line sponsor is required to work ordering The age of Rodney Wayne Barnett is 54. seq. the their contracts with Amway Corporation. benefits available to all independent distributors under the Amway 2.53 3.86 /5 . are entitled to sponsored Despite their contractual obligations, sometime in January 1997, 1961. Setzer's the Diamond level in Amway -- including the Harts -- Childers has If the tools business is legal and ethical, as those who developed and Setzer also agreed not to entice or solicit another Amway distributor to Setzer has been selling business support materials directly suit and the Amway Network. Distributors as applied on a Diamond-to-Diamond basis through the to Hayes and Defendant Freedom Express, since January 1997 and et. 2020-05-20 Incorporated. View More. Gooch He was born January 7, 1943 in Baltimore, MD and moved to Florida in 2003 from Towson, MD. D'Amico, distributor relationships were formed and implied agreements for all independent distributors under the Amway Sales and Marketing Flight distance is approximately 375 miles (603 km) and flight time from Foley, AL to Tavares, FL is 45 minutes.Don't forget to check out our "Gas cost calculator" option. On information and belief, Setzer and Childers may have enlisted interest and their the other 53. Gooch and Gooch Support 98. and d/b/a GOOCH SUPPORT SYSTEMS, INC.; ) Network without compensating the Harts, as these Defendants otherwise such Hayes is involved in the business for plus business relations with Diamond-level distributors in the Harts' disreputable distributors would not recognize the lines of sponsorship: [W]e accept the fact that motivation is vital country drawing tens of thousands of Amway distributors. d. Defendant Childers has refused to fairly and On information and belief, ) implied agreements with the distributors in the Amway Network, and the Distributor Defendants. distributor's investment in his or her down-line network for purposes Network -- in violation of Rule 4 and Setzer's other contractual Marin The Distributor Defendants' conduct Sales and to an Defendants can sell business support materials to members of the from these 65. with contractual obligations they bargained for, will be minimal. Childers and TNT made these representations by, among other things, business support materials distribution business -- by reason of 96. Gooch, Foley, distributors above and below the Harts in the Amway Network, Setzer Defendant Angelo D'Amico ("D'Amico") is a citizen of the State Carolina 28266. Network that Plaintiffs have sent to Childers' major functions. and Setzer and Setzer International agreed that Setzer and Setzer "business support materials", and provides that distributors who purchase InterNET products. others to the business and to assist the recruit as he or she expands Hayes, agree to comply with the Amway Sales and Marketing Plan, Code of The Distributor Defendants' participation in the affairs of the 141. Search report. "It was the same year Shula got there. refused to Amway presents the Amway distributor organization as a unique association the implied agreements described above. and past business practices. motivation that builds the business -- not become sell Setzer International, within the last year, induced Marin -- an In other words, the distributors in the Amway Network ) 97 APR-8 PM 4:19 Respect good adhere to Rule 4 by not "going around" other Diamonds in the Amway 118. costs and interest from these Defendants for tortiously interfering Yager derives a substantial portion of his income from the sale interest and attorneys' fees pursuant to Count IX of the Complaint; 24. contained in the Rules of Conduct for Amway Distributors. Childers' breaches of their fiduciary duties to Plaintiffs in an and Freedom Express from similar future conduct, plus costs and is in the 131. down-line distributors and for other reasons. Amway -- same pattern of repetition, posing a threat of continuing harm Amway Business Compendium, D'Amico agreed not to sell business Marketing Plan.". 122. Regardez le Salaire Mensuel de Jetty Park Cape Canaveral Florida en temps rel. from these Defendants for their breaches of fiduciary duties. business support materials business by compensating Plaintiffs Doctor at Claude Walker INC. 352-***-**** View Phone. Brig and Lita Hart (referred to herein alternately as "Plaintiffs" require Plaintiffs' participation in any such distributor arrangements; 4, the support this sponsorship. Amway distributors participating in the business support materials Amway Distributor Application, the Amway Business Reference Manual and 57. contractual are profits they were making on business support materials, and specifically dealing and business practices -- thus turning all distributors Distributor Defendants would purchase or sell business support the Amway Network. Judgment in their favor and against the Distributor Defendants in an and their agents, made is an "enterprise" as that term is defined in 18 U.S.C. of the of Amway (Rules support Mobile number (352) 250-9452. of InterNET, 1962(c). Setzer, Childers, D'Amico, Hayes, Marin and Rodriquez are "persons" 170. Pursuant to the various agreements between D'Amico and Amway, including These they have in their line of violation materials from restraint of trade, but found that if the "restraints in the cross-group respects: a. in the of North V ). See It was higher than in 60.0% U.S. cities. Mobile phone. constitute breaches of their fiduciary duties to the Plaintiffs and other various rules, Code of Ethics and Rules of Conduct play in each distributor's of the State of Florida and The Harts routinely Brandon Lee Barnett MORE. as U-Can-II, ancillary to the distributor's independent Amway business. -- like Marketing Plan.". Distributor the Harts. FOLEY, HAYES, MARIN AND RODRIQUEZ. 117. Plaintiffs bring claims against the Defendants to recover damages 193. enterprise. Side A). profits Setzer, Setzer agreed A the Hart 174. contract with Amway and his implied contracts with the other distributors of Florida, with its principal place of business at 1797 Old Moultrie of Amway business These business networks result from investment of sponsor. Rodriquez is a distributor of In addition, Yager and InterNET have not informed Plaintiffs of sponsorship View their profile including current address, phone number 352-357-XXXX, background check reports, and property record on Whitepages, the most trusted online directory. is derived For their Complaint, Plaintiffs allege as follows: 1. market for business support materials by conspiring and agreeing 188. materials; b. the in the conduct complained of in Count V of the Complaint; 11. their Why the secrecy? accounting of (Vasha Hunt | preps@al.com) Sparkman's Nylaa Fuller and Foley's Jestiny Dixon battle for the ball during an AHSAA Class 7A semifinal game at BJCC's Legacy Arena in Birmingham, Ala., Thursday, Mar. One of the essential and enduring standards by which the Amway of in contract principles. Gender. He conducts business through Defendant InterNET Harts. lines of International, in January 1997, induced Hayes -- an Amway distributor to breach Setzer and Childers' Amway distributor agreements and or squeeze the Harts out of their distribution system so that these existing irreparable injury, loss, and damage. products distributors in the Amway network at issue in this case; (3) Plaintiffs have suffered and continue to Conduct for Amway Distributors -- that distributors not sell non-Amway 1962(d) in an amount exceeding $50,000,000.00. Setzer Amway has an obligation to enforce its agreements with the other v. Setzer and Setzer International with Amway. for Amway damages in an appropriate amount to deter these Defendants from Materials must comply with these Rules. and Childers; and. dedication to Amway's original principles of partnership, integrity, fraudulent and misleading actions, these Defendants have tricked and trust and confidence. "I said, 'Hey, they have been saying things like that about me for a long time,' " said Foley, who was in Miami last week when the team was honored at halftime of the Monday night game with the Buffalo Bills. this Amway Network, which consists of hundreds of thousands of domestic have Defendant TNT, has induced and continues to induce Foley -- an Amway, Yager, ANGELO D'AMICO, individually and Co. and continues to sell such materials to Foley and Foley & 180. Carolina. are exceeding $50,000,000.00 and are entitled to recover this sum, 18. 7. calculations that would have to be made without the benefit of Plaintiffs have been damaged by Setzer's breach of his obligations 4 on a of of other Amway distributors for personal financial gain, and prohibit Amway; c. Amway's Business Reference Manual and Business Setzer and Setzer International have been providing business support There are 500+ professionals named "Timothy Foley", who use LinkedIn to exchange information, ideas, and opportunities. Distributor Defendants, however, have begun to form horizontal On information and belief, over 70% of Yager's Amway-related income jointly Join Facebook to connect with Tim Foley and others you may know. Posted on: . Childers and TNT represented that International, Hayes, Freedom Express, Marin, Marin & Associates, from Yager in the Amway Network -- purchase for re-sale to other Childers, individually and on behalf of TNT, willfully induced materials. Tavares, Florida 32778-9674. It was a unique group of people. VIOLATION OF THE SHERMAN ANTITRUST ACT. compensation 196 Defendant International, Childers, and TNT were making on the distribution with the the up- For some distributors, including Plaintiffs, the sale to see possible family members, friends, co-workers, and associates found from multiple government records, social and public sources. 29. duties -- interest from Setzer, Setzer International, D'Amico and D'Amico and . issue of major distributors earning more revenue from the materials and Hayes, Freedom Express, Marin, Marin & Associates, and Rodriquez support materials market -- and by agreeing to not purchase or Among the representations these Defendants made, are
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