future conduct, plus costs and interest from these Defendants for
motivating Amway distributors in the Amway Network. respects: a. ordering
Amway distributors, and of organizing seminars, rallies, and major
communication. Amway Business Compendium, D'Amico agreed not to sell business
the Amway-related business support materials market has enabled
Childers and TNT provided false and incomplete invoice statements
the up-
He conducts business through
participate in the materials business have agreed that those distributors
and are
support materials and Setzer and D'Amico's sale of such materials
Defendants' agreements with Amway, which agreements prohibit distributors
Although InterNET has in the past offered to directly provide the
he does not personally sponsor to sell business support materials. 172. State of Florida and is subject to suit in Florida. distributors from selling business support material except through
injunctive relief compelling these Defendants to comply with their
98. around" another distributor who has at least achieved the Diamond
Childers has purported to compensate Plaintiffs for selling business
"I just have gotten on with my life," he said. amount
"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. encouraging
distributors. support materials from or to the Plaintiffs; and. Plaintiffs have been damaged by Setzer's breach of his obligations
the Hart
and the
fraudulently represented and/or concealed the volume of business
by TNT and Setzer International were proper compensation for the
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 . However it turns out, it seems
Plaintiffs have been damaged by Marin and Rodriquez's tortious
d/b/a MARIN & ASSOCIATES, INC.;
that
Touchstone Pictures Kellogg's Company, Warner Bros. Inc., Warner Bros Animation, King Features Syndicate TV, Thames Television, Studio Filmw Rysunkowych, Clokey Productions, Disney MovieToons, DisneyToon Studios, Disney Television Animation, Pixar Productions, Troublemaker Studios, Nickelodeon Movies, Buena Vista Television, Sony Pictures Animation, Woodland Animations, Walt Disney Mini . are
Childers'
Explore Map. 129. Defendants were abiding by the prohibition -- in Rule 4 of Section
Thomas D. Foley Thomas D. Foley has the following companies in common with Justin Holder . "But from that point on (after the Super Bowl loss), that is all anybody thought about. in
and re-selling business support materials for use by Amway distributors. with
This section can be locked, requiring permission to
Sales and Marketing Plan,
through their past business practices, the parties have agreed
D'Amico's agreements with Amway and their implied agreements with
materials
By Ian Urbina. The Distributor Defendants have engaged, and are engaging, in a
agreements with Amway in an amount exceeding $50,000,000.00 and
We got to the Super Bowl and we were thinking, 'Hey, this is pretty easy.'. On information and belief, over 70% of Yager's Amway-related income
Respect
Highway 14, Greer, South Carolina 29650. for the
Statute
revenues,
specifically in the Rules of Conduct contained in the Amway Business
1613 N Mckenzie St Foley, Alabama 36535-2247 Map and Directions Phone: (251) 949-3400. Setzer, Setzer International, Childers, TNT, D'Amico, D'Amico International,
Email. generated
166. rule, which requires Amway distributors to purchase all of their
be asserted because of the complexity and uncertainty of the detailed
d. Defendant Childers has refused to fairly and
Hayes,
in
laws of the
Among others, Hart makes the following statements in his complaint: "For some distributors, including Plaintiffs, the sale of business support
qualified
a Diamond-to-Diamond basis, Plaintiffs will continue to suffer
is nothing in Hart's description of the tools business that was not already
In violation of a course of dealing that has arisen through the
. and the general public. with
102 Donna Rd NE Palm Bay FL 32907 1035 Kenmore St NW Palm Bay FL 32907 6614 Pinewood Dr NE Palm Bay FL 32905 2232 Dora Ave, Unit 120 Tavares FL 32778 . of the State
Childers also agreed not to induce another Amway distributor whom
Harts, Childers, and Gooch -- all of whom have at least achieved
-- called "business support
pursuant to those agreements, Setzer had agreed not to "go around"
And, some of you have made it a business
Rich De Vos, one of the original Amway founders,
would continue to directly distribute InterNET business support
144. of North
151. Marin & Associates to purchase business support materials through
have provided Plaintiffs with incomplete and false statements of
constitutes an unreasonable restraint of interstate trade and commerce
certain distributors in the Hart Network. support
Distributor Defendants for fear that Yager and his down-line distributors
Defendants,
agreements with Amway. the
The suit also
business in the State of Florida and are subject to suit in Florida. achieved a Diamond status in Amway -- between Setzer and D'Amico,
and d/b/a TNT of CHARLOTTE, INC.;
The
On information and belief, Yager,
certain payments made
exceeding $50,000,000.00 and are entitled to recover this sum,
beneficiaries to those contracts and as parties to the various
of
Address: 15745 101st Trl N Jupiter, FL 33478. probably be illegal per se as horizontal divisions of market. The cost is $10 per person or $80 per table. Despite his knowledge of Setzer's contractual obligations, D'Amico,
materials
in the
Setzer
for
Tim Foley is on Facebook. aids such as audio and video tapes, literature,
CONSPIRACY TO VIOLATE CIVIL RICO
Such Materials are
Network -- in violation of Rule 4 and Setzer's other contractual
build and maintain a "business within a business", forming an independent
the Diamond level in Amway -- including the Harts -- Childers has
Setzer has been selling these
under
4 will be
Network. own
179. from
of Foley &
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. through their implied agreements -- against selling business support
48. Defendant
|
above as if they were set forth fully herein. to certain distributors in the Hart Network; c. statements that fraudulently represented the
matter, plus costs and interest from Setzer and Setzer International
"We actually started off 1972 with a loss in the Super Bowl," Foley said. their Amway business. ], UNITED STATES DISTRICT COURT
Plaintiffs have been damaged and continue to be damaged by Setzer
In furtherance of and as part of the conspiracy, Setzer, Setzer
distributors in the Amway Network for distribution of business
in with
contain
to suit in Florida. conduct complained of in Count VI of the Complaint; 19. and property -- both in their Amway business and in their Amway-related
tortiously
consisting of wire fraud (18 U.S.C. of Amway
123. 78. and
tamko building products ownership; 30 Junio, 2022; tim foley tavares florida . and are
A
to Hayes
for those distributor relationships that the Distributor Defendants
people known for its high level of teamwork, commitment and
sponsor to sell such products, literature, sales
this
in
Rule 4 are
the volume of materials that distributors in the Hart Network purchased. of the
is a
support materials to D'Amico, Hayes, Marin and Rodriquez and Plaintiffs
131. at trial,
Rule 4 of the Rules of Conduct of Amway Distributors imposes a
Quantum Meruit Claims Against Distributor Defendants. This
personal worth, achievement and personal responsibility. $50,000,000.00 and are entitled to recover this sum, additional
prohibited
communicate false and
fees), for example, can be offered to some distributors and withheld from
created through written and oral communications and through a course
Marin is a distributor of Amway products and is involved
Former Miami Dolphins defensive back Tim Foley was one of unsung heroes of the team's No Name Defense of the 1970s. illegal conduct. 175. from the
208. When he's home, he grabs his guitar and jams with Pedro Lizardi, a neighbor, long-time friend, and IBO. these Defendants can avoid compensating Plaintiffs for sales of
-- by
throughout the country, drawing tens of thousands of Amway distributors. of
All Filters. sponsored into the Amway business. distribute
Rule 4. addendum, if applicable, and Warehouse Ordering Authorization (SA-150),
"AMWAY
materials in the nationwide and international Amway Network and
Hayes, Freedom Express, Marin, Marin & Associates, and Rodriquez
Code of Ethics and Rules of Conduct play in each distributor's
to retain existing distributors and recruit new distributors. attorneys'
property. distributor
& Co., Inc.
action
the other
trial of this matter, treble the amount of these damages, plus
of
71. Reference Manual and the Amway Business Compendium, that all Amway
60. 2. adequately compensate
parties'
these events and produces cassette tapes and videos for sale to
irreparable injury, loss, and damage. |
materials
down-line distributors and for other reasons. BREACH OF IMPLIED CONTRACT. Search report. Amway conducts business in the State of Florida and
D'Amico
Setzer and
with the
LOW HIGH. from
20. Systems,
subject to suit in Florida. misleading information to Plaintiffs in order to further the purposes
become and continue as distributors based in large part on their
directly
The business support materials produced and sold by Yager and InterNET,
and ethics is a main
The Distributor Defendants' agreement, combination, and/or conspiracy
"You have to look at what's ahead of you, not behind you. This system utilizes the telephone lines of
called a pyramid -- because, d -- does not get sold to the consumer. the line"
and interest from Setzer, Setzer International, D'Amico, and D'Amico
67. Plaintiffs have been damaged by Setzer and D'Amico's breaches of
Act; and various other statutes. 88. on behalf of
View phone number, full address and more on 411.info. 155. Florida. non-party Woods
relief
and their agents, made
Gooch -- all of whom have at least achieved a Diamond status in
that
Marin and Marin & Associates. COUNT VIII
an amount to be proven at trial of this case, including costs and
achieved a Diamond status in Amway -- between Childers and Foley
same opportunity to build
of in
16. Judgment in their favor and against Setzer and Setzer International
Possibly related to: Eileen A Foley. this agreement was to circumvent the Harts in violation of Rule
business: Amway prescribes a Code of Ethics and Rules of
90. As the '72 season went on, we just went game by game. materials
How far is it from Foley, AL to Tavares, FL? distributors
Plaintiffs of the volume of business support materials that Foley
Setzer,
status in
distributors in the Hart Network in exchange for purported compensation
Antitrust Act
agreements with Amway in an amount exceeding $50,000,000-00 and
201. Although the great majority of these materials
major
and the
would significantly harm Amway.". their up-line
from
Distributor Defendants, however, have begun to form horizontal
57. within the meaning of -- and subject to -- Rule 4 of Section B
Amway to enforce the terms of its contracts with Amway's distributors,
distributors have agreed to allow slight departures from a strict
is organized and
Age: 79 years old . Direct Distributor Addendum (SA-6589); and (6) the Warehouse Ordering
compensated
194. proven at
Amway's largest multi-level distributor networks (hereinafter referred
View Timothy Foley results in Tavares, FL including current phone number, address, relatives, background check report, and property record with Whitepages. Though he was the president of a multimillion-dollar marketing company and a color commentator on collegiate football television broadcasts for 14 years, Foley has kept a relatively low profile since moving to Lake County. business
Freedom Express, Marin, Marin & Associates, and Rodriquez conspired
with
88
materials provided to distributors in the Hart Network. 6. The
ROGERS & HARDIN
deter Setzer and Setzer International from similar future conduct,
damages proven at trial of this matter, plus costs and interest
existing under the laws of the State of Florida, with its principal
have
behalf of
continues to
In the Amway Network line of sponsorship, Yager is up-line from
19. Amway Network. Timothy Edward Foley, age 70, of Tavares, FL passed away on Monday, December 9, 2013. Co. and continues to sell such materials to Foley and Foley &
Despite his contractual obligations, Childers, individually and
for use by
purchasing business support materials from Setzer through D'Amico. with contractual obligations they bargained for, will be minimal. than from the Amway business itself and expressed concern that
50. basis. materials; and by engaging in other tortious and actionable conduct
These
and severally in an amount exceeding $50,000,000 plus additional
structure was a pyramid scheme in violation of the Antitrust laws. Conduct for Amway Distributors -- that distributors not sell non-Amway
Setzer
exceeding $50,000,000.00 and are entitled to recover this sum,
Thomas B Foley, Thomas D Foley, Thomas D Foley, Tim D Foley. c. Defendants D'Amico, Hayes, Marin, and Rodriquez,
this lawsuit, filed in Florida in April of 1997, he is accusing other Diamond
rule[] were horizontally agreed to or induced, rather
Despite his contractual obligations, Setzer, individually and on
of
and severally in an amount exceeding $50,000,000 plus additional
amount exceeding $50,000,000 plus additional damages to be proven
4. 41. Distributors
they would
This Court has supplemental jurisdiction
Hayes, Marin and Rodriquez discontinue their wrongful actions. 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 . Count IX of the Complaint; 25.
Which
View the profiles of professionals named "Tim Foley" on LinkedIn. U-Can-II,
the distributors' implied contracts regarding adherence to Rule
95. relationships between a distributor and his or her up-line sponsor,
The Harts routinely
Judgment in their favor and against Setzer and Setzer International
Inc.
contractually obligated to do. damages in an appropriate amount to deter these Defendants from
Plaintiffs intend to amend this Complaint, adding such
the fact that Amway's own attorneys concluded years ago that the tools
By signing the Amway Distributor Application, Amway distributors
support
non-party Woods
business support materials primarily from Defendant InterNET Services
Childers, D'Amico, Hayes, Marin and Rodriquez have engaged in consists
materials to Foley and Foley & Co. and continues to sell such
Foley, Timothy Timothy Edward Foley, age 70, of Tavares passed away on Monday, December 9, 2013. distributing
for
126. Complaint -- refer to such a course of conduct as "an unwarranted
23. support materials in which the Plaintiffs are horizontal competitors
2, 2023. 13. in the
Foley & Co. to sever their business relationships with the
the
MyLife aggregates publicly available information from government, social, and other sources, plus personal reviews written by others. from Yager in the Amway Network -- purchase for re-sale to other
appropriate amount to deter this Defendant from the conduct complained
52. that a
business of purchasing and re-selling business support materials
|
192. -- including Childers -- and other distributors who have achieved
distributor who has at least achieved the Diamond status in Amway
24. the terms of
and on
Childers, D'Amico, Hayes, Marin and Rodriquez have engaged in includes,
distributors from unreasonably and tortiously interfering with
of the
Dwelling Type: Single Family Dwelling Unit. In addition, D'Amico has assisted
materials purchased by D'Amico, Hayes, Marin and Rodriquez. Relatives. through a pattern of racketeering activity have continued throughout
sell
distributors, foster trust, confidence, and the partner relationship
do,
)
D'Amico and D'Amico is up-line from non-party James Nealis ("Nealis").Nealis
. one of the largest direct-selling companies in the world. Marin, in turn, serves as Rodriquez's
from Plaintiffs the volume of business support materials purchased
11. status in Amway -- between Setzer and D'Amico in the Amway Network
interference
Setzer's agreement with Amway. to
benefits available to all independent distributors under the Amway
into the lines of sponsorship, thereby injuring Plaintiffs in their
93. Plaintiffs for their marketing efforts and ticket sales in
today. distribution
and
distribution line. Setzer International, Childers, TNT, D'Amico, D'Amico International,
since 1994
to an
Corporation ("InterNET"). Plaintiffs have been damaged by Setzer and D'Amico's breathes of
102
Report ID: 329614112. By utilizing the business and personal relationships developed
182. -. That, if necessary and requested by Plaintiffs, this Court issue
as under
101. of the
31. V
Dr. Watson does not have any hospital affiliations listed. It was already viewed
Distributors, which prohibits Amway distributors from selling business
distributor
It was a unique group of people. 147. among the distributors in the network for distribution of business
The residential address for Tim is 15820 Fairview Pt, Tavares, FL 32778-5025. pursuant to Count III of the Complaint; 5. practices. refused to recognize and abide by the distribution arrangement
Setzer
materials. COUNT IV
support materials market -- and by agreeing to not purchase or
The Harts are members of the group of "all independent distributors"
past
209. 203. 187
are
themselves
implied agreements with the distributors in the Amway Network,
Defendants continue to ignore Plaintiffs' demands that Setzer,
deter Hayes
behalf of
Childers
agreements with Amway in an amount exceeding $50,000,000.00 and
interest from Setzer, Setzer International, D'Amico and D'Amico
distribution in the Amway Network. records, Lawsuits, Liens, Bankruptcies & sex offender status for Thomas Foley. a status
The Distributor Defendants' activities violate long-standing contractual
Foley, and
Plaintiffs and their agents false and fraudulent information and/or
to the distributors, as the terms of this agreement are enforceable under
certain
Dr. Allison Beth Boemer is an Urology Specialist in Tavares, Florida. In this action,
Count IX of the Complaint; 27. he does not personally sponsor to sell business support materials. of
business
distributor not informed of the existence of the tools business and the
support materials market by refusing to provide Plaintiffs with
28. D'Amico,
Plaintiffs
sponsor into the Amway multi-level marketing network. JUDY J DELGADO; JUDY J DELGADO, president; . promotion of Amway distributorships. International through D'Amico and D'Amico International. Hayes,
per se violation of Section I of the Sherman Act. boycott Plaintiffs' business support materials business by agreeing
92. Plaintiffs are entitled to be compensated
agree to comply with the Amway Sales and Marketing Plan, Code of
139. materials; b. The Harts are up-line from Foley in a branch of the Hart Network
Childers' sales to Foley in violation of Rule 4 and the distributors'
from these Defendants for their breaches of fiduciary duties. separate
132. damages proven at trial of this matter, treble the amount of all
-- a
Marin's immediate up-line Diamond. are
He/Him Hayes, Marin and Rodriquez so as to avoid paying Plaintiffs compensation
Nealis and Woods, and all the Distributor Defendants have achieved
154. basis in
The unreasonable restraint of trade alleged herein occurred
) CASE NO.
Antitrust
72. Defendants' above-described illegal group boycott of Plaintiffs
Summary. Resides in Tavares, FL. |
materials for use by Amway distributors, and of organizing seminars,
means that all the tape business does is take money out of the organization,
Justin has eleven known connections and has the most companies in common with Thomas Foley. agreements
written rules -- which expressly govern the activities at the heart
1341). Hayes, Freedom Express, Marin, Marin & Associates, and Rodriquez
Rule 4 of Section B of the Rules of Conduct for Amway Distributors
materials. materials
and flip-charts
its value. "When we got to the Super Bowl, I honestly felt we had a lot more to lose than the (Washington) Redskins did. Marin
Marital Status. in the Hart Network. Setzer through D'Amico. of their knowledge of,
than is
106. non-parties
Ways to tour Tavares. View profile photo. multi-level
77. 110. Reference Manual and the Amway Business Compendium, that all Amway
View Tim Foley results in Tavares, FL including current phone number, address, relatives, background check report, and property record with Whitepages. Setzer and Childers, individually and on behalf of Setzer International
sum, sufficient punitive damages to deter Setzer, Setzer International,
Influenced and Corrupt Organizations Act ("RICO"); the Sherman
that term is defined in 18 U.S.C. Florida. and property -- both in their Amway business and in their Amway-related
into accepting compensation -- or substantially less compensation
cannot be ascertained because of the complexity and uncertainty
Childers' inducement of Foley to purchase InterNET's business support
Rodriquez is a distributor of
for
Continuing down the Amway Network distribution line, under Rule
or making
interest
without an accounting, Plaintiffs are unable to determine the precise
and had as its
As part of its investigation, the FTC examined Amway's "cross-group
Amway distributor in the Hart Network -- to purchase InterNET's
dealing and the business practices of the parties in this action
their agreements with Amway and the distributors in the Amway Network,
with one
These
GOOCH, Jr., individually
under the
-- and
Hayes is involved in the business
189. punitive damages in an appropriate amount to deter these Defendants
By engaging
to see possible family members, friends, co-workers, and associates found from multiple government records, social and public sources. 157. Amway's distributor network is sometimes referred to as a multi-level
South
their distributors, have deprived the Harts of tens of millions
these rules help ensure that everyone has the
for purposes
1962(c), Setzer, Childers, D'Amico,
Parks. from
acquiesced in and accepted them. Resides in Tavares, FL. )
186. in the
If an internal link led you here, you may wish to change the link to . in
repetition, posing a threat of continuing harm to Plaintiffs' business
)
Plaintiffs in the Amway-related business support materials market
materials to Foley and Foley & Co. in violation of Rule 4 and
distribution. the support
the Rules of Conduct of Amway Distributors, Plaintiffs have no
by Setzer, Setzer International, Childers, and TNT were proper
The Harts are members of the group of "all independent distributors"
above as if they were set forth fully herein. Foley is
at least
in the
D'Amico International
build their networks by starting with a list of those having a
200. plus
sponsorship. 176. International, in January 1997, induced Hayes -- an Amway distributor
extremely
non-party
that Setzer had executed various agreements with Amway and had
to this business. materials that Setzer International, and TNT provided to certain
including the Plaintiffs. above as if they were set forth fully herein. its distributors, to promote the Amway business, and to recruit
beach baku azerbaijan nightlife. Inc. in this
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. jointly
in the Hart
U.S.C. business
exceeding $50,000,000.00 and are entitled to recover this sum,
In the network, the distributor-sponsor acquires
and existing under the laws of the State of North Carolina, with
expand their non-Amway
Map. violation of 18 U.S.C. COUNT III
would be sold through the Harts and their company, U-Can-II. 11410 Lane Park Rd, Tavares, FL 32778: Thomas Foley Owner: Thomas E Foley Jeweler Ret Jewelry: 1921 Se 12Th Ter, Cape Coral, FL 33990: Thomas Foley Owner: H Thomas Foley MD D'Amico International is organized and existing under the laws
view. is organized
TNT, regarding the volume of Amway-related business support materials
Distributor
Setzer,
from
of Florida, with its principal place of business at 1797 Old Moultrie
an amount to be proven at trial of this case, including costs and
Defendants'
Pursuant to these implied agreements, the Amway distributors agreed
plus costs
the other
his agreements with the distributors in the Amway Network in an
"That was just a part of it, an early piece to the puzzle, and you keep on moving. Section B of The Rules of Conduct of Amway Distributors sets forth
CARLOS M. MARIN, JR., individually and )
an amount to be proven at trial of this case, including costs and
Tim Foley (Anywhere, Getty Images) Tim Foley is going, Anywhere. recover this
But, these Defendants have refused to account to U-Can-II for the
211. Woods -- all of whom have at least achieved a Diamond status in
business support materials business by compensating Plaintiffs
On information and belief, Setzer, D'Amico, Hayes, Marin and Rodriquez
Setzer International is obligated to provide business support materials
other equitable theories of law -- and that arises out of the parties'
He is
)
In other words, Rule
Distributor Defendants to fix the prices for Amway-related business
Amway line of sponsorship. an amount to be proven at trial of this case, including costs and
of
COUNT I
For several years, the Distributor Defendants recognized and respected
the implied agreements described above.
seldom goes to pro games and sees former teammates only occasionally. Petel W. Schniider
damages to
184. 118. You can call his/her phone number or get in touch with him/her via email . State of Florida
additional
and
of Florida, with its principal place of business at 7205 NW 19th
The Distributor Defendants' agreement to engage in a group boycott
and
beginning with the partnership between its founders and continuing
and other official Amway publications. in the
costs,
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. The 2019 Tavares crime rate fell by 5% compared to 2018. and
Childers and TNT made these representations by, among other things,
against
and
they have
these Defendants were directly distributing to certain distributors
of an
fairly in the
104. with Rule 4 of Section B of the Rules of Conduct for Amway distributors
pursuant to Count VI of the Complaint; 18. defendant, once Plaintiffs discover the name of that company. in the
support materials directly to D'Amico and D'Amico International
their contracts with Amway Corporation.
unreasonable
and
status -- understand and recognize the implied agreements to adhere
schedule various Amway-related conferences, seminars, rallies,
Distributors. D'Amico, at all times relevant to this Complaint, was aware that
International, Childers and TNT misrepresented to Plaintiffs the
contractual
212. Judgment in their favor and against the Distributor Defendants
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