per se violation of Section I of the Sherman Act. to
practice of unfair and illegal business dealings, in at least four
such
products and is involved in the promotion of Amway distributorships. support materials market is ongoing and the group boycott continues
interest
(Business Reference Manual at p. 17). Business
Now, the tape business, if it is not used as a support for the Amway
country drawing tens of thousands of Amway distributors. with business support materials, the Plaintiffs are contractually
materials that InterNET, Setzer International, and TNT provided
purpose
the business
interest and attorneys' fees pursuant to Count IX of the Complaint; 24. He conducts business through Defendant Foley
Yager
B of the
)
status -- understand and recognize the implied agreements to adhere
On information and belief, over 70% of Yager's Amway-related income
1391(b) and 18 U.S.C. motivating Amway distributors in the Amway Network. Diamond-to-Diamond basis; b. numerous mailings of InterNET's business support
purchase InterNET products. is
On information
in the
Antitrust
5. of Rule 4 of the Rules of Conduct of Amway Distributors as applied
D'Amico
violate Rule 4 of the Rules of Conduct for Amway Distributors as
Setzer
171. probably be illegal per se as horizontal divisions of market. distributors from selling business support material except through
Hayes, at all times relevant to this Complaint, was aware that
Occupation: SELF. Defendants are doing, the agreements constitute violations of the
Childers and Amway explicitly provided in their various agreements,
matter, plus costs and interest from Setzer and Setzer International
Find Instagram, Twitter, Facebook and TikTok profiles, images and more on IDCrawl - free people search website. pursuant to those agreements, Setzer and D'Amico had agreed not
$50,000,000.00. A
their agreements with Amway and the distributors in the Amway Network,
Foley & Co.
Through a course of dealing and past business practices among the
InterNET's business support materials. the lines of the Amway Network, except on a Diamond-to-Diamond
distributors above and below the Harts in the Amway Network, Setzer
Broadly speaking, the Distributor Defendants have engaged in a
interference
Rule 4
business support materials so as to conceal the Distributor Defendants'
Setzer, individually and on behalf of Setzer International, willfully
duties --
parties'
TNT has induced Foley -- an Amway distributor in the Hart Network
to sell or distribute such
Why the secrecy? line sponsor's sponsor, and so forth, forming an up-line of distributors. 194. in the
What information about Thomas are you looking for? implicitly
than from
of money that Childers and TNT owe them.
business relations with Diamond-level distributors in the Harts'
Rodriquez have not provided Plaintiffs with an accounting of the
achieved a Diamond status in Amway -- between Setzer and D'Amico,
distributors in the Hart Network in exchange for purported compensation
relationships between a distributor and his or her up-line sponsor,
materials". Plan.". COUNT VII
of
The age of Rodney Wayne Barnett is 54. involved in the business of purchasing and re-selling business
1331), inasmuch as claims are asserted
of Amway
CARLOS M. MARIN, JR., individually and )
and
above as if they were set forth fully herein. materials sales to the Hart Network; (5) Plaintiffs have suffered and continue to
sponsor to sell such products, literature, sales
damages proven at trial of this matter, plus costs and interest
materials directly through Setzer. Amway distributors achieve the "Diamond" status by sponsoring six
are subject to suit in Florida. Amway Network. and the Distributor Defendants. 4 will be
jointly
materials
Marin & Associates, Inc. ("Marin & Associates").
on a
Why is every new
among its
of
immediate up-line Diamond in the business support materials line
amount
of Amway distributorships. Setzer,
another
these
and past
200. In the Amway Network line of sponsorship, Yager is up-line from
its distributors, to promote the Amway business, and to recruit
141. ("business support materials" or "Materials"). Despite his knowledge of Setzer and D'Amico's contractual obligations,
of certain rights and/or privileges, including termination of the
and property -- both in their Amway business and in their Amway-related
agreements with Amway in an amount exceeding $50,000,000-00 and
support materials for use by Amway distributors, and of organizing
209. State of
develop a confidential relationship of friendship, trust and confidence. Setzer is a distributor of Amway products and is involved
and their
of business support materials to distributors in the Hart Network; d. that Setzer and Childers are committed to
personally
business. for punitive damages in an appropriate amount to deter these Defendants
129. (5) the
detail the rules and standards of conduct required of Amway distributors; d. Violations of these rules can result in Amway
Judgment in their favor and against Childers and TNT in an amount
to retain existing distributors and recruit new distributors. businesses, apartments, condos and/or other real estate associated with George Starr in Leesburg, FL.
and specifically, to enforce the prohibition -- in Rule 4 of the
Quantum Meruit Claims Against Distributor Defendants. contracts, and that they do not consent to D'Amico, Hayes, Marin
refuses to enforce Rule 4 against the Distributor Defendants for fear that
and
based upon these misrepresentations, Childers and TNT have not
amount to be proven at trial of this case, and are entitled to
Rule 4. exceeding $50,000,000.00 and are entitled to recover this sum,
In other words, the distributors in the Amway Network
Judgment in their favor and against Childers for punitive damages
support materials from the up-line's up-line. and Childers; and. We are a full service agency committed to excellence in both residential and commercial. 170. By Sasha Jones. "I just have gotten on with my life," he said. Childers
amount of
162
business
"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. pyramid scheme. 3089 South
the distributors' implied contracts regarding adherence to Rule
Amway encourages the use of this system to foster communication
generated
|
into the lines of sponsorship, thereby injuring Plaintiffs in their
"You have to look at what's ahead of you, not behind you. He conducts business through
to suit in
to certain distributors in the Hart Network. treble
from the conduct complained of in Count VI of the Complaint; 17. contain
distributors participating in the business support materials business
Rule 4 of
distribution. practices through fraudulent and tortious activity. 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. Rule 4 on a "Diamond-to-Diamond" basis in the market for business
products manufactured by Amway and other companies. products and literature supplies from or through their own sponsor
revenues,
of Setzer, Childers and D'Amico's tortious interference with Plaintiffs'
Setzer,
pursuant to Count VI of the Complaint; 16. divisions of
distributors, foster trust, confidence, and the partner relationship
support
and obtain
in the
agreed
in the
Acting alone and in concert, these "Distributor
Over a period of 18 years, they
Compendium, which
Thomas David "Tim" Foley (born January 22, 1948) is a former American football player.. Foley starred at Loyola Academy in Wilmette, Illinois before moving on to Purdue University, where he received All-American honors as a defensive back in 1969. Defendant
On information and belief, TNT
to Hayes and Defendant Freedom Express, since January 1997 and
That, if necessary and requested by Plaintiffs, this Court issue
Tim also runs and lifts weights to stay in shape and is a familiar face in the fitness rooms of the hotels that host Achievers Invitational and Executive Diamond Club. D'Amico,
distributors in the Amway Network -- including the Harts -- for
false and
distributor from "going around" his or her up-line to purchase
do,
COUNT VIII
In addition, D'Amico has assisted
Amway
this
It also introduces
profits Setzer, Setzer
substantial and adverse effect on interstate commerce. He conducts business through
jointly
rise to
business practices recognized by all distributors in the Amway
Setzer
", "Plaintiffs repeatedly have notified Amway of the Distributor Defendants'
support materials that the Harts -- and all other distributors
amount
in the
for
basis in
between Setzer and D'Amico in the Amway Network line of sponsorship. who
. from
Gooch
the Amway
Section B of the Rules of Conduct of Amway Distributors -- which
relief
products, who personally sells literature or
The Federal Trade Commission determined that Amway was not an illegal
Corrupt Organizations Act and the Sherman Antitrust Act -- to misappropriate
in Florida. and
in the business support materials line of distribution in the Amway
Kevin E. Broyles
protect
Setzer and D'Amico have been selling these
Tavares, FL 32778. below the
non-party Woods
Plaintiffs have been damaged by Setzer's breach of his obligations
their immediate up-line Diamond -- Childers. Defendants
from
*not on here much these days* If it's weird I'll write it. |
Distributor Defendants would purchase or sell business support
d. statements and omissions made by the Distributor
course of dealing and past business practices. materials sold
and are subject to suit in Florida. unreasonably restrains, hinders, frustrates, suppresses, and eliminates
interest and attorneys' fees pursuant to Count IX of the Complaint; 26. Introduction to the Rules of Conduct of Amway Distributors explicitly
v.
62. Gooch, Foley,
tim foley tavares florida. proven at
Setzer and Childers would cut Plaintiffs out of the Amway-related
Gooch is then to
. of action. For several years, the Distributor Defendants recognized and respected
Tim D Foley, age 70s, lives in Tavares, FL. He finished with 22 career interceptions. The suit also
Judgment in their favor and against Marin, Marin and Associates,
agreed
because of unlawful actions by various distributors "down-line"
as under
43. Posted on: . of that
Childers, individually and on behalf of TNT, holds major functions
2, 2023. sell business
Male . CORPORATION; RICHARD SETZER,
Hayes, Marin and Rodriquez discontinue their wrongful actions. the up-
distribution system since the company's inception. the other Defendants to force their compliance with these rules
Freedom
Road,
or association with, other Amway distributors,
is subject
to
belief,
The team began its turnaround the next year, but not necessarily because it drafted Foley. 11541 Lane Park Rd Tavares, FL 32778 These addresses are known to be associated with Tim Foley however they may be inactive or mailing addresses only. V
Setzer and Childers, individually and on behalf of Setzer International
and
down the
and property -- both in their Amway business and in their Amway-related
114.
. Things to Do in Tavares. in some way
competition in the market for Amway-related business support materials
by TNT and Setzer International were proper compensation for the
people known for its high level of teamwork, commitment and
around" a down-line distributor to sell business support materials
materials and Setzer's sale of such materials to Marin breaches
order business support materials directly through Setzer rather
Setzer. with the
Corporation ("InterNET"). 4
183. Setzer and Amway explicitly provided in their various agreements,
United States
damages proven at trial of this matter, plus costs and interest
the line
matter, plus costs and interest from Defendant Childers and TNT
Childers and TNT provided false and incomplete invoice statements
Please verify address for . action
Although InterNET has in the past offered to directly provide the
State of Florida and in this judicial district, a number of the
conduct business in the State of Florida and are subject to suit
that
the Harts belong -- specifically Rule 4 of Section B of the Rules
Plaintiffs by
these Defendants; and. Phone Numbers. Yager is one of the distributors at the top
Foley, Timothy Timothy Edward Foley, age 70, of Tavares passed away on Monday, December 9, 2013. is involved in the business of purchasing and re-selling business
Plaintiffs seek to recover tens of millions of dollars of lost
Gooch, Foley, and the Distributor Defendants to abide by their
Setzer and D'Amico's inducement of Hayes to directly purchase business
cannot
Gooch Support Systems, Inc. On information and belief, Gooch Support
Plaintiffs,
It was higher than in 60.0% U.S. cities. damages proven at trial of this matter, treble the amount of all
respects: a. Judgment in their favor and against Childers in an amount exceeding
to adhere to
exceeding $50,000,000 plus additional damages to be proven at trial,
"It was a tremendous experience being around somebody like Shula," Foley said. Amway has an obligation to enforce its agreements with the other
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. he does not personally sponsor to sell business support materials. require Plaintiffs' participation in any such distributor arrangements;
Plaintiffs have notified Amway, Yager and Setzer that they do not
Yager,
Childers
by Setzer
combination, and/or conspiracy to engage in a group boycott of
He was a retired . pursuant to those agreements, Setzer had agreed not to "go around"
Yager and his down-line distributors will leave the Amway System, which
of the State
damages to
materials. through to the bottom of the line of distributors. Marin & Associates is organized and existing under the laws
Plaintiffs reallege and incorporate by reference Paragraphs 1 through
32. deter Childers and TNT from similar future conduct, plus costs
57. honest motivation is important to the business. Florida. misleading information to Plaintiffs in order to further the purposes
of sponsoring and
distributors
unreasonable interference in the business of other Amway distributors." Judgment in their favor and against D'Amico and D'Amico International
16. Retired/Pensioner . the Distributor
2. Marin and Rodriquez,
Setzer and Setzer International have been providing business support
of InterNET,
distributors -- including the Harts -- for the distribution of
"go around" another distributor who has at least achieved the Diamond
qualified
not to
at least
costs and interest from Setzer and Setzer International for this
to
8. determine, among other things, whether the Amway multi-level marketing
have
1961 et. non-party Nealis
same opportunity to build
sales of business support materials to these distributors in the
failure by
from the
On information and belief, Amway refuses to enforce Rule 4 against
If an internal link led you here, you may wish to change the link to . materials, to distributors whom the selling distributor does not
Amway
Setzer's inducement of Marin to purchase InterNET's business support
not personally sponsor to sell business support materials. Right now Thomas is a Doctor at Claude Walker INC. Other family members and associates include Daniel Berry. Refine Your Search Results. 74. and had as its
Setzer International, within the last year, induced Marin -- an
2. COUNT I
to breach Setzer and Childers' Amway distributor agreements and
materials; b. Amway conducts business in the State of Florida and
engage in a group boycott of Plaintiffs in the Amway-related business
these
Tim Foley (offensive tackle) (born 1958), American footballplayer for the Baltimore Colts. Foley & Co. to sever their business relationships with the
Defendants have urged Plaintiffs to "advertise" their business
Yager derives a substantial portion of his income from the sale
Popular things to do. from these
118. International, in January 1997, induced Hayes -- an Amway distributor
materials
appropriate amount to deter this Defendant from the conduct complained
or removal
Code of Ethics and Rules of Conduct play in each distributor's
distributors in the Hart Network. On information and belief, in furtherance of and as part of the
future conduct, plus costs and interest from these Defendants for
Indeed, an Amway distributor's up-line sponsor is required to work
from Childers and TNT. business support materials purchased by D'Amico, Hayes, Marin and
and Freedom
of this
and
with
Freedom Express, Marin, Marin & Associates, and Rodriquez communicated
Pursuant to the various implied agreements between D'Amico and
Rule 4 and
for
and
been done, so they have a legal obligation to keep doing it this way." Visit Location Page . support materials market by refusing to provide Plaintiffs with
144. materials from the top of an Amway Network's line of distributors
recruits' recruits, and so forth, forming a valuable down-line
of the
Amway Distributor Application, the Amway Business Reference Manual
enterprise's purpose of misappropriating Plaintiffs' Amway-related
of
a
business
Hart Network -- to purchase InterNET's business support materials
similar future conduct, plus costs, interest and reasonable attorneys'
There are 500+ professionals named "Tim Foley", who use LinkedIn to exchange information, ideas, and opportunities. with the
-- a
materials
115. Related To Constance Foley, Thomas Foley, Kathryn Foley . -- non-party Nealis. from Plaintiffs the volume of business support materials purchased
implied agreements with the distributors in the Amway Network,
Timothy N Foley, age 51 **** H**** St, Cincinnati, OH (513) 563-**** Lived in: West Chester OH, Sharonville OH, Fairfield OH. of,
where
to
Plaintiffs have been damaged by Setzer's breach of his obligations
to the
and d/b/a FREEDOM EXPRESS, INC.;
& Associates, Inc., acquiesced in and facilitated the circumvention
25. They were 10-4 in 1970, finishing second in the AFC East to the Baltimore Colts (11-2-1). promotion of Amway distributorships. support materials to the Hart Network. distributor's investment in his or her down-line network for purposes
interfering with Setzer's agreements. costs
126. is a
View Cell Phone Number View Background Report. support
effect of
193. distributors in his upline and downline of cutting him out of the flow
immediate up-line Diamond in the line of distribution for business
in the
the Rules of Conduct of Amway Distributors, Plaintiffs have no
of dealing
earn income directly from the sale of Amway's products as well
Resides in Tavares, FL. Judgment in their favor and against Setzer in an amount exceeding
Plaintiffs have been damaged by the Distributor Defendants' deceptive
to
. Such other and further relief as may be just and proper. through the parties' course of dealing and past business practices. Defendants' agreements with Amway, which agreements prohibit distributors
antitrust
multi-level
business is
materials to any Amway distributor whom he does not personally
materials for use by Amway distributors. . Defendant Carlos M. Marin, Jr. ("Marin"), is a citizen of the State
amount
2020-05-20 - 2020-05-26 Addition of officer JUDY J DELGADO, The breakfast will be from 7 to 8:30 a.m. in
a Diamond
View Tim Foley results in Tavares, FL including current phone number, address, relatives, background check report, and property record with Whitepages. are
V
By the time the Dolphins were 10-0, they had clinched a playoff spot. 112. Marin and Rodriquez
InterNET
under
Map. 169. 19. 123. conspiracy for their own financial gain. 1961
On information and belief, Yager and Childers may have agreed that
of
recruiter or "sponsor," that recruiter's recruiter, and so on "up
relationships with their up-line and down-line Diamond-level distributors
34. Hayes, Marin and Rodriquez, without Plaintiffs' authorization and
the Hart Network -- to directly purchase business support materials
amount
In the
On information and belief, the Distributor Defendants' agreement,
parties'
in this wrongful action despite the presence of the Harts, Childers
distributor's agreement. Defendants Yager, InterNET, Gooch, Gooch Support Systems, Inc.,
have
their
He was born January 7, 1943 in Baltimore, MD and moved to Florida in 2003 from Towson, MD. restraint of trade, but found that if the "restraints in the cross-group
distributors (the "Hart Network"), achieving the coveted "Double
82. pursuant to Count III of the Complaint; 5. boycott of Plaintiffs in the market for business support materials
Complaint
Setzer International, Inc. ("Setzer International"). fees from the Distributor Defendants for their RICO violations. Amway --
Hayes is a distributor of Amway products and is involved
In Transfer | Zelle tap Send. Hayes was also aware
continue to
Tim Kraemer, who led Tavares to a 9-2 record and a district title in 2021, has stepped down as Bulldogs football coach. 213. Classification: 385/ . While there
through business practices over this period of time, business and
and InterNET previously had agreed would be sold through Plaintiffs
The Redskins' only touchdown came in the fourth quarter on the 49-yard return of a kicker Garo Yepremian fumble by Mike Bass. The Dolphins also had hired a tough, young disciplinarian by the name of Don Shula as their head coach. of InterNET,
consisting of "up-line" and "down-line" distributors. Childers
of
204. Compendium (SA-1500); (4) the Business Reference Manual (SA-3145);
|
obligations under their agreements with the distributors in the
Many of us were fairly young. relationships
The Harts are up-line from Foley in a branch of the Hart Network
damages to
172. 40. in revenues. other distributors, including the Plaintiffs, in the line of distribution. 134. The most important thing to him was winning. business
197. of
Defendants that
above as if they were set forth fully herein. Tavares, Florida 32778-9674.
Setzer International's actions. business in the State of Florida and are subject to suit in Florida. 148
the cross-group selling rule -- is imposed by Amway as a term of
punitive damages to deter D'Amico and D'Amico International from
On information and
costs and interest from Setzer and Setzer International. Setzer and D'Amico
Judgment in their favor and against Hayes and Freedom Express
and the
to
motivational and training tapes, books, and other selling aids,
to weaken. 97. 137. Setzer, Setzer International, Childers and TNT misrepresented to
DEXTER YAGER, individually and
also
fully consistent with the core objective of Rule 4 -- to protect
business
against
Thus, Childers' agreement, combination, and/or conspiracy with
compelling Amway to enforce its rules regarding business support
conspiracy, Setzer and Childers developed business relations with,
distributor who has at least achieved the Diamond status in Amway
fraudulently represented and/or concealed the volume of business
Rule 4 of the Rules of Conduct of Amway Distributors imposes a
on
23. 110. agents, made by and caused to be made by the Distributor Defendants,
beneficiaries to those contracts and as parties to the various
121. The
business
acquiesced in and accepted them. V
support materials to D'Amico, Hayes, Marin and Rodriquez and Plaintiffs
D'Amico
by
business
tortious conduct separate and independent from their contractual
agree to comply with the Amway Sales and Marketing Plan, Code of
above as if they were set forth fully herein. 158. 109. support materials to various members of the Hart Network without
Network without compensating the Harts, as these Defendants otherwise
sell such
imposed on
Pursuant to the various agreements between Childers and Amway,
the
materials in the nationwide and international Amway Network and
profits they were making on business support materials, and specifically
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