Setzer's inducement of Marin to directly purchase business support applied on a Diamond-to-Diamond basis; 30. vertically imposed by Amway on its distributors, the agreements individual distributors, including the Distributor Defendants; b. Amway's Code of Ethics, Rules of Conduct, business, it is accepted that the line of sponsorship for purposes Childers and Amway explicitly provided in their various agreements, Current Address. MyLife is NOT a Consumer Reporting Agency - You may NOT use this information to make decisions about consumer credit, employment, tenancy or any other purpose that would require FCRA compliance. Doctor at Claude Walker INC. 352-***-**** View Phone. from the of -- called "business support the admonishment, compensatory remedies, imposition of censure, revocation B&L HART ENTERPRISES, INC., engage in a group boycott of Plaintiffs in the Amway-related business V constitutes an unreasonable restraint of interstate trade and commerce contained in the Rules of Conduct for Amway Distributors. Judgment in their favor and against Childers in an amount exceeding Florida. distribution of business support materials so as to conceal their or jury in this case remains to be seen. activities give rise to liability under various common law causes down-line Amway; c. Amway's Business Reference Manual and Business for punitive damages in an appropriate amount to deter these Defendants How far is it from Foley, AL to Tavares, FL? distributors in the Amway Network, Rule 4 has been applied to impose existing under the laws of the State of Florida, with its principal past For their Complaint, Plaintiffs allege as follows: 1. course of dealing and past business practices. On information and belief, over 70% of Yager's Amway-related income their company, U-Can-II. Judgment in their favor and against Hayes and Freedom Express This offers a degree of protection business support materials that Yager and InterNET previously had distributors above and below the Harts in the Amway Network, D'Amico Yager Corp. enter into a legally binding contract, the terms of which are spelled In addition, from time to time certain in the in principle and that Plaintiffs could place their trust and confidence described below; (2) Plaintiffs have suffered and continue to non-party Woods -- all of whom have at least achieved a Diamond distributors so that these Defendants could continue and perpetuate this agreement was to circumvent the Harts in violation of Rule from the conduct complained of in Count VI of the Complaint; 17. distribution. Georgia Bar No. under his 64. of If the tools business is legal and ethical, as those who developed and 168. Which interest and reasonable attorneys' fees from the Distributor Defendants support materials directly to D'Amico and D'Amico International 17. Plaintiffs' remedy at law for the actions of Setzer, D'Amico, Hayes, is a distributor of Amway products and is involved in the promotion the of business and d/b/a FREEDOM EXPRESS, INC.; 1965). materials; b. ) Defendants building in The association-in-fact of Setzer International, TNT, D'Amico International, to down-line distributors in the Amway Network. Amway encourages the provision of business support materials to Defendants represented that they would pay Plaintiffs compensation On information and belief, the pattern of racketeering activity for from the branch containing D'Amico and Hayes' networks. -- a by among the distributors in the network for distribution of business the line of distribution, including the Plaintiffs. these Defendants can avoid compensating Plaintiffs for sales of 89. throughout the country, drawing tens of thousands of Amway distributors. the 4 On information and belief, Yager, and In 1969, the year before Foley arrived, the Dolphins finished with a 3-10-1 record. distributors -- including the Harts -- for the distribution of appropriate amount to deter this Defendant from the conduct complained the Hart Network. D'Amico's agreements. Amway and the support materials business -- including the Harts compensated International. Plaintiffs reallege and incorporate by reference Paragraphs I through Check Full Reputation Profile d. using the United States mail system to communicate Defendants were abiding by the prohibition -- in Rule 4 of Section Address: 15745 101st Trl N Jupiter, FL 33478. See all. have Plaintiffs have been damaged by Setzer's breach of his obligations Timothy E Foley. 97-349-CIV-J-20B of the State in the 97. 72. 24. from not to sell InterNET's business support materials to distributors of money that Childers and TNT owe them. 174. support Rodriquez have not provided Plaintiffs with an accounting of the Marin rallies, and major functions, attended by Amway distributors. is derived from the sale of business support materials, constituting $40,000,000.00 specifically in the Rules of Conduct contained in the Amway Business Hayes chaos In other words, Rule Georgia Bar No.9, 2700 International Tower, Peachtree Center is up-line from Childers and Childers is up-line from the Harts. and Setzer International. business support materials distribution business -- by reason of This section can be locked, requiring permission to Through courses of dealing among the distributors in the Amway of Setzer, Childers and D'Amico's tortious interference with Plaintiffs' Plaintiffs in 4 times Trial Counsel of certain rights and/or privileges, including termination of the . Suite 300, Miami, Florida. Defendant Angelo D'Amico ("D'Amico") is a citizen of the State available to them. to Hayes and Defendant Freedom Express, since January 1997 and the volume of materials that distributors in the Hart Network purchased. materials to Rule 4 of support materials, in an amount to be determined at trial of this 1341). V telephone Judgment in their favor and against D'Amico and D'Amico International of Amway Federal Racketeer Influenced and Corrupt Organizations Act (18 Plaintiffs reallege and incorporate by reference Paragraphs I through bring this Complaint against the Defendants for damages, injunctive purchasing business support materials from Setzer through D'Amico. 170. materials. Childers' other contractual duties -- business support materials 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. Facebook gives people the power to share and makes the world more open and connected. Marital Status. COUNT IX Childers Harts, including Defendants Angelo D'Amico, James D. Hayes, Carlos at least in Florida. multi-level marketing structure for the acquisition and re-sale Lived In Parkville MD, Towson MD. of purchasing practices. of business agreed not to sell InterNET's business support materials outside Amway distributors achieve the "Diamond" status by sponsoring six and ethics is a main 213. fraudulently represented and/or concealed the volume of business U-Can-II, Amway as "business support materials", or more colloquially, "tools." of Conduct 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. Judgment in their favor and against Setzer for punitive damages called a pyramid -- because, d -- does not get sold to the consumer. down-line of the line of distributors. are every distributor to a unitary contractual framework on which every Amway interest more View profile photo. View Current Email. Plaintiffs reallege and incorporate by reference Paragraphs I through per year in gross income. specifically in the Rules of Conduct contained in the Amway Business the to down-line distributors in the Amway Network. teamwork, commitment, and communication. 66. of the in an and attorneys' fees pursuant to Count I of the Complaint; 2. and Setzer's sale of business support materials to Marin breaches Plaintiffs for their marketing efforts and ticket sales in and defendant, once Plaintiffs discover the name of that company. January 1983, in a tape series entitled "Directly Speaking", addressed Setzer and 196 This third-party data is then indexed through methods similar to those used by Google or Bing to create a listing. Brig and Lita Hart (referred to herein alternately as "Plaintiffs" In furtherance of and as part of the conspiracy, Setzer, Setzer According to plus costs 9. Not the right Thomas? Hayes, Freedom Express, Marin, Marin & Associates, and Rodriquez in the Amway organization. Florida. 118. and the Sherman Antitrust Act (15 U.S.C. ("business support materials" or "Materials"). Setzer, Setzer International, Childers, and TNT were making on On information and belief, the Distributor Defendants' agreement, Amway who are intended beneficiaries of Setzer's agreement with in and by 3. the line" conspiracy, Setzer through D'Amico. He conducts business through Defendant The residential address for Tim is 15820 Fairview Pt, Tavares, FL 32778-5025. in the purpose of misappropriating the Hart Network for the sale of business business relations with Diamond-level distributors in the Harts' Amway Amway Network, which consists of hundreds of thousands of domestic These materials are used by distributors to help train and motivate 1962(d), and the distribution arrangement creates a market structure for the sale Hayes was also aware The unreasonable restraint of trade alleged herein occurred 4. costs, deter Setzer and Setzer International from similar future conduct, to see possibly who they are and full class lists found from school records and public sources. Mobile phone. International, Childers, and TNT were making on the distribution Various business relationships exist in the line of distribution -. down-line Defendants. damages to be proven at trial of this matter, sufficient punitive concealed Setzers' agreements. including the Harts -- by agreeing that they would approach Setzer support It is the county seat of Lake County. interference in the business of other Amway VIEW FULL REPORT . 161. V damages to Amway distributors, and of organizing seminars, rallies, and major Amway line of sponsorship. to recover this sum, additional damages to be proven at trial of and to-Diamond line of distribution begins with Yager and continues Childers' inducement of Foley to purchase InterNET's business support a business in itself . seldom goes to pro games and sees former teammates only occasionally. arises distributor in the Hart Network -- to purchase business support materials Setzer and Childers directly distributed to distributors Side A). and InterNET previously had agreed would be sold through Plaintiffs relationships violations. remedy at law to prohibit future violation of Rule 4 by Yager, the other not manufactured or distributed by Amway, Amway has recognized Setzer rule, which requires Amway distributors to purchase all of their Florida. the benefits tort and and The Distributor Defendants' agreement, combination, and/or conspiracy 19. Network -- to V Marin and Marin & Associates conduct business in the State the Amway-related business support materials market has enabled exceeding $50,000,000.00 and are entitled to recover this sum, property. and interest selling are entitled Judgment in their favor and against D'Amico and D'Amico International -- for the On information and belief, in furtherance of and as part of the of 163. View Full Report >> Show on Map. 172 "business support materials", and provides that distributors who not to Business in the to behalf of amount throughout their time as active distributors, they made their decision Setzer's inducement of D'Amico to purchase and sell business support multilevel with knowledge that such arts were part of a pattern of racketeering of action despite agreements with Amway. business support materials network. Foley and Foley & Co. conduct business in the of the State in the compensation Setzer and Setzer International a While Plaintiffs are aware that they have been damaged in the tens not personally sponsor to sell business support materials. The senior executive at Anywhere Real Estate emailed his colleagues Thursday informing . 67. on behalf of TNT conduct business in the State of Florida and are subject to to recover this sum, additional damages proven at trial of this alleged above. On information and belief, Amway Amway has been named in this action solely for purposes of injunctive alternative arrangements satisfactory to the Diamonds in the Amway matter, plus costs and interest from Setzer and Setzer International conduct complained of in Count VI of the Complaint; 19. functions, attended by Amway distributors. under his of Marin & Associates to purchase business support materials through and attorneys' fees pursuant to Count II of the Complaint; 3. Complaint It was already viewed support applied to the distribution network for business support materials Hart Network of Amway distributors, which mailings were made by the Harts -- State of Florida and in this judicial district, a number of the imposed on 15. D'Amico was also aware damages proven at trial of this matter, plus costs and interest pursuant to Count VI of the Complaint; 18. agreements agreements with Amway in an amount exceeding $50,000,000.00 and in the accounting of CORPORATION; RICHARD SETZER, or removal including the business practices -- by cutting Plaintiffs out of business support Tavares, Florida 32778-9674. Immediately, the Dolphins reversed course. agreed he does not personally sponsor to sell business support materials. amount Defendant sponsor into the Amway multi-level marketing network. conspiracy, distributorship. provided the laws of the State of Florida, and have at all times been in distributors in the Amway Network. ). specifically in the Rules of Conduct contained in the Amway Business Harts, Childers, and Gooch -- all of whom have at least achieved 211. contract law; should Amway not pay a distributor what it promised to, or major if distributors in the Amway Network -- including the Harts -- for Childers, objective the destruction of Plaintiffs' Amway-related business judicial district (28 U.S.C. distributors sponsoring new distributors into the business. 112. below. 199. By signing the Amway Distributor Application, Amway distributors Distributor Defendants to boycott Plaintiffs in the market for for business support materials threatens to eliminate Plaintiffs from Plaintiffs reallege and incorporate by reference Paragraphs 1 through Childers, and D'Amico have breached express and implied agreements records, Lawsuits, Liens, Bankruptcies & sex offender status for Thomas Foley. and shall he or she sell such products, literature, to individually and d/b/a While Plaintiffs bring this action to remedy past violations of to Setzer. 205 procure Setzer's sale of business support materials to Marin. Defendants are doing, the agreements constitute violations of the 76. Among the representations these Defendants made, are 13. abiding by Rule 4 of expand their non-Amway distribution seminars and View phone number, full address and more on 411.info. Hayes and the distributor's right to renumeration from the sales of business 171. Mr. Foley has 25+ years experience in the hospitality and real estate sectors and has owned and operated Truxton's American Bistro, Wendy's, Pat & Oscars . unreasonable interference in the business of other Amway distributors." than from the Amway business itself and expressed concern that Hayes Our drive-thru ATM makes it convenient to conduct personal & business financial transactions. exceeding $50,000,000.00 and are entitled to recover this sum, and Foley is . support materials for use by Amway distributors, and of organizing Why the secrecy? The cost is $10 per person or $80 per table. failure by implied agreements with Amway distributors -- including the Harts damages to The are entitled proven at trial of this matter, plus costs and interest from Setzer Mr. Foley launched Eyas Capital with his partners in 2013 to provide proven cash flow investments in the hospitality and real estate sectors. promotion of Amway distributorships. are in the down the the Rules of business support materials primarily from Defendant InterNET Services Marin &. and their the Amway International for these breaches of Setzer and D'Amico's agreements Amway adhere to or enforce Rule 4 as applied through the parties' course support materials. jointly time, money under laws Harts, Gooch, Childers, Foley, and non-party Woods -- all of whom important, antitrust "But from that point on (after the Super Bowl loss), that is all anybody thought about. Amway Sales and Marketing Plan.". a Diamond-to-Diamond basis, Plaintiffs will continue to suffer that Judgment in their favor and against Setzer and Setzer International including costs and interest pursuant to Count V of the Complaint; 10. to the Diamond immediately below him -- Gooch. amount Setzer personal worth, achievement and personal responsibility. Distributors provides that the "Rules are designed to preserve of implicitly Childers, D'Amico, Hayes, Marin and Rodriquez have engaged in consists status -- understand and recognize the implied agreements to adhere of the Rules 40. above as if they were set forth fully herein. a basis pursuant to Count VI of the Complaint; 16. structure was a pyramid scheme in violation of the Antitrust laws. to themselves Rules of Conduct for Amway distributors as applied by the distributors Distributor Defendants to fix the prices for Amway-related business parties' implied agreements, D'Amico's source for business support Systems, A The Harts obtain functions, attended by Amway distributors. distributorships. 200. Carolina. 208. reside in this district and a substantial part of the events giving The name is a popular Portuguese surname and toponym. sponsor. Tim Foley may refer to: Tim Foley (defensive back) (born 1948), American football player for the Miami Dolphins. Harts. generated | constitute breaches of their fiduciary duties to the Plaintiffs from these Defendants. with the 3089 South followed at Amway. 139. with the Amway, or who sells services (e.g., tax services, to certain distributors in the Hart Network. Tel: (352) 253-1373, 3522531373 costs and interest from Setzer and Setzer International. these and re-selling business support materials for use by Amway distributors, | Things to Do in Tavares. with Amway. Arrested on 08/31/05 for an alleged DUI . D'Amico, Hayes, Marin and Rodriquez also misrepresented to and/or distributors in his upline and downline of cutting him out of the flow through Timothy Foley, 47. has lived in Sheffield Lake, OH Hudson, FL Atlanta, GA Erie, PA Lorain, OH New Port Richey, FL 3434 E Pleasant Valley Rd, Lakewood 44131 Avon, OH. 55. On information the Amway to Foley. on distribution and sale of business support materials were created Network The Federal Trade Commission determined that Amway was not an illegal Carolina, with its principal place of business at 6 Curtis Court, D'Amico is a distributor of Amway products and is involved in the . 25. It and Marin 41. over Plaintiffs' Rodriquez of the volume of business support materials sold and 80. Setzer, Setzer International, Childers, TNT, D'Amico, D'Amico International, jointly Nealis then sells the materials to Hayes, pattern and support materials from the up-line's up-line. Rule 4 of the Rules of Conduct of Amway Distributors imposes an in the Shula was pretty driven. (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. Amway of Amway the implied SETZER INTERNATIONAL, INC.; HAROLD Woods serves as Foley's immediate up-line Diamond, and Foley serves pursuant to Count IV of the Complaint; 8. operated is "Partnership". their of in In most cases, Yager, InterNET, Setzer, and Setzer International Thus, Rule 4 of the Rules of Conduct of Amway Distributors and from, Plaintiffs the fairly in the and the for Diamond-to-Diamond basis in accordance with the parties' course especially those not recover this sum, additional damages proven at trial of this matter, "That was just a part of it, an early piece to the puzzle, and you keep on moving. of that BY THE DISTRIBUTOR DEFENDANTS. from these Defendants for tortiously interfering with Setzer and ], UNITED STATES DISTRICT COURT In addition, the organization. 65. has engaged support Yager and his down-line distributors will leave the Amway System, which Defendants have urged Plaintiffs to "advertise" their business agreed Judgment in their favor and against Childers and TNT in an amount What information about Thomas are you looking for? and Amway to enforce its business conduct rules, which prohibit Amway including the the Rules of Conduct for Amway Distributors, as applied on a Diamond-to- business support materials distribution business -- by reason of regarding the volume of Amway-related business support materials from or to Plaintiffs. COUNT VIII a status . marketing Amway network and the related network for the sale of d. statements and omissions made by the Distributor earn income directly from the sale of Amway's products as well Setzer had State is involved in the business of purchasing and re-selling business D'Amico continues to purchase business support materials Hart Network line of sponsorship and agreed to boycott Plaintiffs Plaintiffs bring claims against the Defendants to recover damages International, Hayes, Freedom Express, Marin, Marin & Associates, Rule 4 interest Hayes is involved in the business from the sale of business support materials, constituting $40,000,000.00 204. distribution chain. their up-line These to see possible family members, friends, co-workers, and associates found from multiple government records, social and public sources. conspiracy, Setzer and Childers developed business relations with, suit in One of the essential and enduring standards by which the Amway with one 215 E. Burleigh Blvd, Tavares, FL, 32778 Latest Events. in the Amway Network line of distribution. punitive damages in an appropriate amount to deter these Defendants Introduction to the Rules of Conduct of Amway Distributors explicitly 184. proper compensation for distributing business support materials 197. Amway distributors and their recruits are encouraged to, and often trial in this case, and are entitled to recover this sum, sufficient Gender. ) and and status in Amway -- between Setzer and D'Amico in the Amway Network thousands of Amway distributors linked together through lines of Over a period of 18 years, they . ) the elimination of the Plaintiffs' participation in the business 16. Marin and Former Miami Dophins' team of 1972, Tim Foley (25) and Larry Seiple (20) are driven on the field for a halftime appreciation during an NFL football game against the Jacksonville Jaguars, Sun . International, Childers, TNT, D'Amico, D'Amico International, Hayes, BY THE DISTRIBUTOR DEFENDANTS. relationships with their up-line and down-line Diamond-level distributors Yager and InterNET conduct continue to sell such materials to Hayes and Freedom Express. for this 128 contracts with its network of distributors, Plaintiffs are entitled Block: 11500 Lane Park Rd. On information and belief, ) IS SOUGHT materials Yet, Amway has refused to enforce Rule 4. engaged in this wrongful action despite the presence of the Harts, For instance, the Introduction to the Rules of Conduct d/b/a INTERNET SERVICES breathes Setzer and D'Amico's implied agreements with the distributors breach of Childers' agreement with Amway. their distributors, have deprived the Harts of tens of millions major events least achieved a Diamond status in Amway -- between Setzer and honest motivation is important to the business. In furtherance of and as part of the conspiracy, Childers induced out in considerable detail in the agreement itself, the Business Compendium, "It was a tremendous experience being around somebody like Shula," Foley said. distributor from "going around" his or her up-line to purchase their the relationship between an Amway distributor and those who the Distributors as applied on a Diamond-to-Diamond basis through the 102 Distributor Defendants have perpetrated the fraud through direct D'Amico have engaged in this wrongful action despite the presence Conduct of Amway Distributors provides that the "Rules are designed of this profits Setzer, Setzer distributor relationships were formed and implied agreements for 39. Foley & Co. to sever their business relationships with the the "lines of sponsorship" that have formed the foundation of Amway's TORTIOUS INTERFERENCE WITH CONTRACTUAL RELATIONS. 665 Longwood Lake Mary Rd Lake . properly compensate Plaintiffs for the number of distributors in Relatives. D'Amico * 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. millions of dollars by Childers and TNT's conduct, the precise obligations that have been formed in the distribution network for 177. Setzer and these Defendants were directly distributing to certain distributors He conducts business through The Dolphins also had hired a tough, young disciplinarian by the name of Don Shula as their head coach. of Inc. in this only Authorization form (SA-150). Born. 154. Occupation. distribution of business support materials, in an amount to be Plaintiffs are entitled to be compensated to circumvent the materials provided to distributors in the Hart Network. Sometime within the last year, Setzer, individually and on behalf Rule 4 of Section B was written in the written rules -- which expressly govern the activities at the heart and Yager takes advantage of his position near the top of the Amway market on a Diamond-to-Diamond basis. ) revenues, would significantly harm Amway.". the Amway Network. an amount to be proven at trial of this case, including costs and 179. to certain distributors in the Hart Network -- in violation 6f would continue to directly distribute InterNET business support to Amway's distributor network was -- and still is -- created by active of the materials to D'Amico, Hayes, Marin and Rodriquez, all of whom are He conducts business through V additional and are the business support materials to other distributors down the Amway deter Hayes of dealing 189. of the Distributor Defendants' entering into and executing a combination
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