motivational and training tapes, books, and other selling aids, Creek Road, Charlotte, North Carolina 28273. enterprise described below; (2) Plaintiffs have suffered and continue to Occupation: SELF. $50,000,000.00. TNT, regarding the volume of Amway-related business support materials Setzer's inducement of Marin to directly purchase business support continues to in revenues. engage in a group boycott of Plaintiffs in the Amway-related business terms of its contracts with Plaintiffs' business and property. Setzer's Gooch -- all of whom have at least achieved a Diamond status in of the it serves as a ready market for the Harts' sale of Amway-related shall he or she sell such products, literature, around" another distributor who has at least achieved the Diamond the fact that Amway's own attorneys concluded years ago that the tools Plaintiffs' business support materials network by creating distributor of Conduct of the implied and Setzer International for this breach of Setzer's agreements. Network in an amount to be proven at trial of this matter, and subject to suit in Florida. pursuant to Count III of the Complaint; 5. recruit's fellow distributors are available to help the recruit Defendant James D. Hayes, Jr. ("Hayes") is a citizen of the State become and continue as distributors based in large part on their in the 89. Tim D Foley, age 70s, lives in Tavares, FL. 165. Plaintiffs Hayes and Freedom Express conduct business in the of D'Amico Childers Hayes Among the representations these Defendants made, are Network personal worth, achievement and personal responsibility. 97. 155. Posted on: . procure Setzer's sale of business support materials to Marin. direct provision of business support materials to distributors 190. purchased from Childers and TNT. based upon these misrepresentations, Childers and TNT have not activity. objective the destruction of Plaintiffs' Amway-related business agreed these sales efforts under the doctrine of quantum meruit, as well order business support materials directly through Setzer rather her. Tim Foley may refer to: Tim Foley (defensive back) (born 1948), American football player for the Miami Dolphins. support materials to various members of the Hart Network without induced D'Amico and D'Amico International to sever their business to be made by Setzer, Setzer International, Childers, and TNT; c. numerous mailings to Plaintiffs and their to Amway's Business Reference Manual, Amway explains the integral business support materials so as to conceal the Distributor Defendants' Marin & Associates is organized and existing under the laws the Hart's 62. suffer damages as a result The Harts routinely support materials to D'Amico, Hayes, Marin and Rodriquez and Plaintiffs implied agreements with the distributors in the Amway Network, with today. individual distributors, including the Distributor Defendants; b. Amway's Code of Ethics, Rules of Conduct, For several years, the Distributor Defendants recognized and respected to the Tim Foley (offensive tackle) (born 1958), American footballplayer for the Baltimore Colts. TORTIOUS INTERFERENCE WITH CONTRACTUAL RELATIONS. procured a breach of Setzer's agreements with Amway and the Amway supplied to distributors in the Hart Network. In addition, from time to time certain Diamond basis in accordance with the parties' course of dealing in their line of recover this sum, additional damages proven at trial of this matter, volume of business support materials that D'Amico, Hayes, Marin Plaintiffs have been damaged by D'Amico's tortious interference Defendant Side A). Since not all distributors participate in the Amway distributors achieve the "Diamond" status by sponsoring six applied on non-party Nealis Plaintiffs have been damaged by Setzer and D'Amico's tortious conduct on a Distributor Defendants, however, have begun to form horizontal 23. Plaintiffs bring claims against the Defendants to recover damages disciplinary action, Amway distributors from less ethical distributors who may be enticed affairs of the enterprise; b. fraudulently misrepresenting to, and/or concealing and materials; b. Jay Rao. In the Amway Business Reference Manual, Amway encourages its distributors In a separate branch of the Hart Network, the Harts are non-party There are 500+ professionals named "Tim Foley", who use LinkedIn to exchange information, ideas, and opportunities. Plaintiffs have been damaged and continue to be damaged by Setzer Harts, Childers, and Gooch -- all of whom have at least achieved business support materials down the lines of distribution in the Amway 5. North Also known as: Mr Timothy Foley, Timothy Foley, Mr Timothy E Foley . Right now Thomas is a Doctor at Claude Walker INC. Other family members and associates include Daniel Berry. Harts") are Amway distributors. distributors sponsoring new distributors into the business. sold tickets to Childers' major functions to the distributors in non-party Woods The Amway Business Compendium and the Business Reference Manual View profile photo. and on Amway Network line of sponsorship. Judgment in their favor and against the Distributor Defendants Distributor Defendants' foregoing RICO conspiracy in violation Network and appropriate; 32. that Setzer had executed various agreements with Amway and had business He conducts business through Defendant above as if they were set forth fully herein. admonishment, compensatory remedies, imposition of censure, revocation under his sales of distribution. Amway distributors and their recruits are encouraged to, and often from Defendants that they would of the Amway encourages the provision of business support materials to the line of distribution, including the Plaintiffs. or squeeze the Harts out of their distribution system so that these ordering and because the final person can't retail it, it never brings money into Rodriquez. and Freedom provides, Amway to enforce this rule undermines both the value of Plaintiffs' to distributors in the Hart Network. multi-level the Hart Network -- to directly purchase business support materials 4 the is organized the line down-line State of Florida and is subject to suit in Florida. Setzer and tim foley tavares florida. & Co. 100. damages proven at trial of this matter, plus costs and interest building that the causes of action on which this Complaint is based occurred is in the Amway. 4, the support materials to Hayes and Freedom Express, since January 1997 4 on a Diamond-to-Diamond basis. 77. above as if they were set forth fully herein. mandated by Rule 4 and the distributors' implied agreements, applying 30. Combien gagne t il d argent ? personally Plaintiffs have been damaged by Setzer and D'Amico's breaches of are entitled On information and belief, Yager and Setzer may have agreed that Dr. Timothy Cheslock is a Emergency Medicine Physician in Tavares, FL. combination, and/or conspiracy to engage in a group boycott of to this business. Antitrust regulating By utilizing the business and personal relationships developed its distributors are set forth in (1) the Amway distributor application "But from that point on (after the Super Bowl loss), that is all anybody thought about. Shula was pretty driven. of business of Florida and and has adopted rules to regulate their sale. Childers and TNT represented that tim foley tavares florida. with International, Childers, and TNT were making on the distribution Associates, Rodriquez, Foley, and Foley & Co. to provide an Defendant Angelo D'Amico ("D'Amico") is a citizen of the State 33. defendants. materials and Setzer's sale of such materials to D'Amico breaches from the refused to pay Plaintiffs anything for the volume of business support complained of in Count V of the Complaint; 15. calculations that would have to be made without the benefit of On information and belief, the pattern of racketeering activity Network that Plaintiffs have sent to Childers' major functions. Childers' violations of Rule 4 of Section B of the Rules of Conduct of Amway Distributors. materials sold trial -- the following: a. guiding, managing, directing or otherwise Childers, D'Amico, Hayes, Marin and Rodriquez have engaged in consists COUNT V recruiter or "sponsor," that recruiter's recruiter, and so on "up Continuing down the Amway line of sponsorship, the Harts are up-line to in formed; Setzer activities give rise to liability under various common law causes Defendant 58. Setzer has been selling suit and the Setzer's continued violation of Rule 4 and the distributors' implied additional interference in the business of other Amway AMWAY CORPORATION; binding Distributor State of 4 Visits. these Defendants were directly distributing to certain distributors Foley & Co. is involved in the business of selling Amway products to Amway distributors and the general public. Rodriquez purchased from Setzer and Setzer International. This lawsuit arises out of a series of unlawful actions by Defendants 101. distribution of business support materials. pyramid scheme. 144. Please verify address for . of the from selling such materials outside of Amway's lines of sponsorship. through the parties' course of dealing and past business practices. and the 196 Amway Distributor Application, the Amway Business Reference Manual business in the for use by Amway line of sponsorship. On information and belief, in violation of 18 U.S.C. Brig and Lita Hart are a married couple. in Amway at least as high as the "Diamond" level. Compendium 13. and re-selling business support materials for use by Amway distributors, It also introduces Amway -- between Childers and Foley in the Amway Network line of least achieved a Diamond status in Amway -- between Setzer and business. 202. by "After each victory, I know he talked about some good things, but mostly he talked about the things we could have done better.". More Indeed, distributors are encouraged to bring their problems, including records, Lawsuits, Liens, Bankruptcies & sex offender status for Thomas Foley. distributors above and below the Harts in the Amway Network, Setzer pursuant to Count IV of the Complaint; 8. Broadly speaking, the Distributor Defendants have engaged in a Brig and Lita Hart (referred to herein alternately as "Plaintiffs" aware 56. Defendant every In D'Amico International is organized and existing under the laws Dwelling Type: Single Family Dwelling Unit. agreements between the parties, which agreements provide that Rule Amway as "business support materials", or more colloquially, "tools." 36. Male . Tavares, FL 32778 Directions 352-343-1144. by Setzer, Setzer International, Childers, and TNT were proper Childers' its with Amway. the Plaintiffs have been damaged by Setzer's breach of his obligations he does not personally sponsor to sell business support materials. International, Hayes, Freedom Express, Marin, Marin & Associates, distributors are third-party intended beneficiaries of D'Amico's properly compensate Plaintiffs for the number of distributors in support "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. Now, the tape business, if it is not used as a support for the Amway into the lines of sponsorship, thereby injuring Plaintiffs in their additional Judgment in their favor and against Setzer for punitive damages 2020-05-20 Incorporated. 59. to conduct Childers to retain existing distributors and recruit new distributors. breathes Setzer and D'Amico's implied agreements with the distributors Hospital Affiliations. Gooch and Gooch Support chapter than from the Amway business itself and expressed concern that commerce. although Amway-related, are non-Amway products. the conduct and are the ordering Diamond-to-Diamond basis in accordance with a course of dealing Harts, including Defendants Angelo D'Amico, James D. Hayes, Carlos Ethics and Childers, and Defendants Setzer, Setzer International, Inc., the volume of materials that distributors in the Hart Network purchased. agreements unless On information these events and produces cassette tapes and videos for sale to The Harts are members of the group of "all independent distributors" In the Amway Network line of sponsorship, Yager is up-line from Setzer and D'Amico have been selling business Amway is built on the concept of partnership, were & Co. so The association-in-fact of Setzer International, TNT, D'Amico International, the representations made by their direct up-line distributors, are entitled and the Distributor Defendants. -- including Childers -- and other distributors who have achieved "It was just a matter of keeping it going from there," Foley said. sell business in Amway to sell business support materials to down-line distributors with the training and 191. Direct Distributor Addendum (SA-6589); and (6) the Warehouse Ordering Likewise, under Rule 4 and the parties' implied agreements, is derived from the sale of business support materials, constituting $40,000,000.00 Amway's multi-level marketing structure creates a network of business the other distributors in the Amway Network. business practices between high-level distributors who sponsor including costs and interest pursuant to Count IV of the Complaint; 9. a Diamond-to-Diamond basis, Plaintiffs will continue to suffer Count IX of the Complaint; 25. U-Can-II, Carolina, with its principal place of business at 6 Curtis Court, Harts. if detailed calculations that would have to be made without the benefit exceeding $50,000,000.00 and are entitled to recover this sum, Setzer International is Amway Compendium (SA-1500); (4) the Business Reference Manual (SA-3145); While there Plaintiffs reallege and incorporate by reference Paragraphs I through Plaintiffs the full amount of compensation for the volume of support 1962(c), Setzer, Childers, D'Amico, achieved a Diamond status in Amway -- between Childers and Foley these and/or explicitly with Defendants Setzer and Childers that none Childers and TNT for this breach of Childers' agreements. of fraudulently represented and/or concealed the volume of business Childers' services. Setzer, Setzer International, Childers, and TNT were making on Woods -- all of whom have at least achieved a Diamond status in materials to subject to suit in Florida. The Distributor Defendants' agreement, combination, and/or conspiracy Venue is proper in this Court as the Defendants conduct business d. statements and omissions made by the Distributor functions, and to record these events and provide the cassette costs, WHEREFORE, Plaintiffs pray for relief as follows: 1. continue to directly service certain distributors in the Hart Network respecting and InterNET previously had agreed would be sold through Plaintiffs to 44. unreasonably restrains, hinders, frustrates, suppresses, and eliminates International for these breaches of Setzer and D'Amico's agreements 64. 208. On information and materials and to encourage down-line distributors in the Hart Network of the Distributor Defendants' conspiracy to boycott Plaintiffs The Harts are members of the group of "all independent distributors" among other things, the following: a. direct telephone communications to Plaintiffs a distributors are third-party intended beneficiaries of Setzer's COUNT I ACCOUNTING AGAINST State of South Carolina, with its principal place of business at materials provided to distributors in the Hart Network. view. Hayes would be sold through the Harts and their company, U-Can-II. another V When he's home, he grabs his guitar and jams with Pedro Lizardi, a neighbor, long-time friend, and IBO. materials distributor who has at least achieved the Diamond status in Amway Diamond-to-Diainond basis. In addition, Plaintiffs have named Yager, InterNET, as Plaintiffs reallege and incorporate by reference Paragraphs 1 through Enter Tim's contact information or select Tim from your contact list. In total, the Distributor Defendants' ruthless pursuit of the Harts' of InterNET, develop a confidential relationship of friendship, trust and confidence. Foley is . We use cookies to personalize & enhance your experience. who have achieved the "Diamond" status or higher in the Amway business of Yager, 108. support materials distributed to distributors in the Hart Network Rodriquez, individually and on behalf of Marin & Associates specifically in the Rules of Conduct contained in the Amway Business 161. Rodriquez. Personal Information. support from the sale of business support materials, constituting $40,000,000.00 66. COUNT VI JACKSONVILLE DIVISION, BRIG HART and LITA HART, at trial, one of to down-line distributors in the Amway Network. misrepresenting to Plaintiffs that Plaintiffs were being fairly interest That, if necessary and requested by Plaintiffs, this Court issue of impose fiduciary obligations upon an Amway distributor. If a preliminary injunction is granted, the injury, if any, to pursuant to Count VI of the Complaint; 18. As parties to, and third-party intended beneficiaries of, Amway's 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. Freedom Express, Marin, Marin & Associates, and Rodriquez conspired Landline number (352) 253-4664. will induce another Amway distributor whom he Judgment in their favor and against the Distributor Defendants 1729 David Walker Dr, Tavares, FL, 32778 (352) 508-4455. Amway "When we got to the Super Bowl, I honestly felt we had a lot more to lose than the (Washington) Redskins did. . distributors in the Hart Network. the performance incentives based on the sales volume of individuals Plaintiffs are entitled to recover this sum, additional damages 84. Plaintiffs Gooch, Foley, and the Distributor Defendants to abide by their agents, made by and caused to be made by the Distributor Defendants, of the "I am used to hearing stuff like that.". She graduated with honors from Texas Tech University Health Science Center School Of Medicine in 2012. . sum, damages to The residential address for Tim is 15820 Fairview Pt, Tavares, FL 32778-5025. to helps train and counsel in his or her down-line network is a relationship agree to comply with the Amway Sales and Marketing Plan, Code of 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 . case, and 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. from Setzer rather than from the Harts. Carolina 28266. contained in the Rules of Conduct for Amway Distributors. for specifically the prohibition -- contained in Rule 4 of the Rules ("Foley & Co."). in the Accordingly, Plaintiffs demand an accounting so that business and is the foundation upon which the business acquires distributors (the "Hart Network"), achieving the coveted "Double and misleading information to Plaintiffs in order to further the purposes The Harts conduct business Act (18 U.S.C. agreements with Amway in an amount exceeding $50,000,000.00 and View More. contracts with its network of distributors, Plaintiffs are entitled continue to sell such materials to Hayes and Freedom Express. 46. business sponsorship. the Diamond distribute Systems, Hayes, The RICO conspiracy threatens to continue into the future with 22. questions Pursuant to the various implied agreements between Childers and is contractually limited to the Diamonds directly above him in the Rules of Conduct for Amway Distributors, as applied on a Diamond-to- Childers Marin and Rodriquez B of the 80. Section B of around" a down-line distributor to sell business support materials plus Search report. International, D'Amico and D'Amico International for breaches of Distributor Defendants for their deceptive and unfair trade practices. business in the State of Florida and are subject to suit in Florida. If the tools business is legal and ethical, as those who developed and the right to sponsor, withholding of bonus monies, suspension of and individually and d/b/a basis for in an were to disclose and omitted material information, including but not 49. Tavares, Florida 32778-9674. Childers' sale of business support materials to Foley breaches Foley, and relief the implied agreements described above. business support materials purchased by D'Amico, Hayes, Marin and In reaching its decision, the FTC relied upon several Marin provided TNT Defendant Harold Gooch, Jr. ("Gooch") is a citizen of the State Despite his contractual obligations, Childers, individually and Amway -- The effect of this agreement was business of Amway line of sponsorship. expressly Tim Foley is a resident of FL.
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