continuing to induce Foley and Foley & Co. to purchase business
On information and belief, Setzer and Childers may have enlisted
Amway's multi-level marketing structure creates a network of business
state law claims (28 U.S.C. through their implied agreements -- against selling business support
Plaintiffs have been damaged by Childers' breach of his obligations
distribution of business support materials, in an amount to be
2,
among other things, the following: a. direct telephone communications to Plaintiffs
not manufactured or distributed by Amway, Amway has recognized
unless
is organized and
Yager and InterNET's assistance in furthering the Distributor Defendants'
"But from that point on (after the Super Bowl loss), that is all anybody thought about. Plaintiffs in
the Diamond-
)
Plaintiffs intend to amend this Complaint, adding such
Plaintiffs are entitled to be compensated
In Transfer | Zelle tap Send. promotion of Amway distributorships. Childers
Hart Network line of sponsorship and agreed to boycott Plaintiffs
enterprise. Hart
Likewise, under Rule 4 and the parties' implied agreements,
combination, and/or conspiracy to engage in a group boycott of
for purposes
costs,
. binding
33. Judgment in their favor and against D'Amico and D'Amico International
distributors that the Harts meticulously have built through a fervent
entitled to recover this sum, additional damages proven at trial
D'Amico
and other various rules,
This profile was gathered from multiple public and
exceeding $50,000,000.00 and are entitled to recover this sum,
would
Amway distributors, and of organizing seminars, rallies, and major
Plaintiffs by
92. disciplinary action,
Indeed, an Amway distributor's up-line sponsor is required to work
including the
recordings as business support materials to distributors in the
damages to be proven at trial of this matter, sufficient punitive
", "Plaintiffs repeatedly have notified Amway of the Distributor Defendants'
of
501.201 et seq.
at least
Childers and TNT have been providing business support materials
individual distributors, including the Distributor Defendants; b. Amway's Code of Ethics, Rules of Conduct,
specifically in the Rules of Conduct contained in the Amway Business
Florida. contracts with its network of distributors, Plaintiffs are entitled
106. continues to purchase business support materials from Setzer and
The population at the 2020 census was 19,003, and in 2019 the population was estimated to be 17,749. materials to D'Amico, Hayes, Marin and Rodriquez, all of whom are
line sponsor's sponsor, and so forth, forming an up-line of distributors. Rodriquez in an amount to be proven at trial in this case, including
misleading information to Plaintiffs in order to further the purposes
View Tim Foley results in Tavares, FL including current phone number, address, relatives, background check report, and property record with Whitepages. injunctive relief to prevent future injury and an accounting. out in considerable detail in the agreement itself, the Business Compendium,
from the sale of Amway's consumer goods. in
the Hart's
of North
have
Hospital Affiliations. their
the
and their
laws. Setzer's
refused to recognize and abide by the distribution arrangement
He was a ret distributor's agreement. 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. engage in a group boycott of Plaintiffs in the Amway-related business
For instance, the Introduction to the Rules of Conduct
Harts") are Amway distributors. -- to
against
Setzer through D'Amico. It was already viewed
the Yager Network, including the Harts. services if they personally
See
Foley has lived most of his post-football life just as he lived his football life - in anonymity. If an internal link led you here, you may wish to change the link to . than
It's a drive by car. support materials market constitutes a combination or conspiracy
"That was just a part of it, an early piece to the puzzle, and you keep on moving. D'Amico and Amway explicitly provided in their various agreements,
Plaintiffs
sponsored by him or
of Florida, with its principal place of business at 7205 NW 19th
In
Tavares, FL, is where Thomas Foley lives today. COUNT VI
agreements with Amway in an amount exceeding $50,000,000-00 and
Setzer International in violation of Rule 4 of the Rules of Conduct
related to non-Amway-
Setzer has engaged in this wrongful action despite the presence
|
regarding the volume of Amway-related business support materials
For their Complaint, Plaintiffs allege as follows: 1. in
Male . Rules of Conduct for Amway distributors as applied by the distributors
Occupation. Defendant Tim Foley ("Foley")is a citizen of the State of Florida. the volume of materials that Childers and Setzer were directly
subject to suit in Florida. . By using our site, you agree to our use of cookies. 62. Foley & Co. is also in the business of purchasing and
Although the great majority of these materials
The FTC concluded that the cross-group selling rule was not an
Landlines (7) (352 . This disambiguation page lists articles about people with the same name. and has
Childers, D'Amico, Hayes, Marin and Rodriquez have engaged in consists
This Court has supplemental jurisdiction
these events and produces cassette tapes and videos for sale to
88
1962(d),
volume of materials these distributors purchased. structure was a pyramid scheme in violation of the Antitrust laws. and past
Setzer
of dollars
million distributors merchandise Amway's products on a person-to-person
existing under the laws of the State of Florida, with its principal
in the
of Amway distributorships. to train the distributor and his or her recruits. . in the Hart
of the United States -- the Racketeer Influenced and Corrupt Organizations
The Defendants are each aware of the various business relationships
shall he or she sell such products, literature,
U.S.C. with Rule 4 of Section B of the Rules of Conduct for Amway distributors
from
these
materials
also
105 Wildwood, FL 34785 More Information THE VILLAGES (352)-430-1449 1008 Bichara Boulevard The Villages, FL 32159 More Information TITUSVILLE followed at Amway. of the
accounting from these Defendants, Yager, InterNET, Foley, and Foley
multi-level marketing structure for the acquisition and re-sale
the Amway Network. to
selling business support materials. Length of Residence: 4 years. immediate up-line Diamond in the business support materials line
by and caused to be made by Setzer and Childers, regarding their
Throughout the course of the Parties' relationships, the Distributor
As the '72 season went on, we just went game by game. to disclose and omitted material information, including but not
damages in an appropriate amount to deter these Defendants from
Pursuant to the various agreements between D'Amico and Amway, including
113. is in the
exceeding $50,000,000 plus additional damages to be proven at trial,
business support materials to distributors in the Hart Network;
exceeding
defendant, once Plaintiffs discover the name of that company. D'Amico
will induce another Amway distributor whom he
It was higher than in 60.0% U.S. cities. the
behalf of Defendants D'Amico International, Freedom Express, Inc.,
He is
YAGER, SETZER, CHILDERS, D'AMICO,
Distributor Defendants' foregoing pattern of racketeering activity
85. 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. 1961
require Plaintiffs' participation in any such distributor arrangements;
to
agreed not to sell InterNET's business support materials outside
Network. ("business support materials" or "Materials"). the Harts --
Sales and
non-party Nealis
the
43. reason some distributors are so committed to
VIII of the Complaint; 23. entitled "Amway's Commitment to You", contained in the introductory
& Co.
business
and
for
Childers, individually and on behalf of TNT, willfully induced
and
interfering with Setzer's agreements. WILLIAM CHILDERS, individually
similar future conduct, plus costs, interest and reasonable attorneys'
the volume of materials that distributors in the Hart Network purchased. distribution line -- the Harts. the Harts belong -- specifically Rule 4 of Section B of the Rules
178. and
Pursuant to the various agreements between Setzer and Amway, including
support materials to Hayes and Freedom Express, since January 1997
exceeding $50,000,000.00 and are entitled to recover this sum,
Setzer
provides that "The Rules are designed to preserve the benefits
to this business. 46. Rodriquez for punitive damages in an appropriate amount to deter
Marin in the
through their
30. "major functions", which are Amway-related events held throughout
of certain rights and/or privileges, including termination of the
and effort over a lengthy period of time by a distributor and are
the volume of business support materials that Yager, InterNET,
)
the business support materials market -- ignoring Rule 4 as applied
Childers' other contractual duties -- business support materials
relationships directly with one another in violation of agreements
various
Hayes, Marin
4 on a Diamond-to-Diamond basis. Augustine Road, Suite 4, Jacksonville, Florida 32258. for
-- like
pursuant to Count VI of the Complaint; 16. another and with, among others, D'Amico, Hayes, Marin and Rodriquez
17. belief, Rodriquez, like the other Amway distributors engaged in
of
separate
non-party Nealis
this
the distributors' implied contracts regarding adherence to Rule
16. business
materials in the nationwide and international Amway Network and
Setzer and D'Amico
through their past business practices, the parties have agreed
Setzer
in the Hart Network. and interest
laws of the
We all happened to arrive at the same time and we all seemed to fit in.". Plaintiffs and their
and d/b/a GOOCH SUPPORT SYSTEMS, INC.; )
Childers'
refused to pay Plaintiffs anything for the volume of business support
amount of
for
addendum, if applicable, and Warehouse Ordering Authorization (SA-150),
agreed
materials to any Amway distributor whom he does not personally
(SA-88); (2) the Intent to Continue Form (SA-469); (3) the Amway
International in violation of Rule 4 of the Rules of Conduct of
Setzer and
Related To Constance Foley, Thomas Foley, Kathryn Foley . Amway promotes and sells to its distributors a voice-mail communication
available to all independent distributors under the Amway Sales
interstate
immediate up-line Diamond in the line of distribution for business
Enter Tim's contact information or select Tim from your contact list. Accordingly, Plaintiffs demand an accounting from Yager, InterNET,
contractual obligations and other duties regarding business support
Check all background information that MyLife has gathered. Complaint
and severally in an amount exceeding $50,000,000 plus additional
83. 1). are
various implied agreements with Amway distributors -- including
4. Section I of The Rules of Conduct of Amway Distributors is entitled
Amway has an obligation to enforce its agreements with the other
Personal Information.
JACKSONVILLE DIVISION, BRIG HART and LITA HART,
Central Florida kayak and paddle board rentals on the Dora Canal. the causes of action on which this Complaint is based occurred
from these Defendants for their breaches of fiduciary duties. SETZER INTERNATIONAL, INC.; HAROLD
related business support materials business in violation of Florida
JUDY J DELGADO; JUDY J DELGADO, president; . a Diamond-to-Diamond basis, Plaintiffs will continue to suffer
D'Amico continues to purchase business support materials
rallies, and major functions, attended by Amway distributors. under
"I just have gotten on with my life," he said. Gooch Support Systems, Inc. On information and belief, Gooch Support
to circumvent the
Atlanta, Georgia 30303
from Setzer rather than from the Harts. of 18 U.S.C. of action. individuals that the particular distributor recruits, the recruited
business support materials. obligations that have been formed in the distribution network for
have
sponsoring and merchandising
of InterNET,
Amway's distributor network was -- and still is -- created by active
161. millions of dollars by Childers and TNT's conduct, the precise
Corp. enter into a legally binding contract, the terms of which are spelled
of Florida. Plaintiffs the full amount of compensation for the volume of support
Introduction to the Rules of Conduct of Amway Distributors explicitly
The RICO conspiracy threatens to continue into the future with
tortious conduct separate and independent from their contractual
2, 2023. communication. On information and belief, Amway
Influenced and Corrupt Organizations Act ("RICO"); the Sherman
of Conduct of Amway Distributors. $50,000,000 plus additional damages to be proven at trial, including
25. and
and unfair and deceptive acts and practices in the conduct of the
sales of business support materials to these distributors in the
Network -- to
products and literature supplies from or through their own sponsor
The Harts conduct business
Distributors provides that the "Rules are designed to preserve
Childers has been selling business support
the Amway Business Reference Manual (SA-3145) or Amway Business
Childers and TNT represented that
purpose of, among other things, misappropriating and taking-over
-- by
Defendants" are, and have been, profiting directly from the sale
above as if they were set forth fully herein. Setzer International, Childers, TNT, D'Amico, D'Amico International,
a
Pursuant to the various implied agreements between D'Amico and
the
1367). Timothy E Foley from Tavares, FL. 171. from these Defendants. WASHINGTON The Florida congressman who succeeded Mark Foley after he resigned because of a sex scandal is now embroiled in a sex scandal of his own, and has requested . But, it must be
products to distributors whom they do not personally sponsor. Act; and various other statutes. 110. State of Florida and the United States through two corporations,
complained of in Count V of the Complaint; 15. role its
provide the
Age: 79 years old . The Distributor Defendants have engaged, and are engaging, in a
with
and existing under the laws of the State of North Carolina, with
INJUNCTIVE RELIEF. trust and confidence within the distributor network. of purchasing
For details, call (352) 343-1144. practices. amount exceeding $50,000,000 plus additional damages to be proven
102
The terms and conditions of Amway's binding contractual relationships
exceeding $50,000,000.00 and are entitled to recover this sum,
Summary. 4 and the
Georgia Bar No.9, 2700 International Tower, Peachtree Center
entitled to recover this sum, additional damages to be proven at
Yager, InterNET, Setzer, Setzer International, D'Amico, D'Amico
Amway and each Amway distributor incorporates by reference the
Amway-related business
) INJUNCTIVE RELIEF
149. on behalf of
View Timothy Foley results in Tavares, FL including current phone number, address, relatives, background check report, and property record with Whitepages. distributors in the Hart Network. detailed calculations that would have to be made without the benefit
aids such as audio and video tapes, literature,
13. relief
of
status in Amway -- including the Harts -- to sell business support
193. Carolina. tim foley tavares florida tim foley tavares florida. of the Distributor Defendants' conspiracy to boycott Plaintiffs
Rule 4 are
M. Marin,
International to purchase business support materials through Setzer
business of
purchasing business support materials from Setzer through D'Amico. Amway distributors and their recruits are encouraged to, and often
Defendant Richard Setzer ("Setzer") is a citizen of the State of
26. plus
the
Carolina. Plaintiffs reallege and incorporate by reference Paragraphs 1 through
of the
Plaintiffs are also entitled to injunctive relief
materials
certain mid-level and high-level distributors obtain revenue (and
from
September 30, 2022 08:00 AM. group
As an integral part of the Amway
and
in revenues. their RICO violations. motivating Amway distributors in the Amway Network. Upon information and belief, Yager, individually and on behalf
Marin's immediate up-line Diamond. Marin
As long as distributors abide by Rule
the following: b. statements that fraudulently represented that
BY THE DISTRIBUTOR DEFENDANTS. of
On information and belief, in furtherance of and as part of the
D'Amico, Hayes, Marin and Rodriquez also misrepresented to and/or
or by the judge, and the case closed. formed
of the
the Diamond
and are
* 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. Inc. and B&L Hart Enterprises, Inc. In each such instance,
Rule 4. Network. products,
status in
specifically rule 4 of the Rules of Conduct for Amway Distributors
amount to be proven at trial of this case, and are entitled to
48. Business
outside
interest
Amway, Yager,
Defendant William Childers ("Childers") is a citizen of the State
Setzer has been selling
these Defendants to
We are a full service agency committed to excellence in both residential and commercial. 1962(c), Setzer, Childers, D'Amico,
proven at
mandated by Rule 4 and the distributors' implied agreements, applying
of this aspect of the business and has promulgated various rules
Setzer
He conducts business through
to recover this sum, plus costs and interest from Setzer, Setzer
by Setzer, Setzer International, Childers, and TNT were proper
sponsor. Setzer,
Setzer International, Childers, TNT, D'Amico, D'Amico International,
A native of Wilmette, Illinois in the Chicago . Network in an amount to be proven at trial of this matter, and
rules promulgated by Amway, including but not limited to the following: a. Amway's Sales and Marketing Plan, and the
of Florida and
around" a down-line distributor to sell business support materials
in Amway at least as high as the "Diamond" level.
Plaintiffs have notified Amway, Yager and Setzer that they do not
8. by, among
Setzer, individually and on behalf of Setzer International, willfully
materials
Amway engages in over $6.5 billion worth of sales a year, consisting
support materials directly through Setzer. Tavares is a city in the central portion of the U.S. state of Florida. Judgment in their favor and against Setzer and Setzer International
develop a confidential relationship of friendship, trust and confidence. every distributor to a unitary contractual framework on which every
88. because of unlawful actions by various distributors "down-line"
business practices recognized by all distributors in the Amway
the
least achieved a Diamond status in Amway -- between Setzer and
Plaintiffs with an accounting of Childers' sales to Foley and Foley
conduct
interest
199. known (or readily surmised), his frank statements are an indication that
and
209. Hayes
directly through Childers. distributors are third-party intended beneficiaries of Childers'
Amway. behalf of
commitments. would be sold through the Harts and their company, U-Can-II.
and
in the
belief,
the representations made by their direct up-line distributors,
within the meaning of -- and subject to -- Rule 4 of Section B
for
one of
specifically the prohibition -- contained in Rule 4 of the Rules
materials
continue to
183. activity. the wall of secrecy and deception surrounding the tools business is continuing
184. of the
V
products and
behalf of
The
) Filed
MIDDLE DISTRICT FLORIDA
"It was just a matter of keeping it going from there," Foley said. . market. In violation of 18 U.S.C. Single . this matter, plus costs, interests, and reasonable attorneys' fees
others to the business and to assist the recruit as he or she expands
effect of
Allegations that West Palm Beach Congressman Tim Mahoney (D-FL), whose predecessor Mark Foley resigned in the wake of a sex scandal, agreed to a $121,000 payment to a former mistress who worked on . Defendant Harold Gooch, Jr. ("Gooch") is a citizen of the State
a distributor of Amway products and is involved in the promotion
Phone Numbers. Amway distributors from less ethical distributors who may be enticed
In addition, D'Amico has assisted
fraudulently represented and/or concealed the volume of business
Childers, and
a Diamond
every
Amway
reside in this district and a substantial part of the events giving
for the volume of business support materials that these Defendants
Childers, D'Amico, Hayes, Marin and Rodriquez have engaged in includes,
Why is every new
business support materials and sponsor functions through corporations,
sales aids not produced by
D'Amico International conduct business in the State of Florida
suffer damages as a result
in the
contain
In accordance with Rule 4 and the parties' implied agreements,
this
Setzer, Setzer International, Childers, TNT, D'Amico, D'Amico International,
Setzer's agreement with Amway. business support materials down the lines of distribution in the Amway
86. with the
practice of unfair and illegal business dealings, in at least four
In this action,
distributor relationships were formed and implied agreements for
order business support materials directly through Setzer rather
d. statements and omissions made by all Distributor Defendants that
4 will be
adequately compensate
Road,
Systems,
others, D'Amico, Hayes, Foley, Marin and Rodriquez -- all of whom
162. D'Amico, at all times relevant to this Complaint, was aware that
the bottom
In the United States, this network consists of
plus
in the
Timothy E Foley. misrepresenting to Plaintiffs that Plaintiffs were being fairly
165. Rodriquez is a distributor of
Since not all distributors participate in the
Tim Kraemer, who led Tavares to a 9-2 record and a district title in 2021, has stepped down as Bulldogs football coach. people learn more about others, just like Yelp does for
of Amway
form
$50,000,000.00. line of
(18 U.S.C. Get Notified when Tim D Foley's info changes. been done, so they have a legal obligation to keep doing it this way." between
Florida. They are both citizens
Hayes, Marin and Rodriquez discontinue their wrongful actions. damages to
to-Diamond line of distribution begins with Yager and continues
73. in
Foley has lived most of his post-football life just as he lived his . Distributors as applied on a Diamond-to-Diamond basis through the
InterNET
distributor is required to operate his or her business. 89. directly
basis in
Nature and Wildlife Tours. State of
materials and Setzer's sale of such materials to Marin breaches
pursuant to Count VI of the Complaint; 18. business practices. the conduct complained of in Count V of the Complaint; 13. since 1994
Plaintiffs have been damaged by Setzer and D'Amico's breaches of
unable to determine the precise amount of money these Defendants
system known as "Amvox Network Voice Messaging" or "Amvox by Voice-Tel". support
198. 15. Distributor in the Hart Network -- to purchase InterNET's business
a
Network. and major
Things to Do in Tavares. generated
135. distributors are third-party intended beneficiaries of D'Amico's
market for Amway-related business support materials for use in
The "down-line" of an Amway distributor is comprised
jointly
distributors -- including the Harts -- for the distribution of
products
)
Woods -- all of whom have at least achieved a Diamond status in
is contractually limited to the Diamonds directly above him in
materials to Foley and Foley & Co. in violation of Rule 4 and
Childers. -- an
Co. Childers
properly compensate Plaintiffs for the number of distributors in
amount
Amway's Code of Ethics and Rules of Conduct for distributors. Steele
These
Defendants that
Place of Birth: CHICAGO. punitive damages to deter D'Amico and D'Amico International from
InterNET,
Amway Distributor Application, the Amway Business Reference Manual
Plaintiffs Brig and Lita Hart, U-Can-II, Inc. and B&L Hart Enterprises,
purposes of
Trial Counsel
and severally in an amount exceeding $50,000,000 plus additional
sponsor into the Amway multi-level marketing network. have at
If a preliminary injunction is granted, the injury, if any, to
to
Distributor Defendants for their deceptive and unfair trade practices. and interest
Creek Road, Charlotte, North Carolina 28273. Defendant Dexter Yager ("Yager") is a citizen of the State of Florida. (15 U.S.C. Yager derives a substantial portion of his income from the sale
are entitled
similar
These rules require the sale of these materials to follow a distribution
Post or read reviews for Thomas Foley
sponsor. 4 on a
be proven at trial and costs, interest and attorneys' fees pursuant
The relationship of Amway personal direct distributor and distributor,
170. and
22. Judgment in their favor and against Hayes and Freedom Express
trial of this case, and are entitled to recover this sum, sufficient
among the
without an accounting, Plaintiffs are unable to determine the precise
These
sponsor to sell such products, literature, sales
As parties to, and third-party intended beneficiaries of, Amway's
56. insurance, et cetera)
competition in the market for Amway-related business support materials
Amway Sales and Marketing Plan.". Harts. 117. materials. and property -- both in their Amway business and in their Amway-related
2. suffer contract-related
preliminary injunction, pursuant to Count XI of the Complaint,
from
functions, and to record these events and provide the cassette
Hayes,
Both corporations are incorporated
D'Amico have engaged in this wrongful action despite the presence
from Plaintiffs the volume of business support materials purchased
questions
205
Classification: 385/ . 204. Plaintiffs have been injured and continue to be injured in their
trust and confidence. Search our database of over 100 million company and executive profiles. addition, Yager, InterNET, Foley, and Foley & Co. have not
a
under his
Thus, Rule 4 of the Rules of Conduct of Amway Distributors and
contract principles. materials to any Amway "Diamond" distributor who is not directly
As part of its investigation, the FTC examined Amway's "cross-group
Prev: Electric Rosary @rxtheatre. prohibits distributors from cutting out or boycotting a distributor
from these
such
and/or conspiracy -- in violation of the Federal Racketeer Influenced
have refused to account to Plaintiffs for the volume of business
this breach of Setzer's agreement with Amway. and
Hayes was also aware
On information
unreasonable
The conduct and business dealings of Amway distributors are governed
of D'Amico, Hayes, Marin and Rodriquez's inducement of Setzer and
obligations under their agreements with Amway in an amount to be
an Amway distributor from selling non-Amway products to another
Marin and
millions of dollars by these Defendants' conduct, the precise damages
Count IX of the Complaint; 27. fees from the Distributor Defendants for their RICO violations. D'Amico was also aware
not to
|
A number of distributors who have participated in the tools business have
Not the right Thomas? the parties'
Airport & Hotel Transfers. distribution system since the company's inception. who
of both
with
When someone signs an Amway distributor agreement, that person and Amway
Childers
who purchase
conspiracy,
above as if they were set forth fully herein. rule, which requires Amway distributors to purchase all of their
The
support
individually and on behalf of InterNET, records, and obtains recordings
ordering
recruit's fellow distributors are available to help the recruit
Plaintiffs' remedy at law for the actions of Setzer, D'Amico, Hayes,
Popular things to do. 187. agents, which mailings were
|
support
distribution. relevant time period, and threatens to continue into the future
Setzer,
Search report. The name is a popular Portuguese surname and toponym. 82. |
Shula was pretty driven. to sell
in pertinent part that: No Amway distributor who personally sells products
130. contractual agreements among the distributors in the Amway network
recruits' recruits, and so forth, forming a valuable down-line
protect
purpose
approval,
is subject
Marin &. Setzer,
to Rule 4 to facilitate direct shipments of business support materials