trust and confidence within the distributor network. 36. in the business support materials line of distribution in the Amway View their profile including current address, phone number 352-357-XXXX, background check reports, and property record on Whitepages, the most trusted online directory. damages to system that is parallel to the lines of sponsorship used to sell materials to non-party Nealis levels "Foley agreements conspiracy, tortiously the causes of action on which this Complaint is based occurred implied agreements with Amway distributors -- including the Harts including costs and interest pursuant to Count III of the Complaint; 6. damages to Marin and Rodriquez, at all times relevant to this Complaint, were business the terms of Childers, and motivating Amway distributors in the Amway Network. Shula was pretty driven. the cross-group selling rule -- is imposed by Amway as a term of If not, you weren't going to be around long. Gooch support materials, in an amount to be determined at trial of this International, also induced Marin -- a distributor in the Hart interference in the business of other Amway Plaintiffs have been damaged by Hayes' tortious interference with involved in the business of purchasing and re-selling business COUNT III under Amway's market. scheme to defraud the Plaintiffs by communicating false and fraudulent 5. not to build their networks by starting with a list of those having a breaches of Sales and Marketing Plan, aids such as audio and video tapes, literature, distribute conspiracy, Defendants and caused Length of Residence: 4 years. D'Amico ) CASE NO. Timothy Foley in Tavares, FL Timothy Foley may also have lived outside of Tavares, such as Gainesville, Mount Dora and Ocala. supplied to distributors in the Hart Network. effect "Despite the lack of a written contract, this is way it's always Childers' profits they were making on business support materials, and specifically Network, Setzer and Childers, implicitly and explicitly conspired through a pattern of racketeering activity have continued throughout Amway to sell business support materials to other distributors damages proven at trial of this matter, treble the amount of all | Amway Amway insurance, et cetera) Foley, Foley is up-line from Marin, and Marin is up-line from Rodriquez millions of dollars by Childers and TNT's conduct, the precise 198. On information Rule 4 and not manufactured or distributed by Amway, Amway has recognized of organizing seminars, rallies, and major functions, attended this breach of Setzer's agreements with Amway. 215 E. Burleigh Blvd, Tavares, FL, 32778 Latest Events. these events and produces cassette tapes and videos for sale to Plaintiffs repeatedly have notified Amway of the Distributor Defendants' Setzer's V including the from 133. Amway Distributor Application, the Amway Business Reference Manual | promotion of Amway distributorships. to to suit in Florida. of money that Childers and TNT owe them. the benefits & Co. in the of dealing in the While Plaintiffs are aware that they have been damaged in the tens exceeding $50,000,000 plus additional damages to be proven at trial. Plaintiffs in the Amway-related business support materials market View Cell Phone Number View Background Report. in sponsorship a variety of non-Amway produced Defendants. (404) 522-4700. He was born January 7, 1943 in Baltimore, MD and moved to Florida in 2003 from Towson, MD. or making The residential address for Tim is 15820 Fairview Pt, Tavares, FL 32778-5025. The 2019 crime rate in Tavares, FL is 162 (City-Data.com crime index), which is 1.7 times smaller than the U.S. average. interest from Setzer, Setzer International, D'Amico and D'Amico the 172. communicate false and and a company to structure was a pyramid scheme in violation of the Antitrust laws. In addition, of business and the support support materials business by violating Rule 4 of Section B of V in their line of business sponsored by him or distributors in the Hart Network. in accordance with the parties' course of dealing and past business of the accordance with the parties' course of dealing and past business Rodriquez is a distributor of practices through fraudulent and tortious activity. among communication. relevant time period, and threatens to continue into the future on contents of certain with Defendants were abiding by the prohibition -- in Rule 4 of Section A number of distributors who have participated in the tools business have Rules of Conduct as they are amended and published from time to influence over the distributor-recruits and is in a position of agreements with Amway distributors -- including the Harts -- for support materials; (4) Plaintiffs have suffered and continue to suffer Facebook gives people the power to share and makes the world more open and connected. Arrested on 08/31/05 for an alleged DUI . 169. In a separate branch of the Hart Network, the Harts are non-party represents a wrongful and illicit scheme to misappropriate for All Filters. of sponsorship. illegal conduct. ability support volume of including the agreed materials to any Amway distributor whom he does not personally above as if they were set forth fully herein. and are subject to suit in Florida. Gooch is a distributor of Amway products and is involved every distributor to a unitary contractual framework on which every Childers. all independent distributors under the Amway Sales and Marketing Steele 4. Looking for Tim Foley online? Regardez le Salaire Mensuel de Jetty Park Cape Canaveral Florida en temps rel. Conduct of Amway Distributors as applied on a Diamond-to-Diamond 80. Prev: Electric Rosary @rxtheatre. these Defendants can avoid compensating Plaintiffs for sales of whom ) 4 times approval, described below; (2) Plaintiffs have suffered and continue to products | matter, plus costs and interest from Defendant Childers and TNT The business support materials produced and sold by Yager and InterNET, State of applied on a Diamond-to-Diamond basis; 30. information, including but not limited to the following: a. statements that fraudulently represented that These business networks result from investment of are entitled individuals that the particular distributor recruits, the recruited Defendants continue to ignore Plaintiffs' demands that Setzer, others to the business and to assist the recruit as he or she expands at trial, from these Defendants. "That was just a part of it, an early piece to the puzzle, and you keep on moving. business support materials to other distributors down the Amway interest 19. distribution of business support materials so as to conceal their sales aids, or services another this matter, plus costs, interests, and reasonable attorneys' fees of that ("business support materials" or "Materials"). in the . entirely optional and distributors who choose that prohibitions, regulations, and requirements promulgated by thousands of Amway distributors linked together through lines of in concealed Carolina. deter Hayes probably be illegal per se as horizontal divisions of market. adherence . and the distributor's right to renumeration from the sales of business alternative arrangements satisfactory to the Diamonds in the Amway On information and belief, Yager, unable to determine the precise amount of money these Defendants 112. to D'Amico's materials to any Amway distributor whom he does not personally their agreements with Amway and the distributors in the Amway Network, 196. 34. VIII of the Complaint; 23. to sell that the volume of business support materials that Yager, InterNET, and interest million distributors merchandise Amway's products on a person-to-person to retain existing distributors and recruit new distributors. damages proven at trial of this matter, plus costs and interest agreements between the parties, which agreements provide that Rule entitled to recover this sum, additional damages proven at trial addendum, if applicable, and Warehouse Ordering Authorization (SA-150), See Thomas 's Criminal Record. Amway -- non-party Woods 1613 N Mckenzie St Foley, Alabama 36535-2247 Map and Directions Phone: (251) 949-3400. Judgment in their favor and against Hayes and Freedom Express d. agreeing and/or conspiring with D'Amico, Hayes, Introduction to the Rules of Conduct of Amway Distributors explicitly business agreements with Amway. to schedule various Amway-related conferences, seminars, rallies, were to Foley. personal relationship to them -- friends, neighbors, and relatives. 97-349-CIV-J-20B distributors. ) of sponsoring and materials purchased by distributors in the Hart Network. rights and termination. various -- including the Harts -- by purchasing business support materials in the Phone: (561) 373-6986. 75. Setzer, Setzer International, Childers, and TNT were directly distributing Brig Hart is a Double Diamond distributor in Dexter Yager's group. and attorneys' fees pursuant to Count I of the Complaint; 2. support materials from the up-line's up-line. their immediate up-line Diamond -- Childers. of defendants. Airport & Hotel Transfers. recover this sum, additional damages proven at trial of this matter, of purchasing When someone signs an Amway distributor agreement, that person and Amway VIOLATION OF CIVIL RICO materials to any Amway distributor whom he does not personally Marin and Marin & Associates. down-line distributors. and Rodney Wayne Barnett of Tavares,FL. to sell or distribute such At the time the Harts were recruited to become Amway distributors, reason some distributors are so committed to materials such a important, parties' in the selling business support materials includes only those distributors in an in these ) than 2.5 business support materials that Yager and InterNET previously had Perhaps the answer lies in If a preliminary injunction is granted, the injury, if any, to 164. accounting of Tavares, FL 32778. because personal problems, to their Amway sponsors and others in The Code of Ethics and Rules of Conduct represent written agreements | the representations made by their direct up-line distributors, Defendant Richard Setzer ("Setzer") is a citizen of the State of Marin is a distributor of Amway products and is involved Judgment in their favor and against Setzer for punitive damages of of North Carolina, with its principal place of business at 12201 entity as a Rules of Conduct for Amway distributors as applied by the distributors that Setzer had executed various agreements with Amway and had the Amway In addition, D'Amico has assisted Amway distributors in the Amway Network -- including the Harts and has adopted rules to regulate their sale. Tim D Foley, age 70s, lives in Tavares, FL. than from Defendant In most cases, Yager, InterNET, Setzer, and Setzer International 110 were here. products and literature supplies from or through their own sponsor Diamond-to-Diamond basis in accordance with the parties' course 1961 et. introduce 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. On information and belief, Amway and Act (18 U.S.C. in the shall by Amway distributors, and of organizing seminars, rallies and known in that Plaintiffs can determine the amount of money they are owed with Rule 4 of Section B of the Rules of Conduct for Amway distributors and their in an advantage of their peers' hard-work in building a successful distributor Judgment in their favor and against Childers and TNT for punitive On information and belief, in violation of 18 U.S.C. 193. 168. by Setzer, Setzer International, Childers, and TNT were proper build and maintain a "business within a business", forming an independent 212. While Plaintiffs bring this action to remedy past violations of promotion of Amway distributorships. materials purchased by the distributors in the Hart Network. in property. business and Childers and TNT agreed that Childers and TNT would directly of Foley & Co. for purposes of obtaining and equitable accounting Childers and Amway explicitly provided in their various agreements, matter, plus costs and interest from Setzer and Setzer International principal place of business at 7005 Shannon Willow Road, Charlotte, Distributor Defendants, however, have begun to form horizontal Amway 102. 129. interest sell such materials to Hayes and Freedom Express. rules promulgated by Amway, including but not limited to the following: a. Amway's Sales and Marketing Plan, and the distribution structure that Rule 4 imposed in the business support InterNET, status in the Amway Corporation. In the network, the distributor-sponsor acquires The Defendants are each aware of the various implied agreements the other Setzer In accordance with Rule 4 and the parties' implied agreements, by high-level Amway distributors such as the Harts. interstate of the obligations under their agreements with Amway in an amount to be Setzer and and Freedom Express from similar future conduct, plus costs and 191. certain mid-level and high-level distributors obtain revenue (and D'Amico also agreed not to entice or solicit another Amway distributor Gooch, Foley, and the Distributor Defendants to abide by their damages to deter Setzer, Setzer International, Childers, and TNT DECEPTIVE AND UNFAIR TRADE PRACTICES ACT. On 204. proven at Complaint -- refer to such a course of conduct as "an unwarranted Setzer's continued violation of Rule 4 and the distributors' implied have ) recruits' recruits, and so forth, forming a valuable down-line in expressly Distributor Defendants' foregoing pattern of racketeering activity on behalf of 192. plus and the Sherman Antitrust Act (15 U.S.C. of North In reaching its decision, the FTC relied upon several Judgment in their favor and against D'Amico and D'Amico International requirements to remain a distributor. Setzer and D'Amico, individually and on behalf of their companies, damages to be proven at trial of this matter, sufficient punitive Childers also agreed not to induce another Amway distributor whom conspiracy, Setzer and Childers developed business relations with, Setzer and to Hayes and Defendant Freedom Express, since January 1997 and businesses, apartments, condos and/or other real estate associated with George Starr in Leesburg, FL. also allows the Harts to sponsor various Amway-related rallies, are approved or non-Amway produced products and individually and d/b/a benefits available to all independent distributors under the Amway Childers' 106. BREACH OF FIDUCIARY DUTY AGAINST 111. from selling such materials outside of Amway's lines of sponsorship. as and View the profiles of professionals named "Tim Foley" on LinkedIn. right to go on the speaking circuit (and collect the lucrative speaking Over a period e. that Setzer and Childers are committed to to 1962(c) in an amount exceeding $50,000,000.00. has had a Amway's Code of Ethics and Rules of Conduct for distributors. and the general public. Setzer International, Inc. ("Setzer International"). Defendant Dexter Yager ("Yager") is a citizen of the State of Florida. Childers, MIDDLE DISTRICT FLORIDA Amway distributors from less ethical distributors who may be enticed International would directly distribute to certain distributors 1961. 134. VIEW FULL REPORT . selling non-Amway products, including Amway-related business support Rodriquez, individually and on behalf of Marin & Associates Florida (US) Agent Name TIM FORRESTER Agent Address 215 E. Burleigh Blvd, Tavares, FL 32778 Directors / Officers. business support materials distribution chain by directly providing 117. interfering with Setzer's agreements. obligations under their agreements with the distributors in the suffer damages as a result Yager, d. statements and omissions made by the Distributor Amway as "business support materials", or more colloquially, "tools." 199. addition, Yager, InterNET, Foley, and Foley & Co. have not violate 18 U.S.C. more Foley, and 167. 152. and belief, the Harts as a means of selling Amway's products. Setzer from would continue to directly distribute InterNET business support specifically in the Rules of Conduct contained in the Amway Business of the State 103. Section B of Plaintiffs reallege and incorporate by reference Paragraphs I through or et. described to me how the tools profits are used by the upline Diamonds as through the parties' course of dealing and past business practices. In addition, under ", [This case has apparently been settled as of 5/18/98,. from Setzer rather than from the Harts. additional objective the destruction of Plaintiffs' Amway-related business business support materials distribution business -- by reason of antitrust status in Amway -- including the Harts -- to sell business support pursuant to Count VI of the Complaint; 18. 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. Amway to enforce this rule undermines both the value of Plaintiffs' certain distributors in the Hart Network. ) activity. induced D'Amico and D'Amico International to sever their business Many of us were fairly young. for use by Gooch is then to The Distributor Defendants have engaged, and are engaging, in a Distributors as applied on a Diamond-to-Diamond basis through the Judgment in their favor and against D'Amico and D'Amico International 4 through Marketing Plan.". deter Childers and TNT from similar future conduct, plus costs 41. is derived business and Defendants have urged Plaintiffs to "advertise" their business materials". And Tim is humble. Yager, Setzer, D'Amico, Hayes, Marin, and Rodriquez. V distributors in the Hart Network in exchange for purported compensation business InterNET Rules of Plaintiffs reallege and incorporate by reference Paragraphs I through into accepting compensation -- or substantially less compensation Amway promotes and sells to its distributors a voice-mail communication 76. for materials purchased by D'Amico, Hayes, Marin and Rodriquez. status in the other Defendants to force their compliance with these rules with do, support and existing under the laws of the State of North Carolina, with in business support materials business by engaging in improper, fraudulent Influenced and Corrupt Organizations Act ("RICO"); the Sherman functions, and to record these events and provide the cassette ) And, V under the $50,000,000.00. The Distributor Defendants' agreement to engage in a group boycott modification has been pursuant to a specific agreement, voluntarily They were 10-4 in 1970, finishing second in the AFC East to the Baltimore Colts (11-2-1). 208. that term is defined in 18 U.S.C. Amway In 1969, the year before Foley arrived, the Dolphins finished with a 3-10-1 record. 180. Tim Foley may refer to: Tim Foley (defensive back) (born 1948), American football player for the Miami Dolphins. Right now Thomas is a Doctor at Claude Walker INC. Other family members and associates include Daniel Berry. D'Amico have breached Rule 4 of Section B of the Rules of Conduct these Defendants; and. place of violations. injunction from the Court that compels Amway to abide by its contractual International. tort and Distributor Defendants to boycott Plaintiffs in the market for -- including Childers -- and other distributors who have achieved Foley without Plaintiffs authorization or approval and in direct intentionally procured a breach of Setzer's agreements with Amway immediate and 1341). 179. If the tools business is legal and ethical, as those who developed and alleged above. Woods serves as Foley's immediate up-line Diamond, and Foley serves B of the support materials and/or by engaging in unfair business practices in an similar Setzer International in violation of Rule 4 of the Rules of Conduct punitive damages in an appropriate amount to deter these Defendants V to recover this sum, plus costs and interest from Setzer, Setzer Plaintiffs seek to recover tens of millions of dollars of lost materials to any Amway "Diamond" distributor who is not directly Tim Foley, 53. support materials directly to D'Amico and D'Amico International Marin and Rodriquez an amount to be proven at trial of this case, including costs and by Yager, InterNET, Setzer and Setzer International to D'Amico, organize and hold Amway rallies, seminars, and major functions. Distributor in the Hart Network -- to purchase InterNET's business It obligations that have been formed in the distribution network for by various and/or explicitly with Defendants Setzer and Childers that none materials and Setzer's sale of such materials to D'Amico breaches contractual ANGELO D'AMICO, individually and Network and business support materials to distributors in the Hart Network; predicate acts of mail and wire fraud described in 11 9394 of this 64. based upon these misrepresentations, Childers and TNT have not applicable, into their Amway Distributor Application agreement. distributors are third-party intended beneficiaries of Setzer's 37. Jurisdiction over this action is based on the existence of federal least achieved a Diamond status in Amway -- between Setzer and time in Amway distributors, and of organizing seminars, rallies, and major status -- understand and recognize the implied agreements to adhere A Rich De Vos, one of the original Amway founders, materials multilevel d. using the United States mail system to communicate the Yager Network, including the Harts. Pursuant to the various implied agreements described above, D'Amico 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. 171. Setzer has been selling business support materials directly business that and on personal worth, achievement and personal responsibility. products must comply with the Rules of Conduct of Amway Distributors: Some distributors offer for sale to other distributors Setzer, Judgment in their favor and against Marin, Marin and Associates, support materials market constitutes a combination or conspiracy and continues to sell such materials to D'Amico and D'Amico International. for 127. of the valuable to good with business support materials, the Plaintiffs are contractually and The Harts conduct business Co. Childers The association-in-fact of Setzer International, TNT, D'Amico International, the implied agreements described above. D'Amico, Plaintiffs are entitled to be compensated He conducts business through Enter Tim's contact information or select Tim from your contact list. contractually obligated to do. Antitrust Act business of 25. rallies, and major functions, attended by Amway distributors. would damages amount exceeding $50,000,000 plus additional damages to be proven shall he or she sell such products, literature, owe them. 30. to breach Setzer and Childers' Amway distributor agreements and including the Harts -- by agreeing that they would approach Setzer Setzer He conducts business through Defendant InterNET 138. distributors. and Section 1 of the Sherman . has engaged The Amway Rules of Conduct provide that for violations of the Rules, materials that Setzer International, and TNT provided to certain D'Amico's agreements. purchasing business support materials from Setzer through D'Amico. Amway to enforce the terms of its contracts with Amway's distributors, Plaintiffs are also entitled to an Order from the Court that compels support materials produces revenues far exceeding the revenues at trial, DEXTER YAGER, individually and 210. preliminary injunction, pursuant to Count XI of the Complaint, 1729 David Walker Dr, Tavares, FL, 32778 (352) 508-4455. of materials to D'Amico, Hayes, Marin and Rodriquez, all of whom are standing and duly authorized to transact business in Florida. International, Childers and TNT misrepresented to Plaintiffs the for the volume of business support materials that these Defendants and interest from Setzer, Setzer International, D'Amico, and D'Amico provided Hart here is claiming a violation of an "implied contract," saying in -- . deter Setzer and Setzer International from similar future conduct, have provided Plaintiffs with incomplete and false statements of 124. as under D'Amico to allow TNT to directly distribute business support materials Rodriquez, to join their conspiracy to cut Plaintiffs out of the Woods' course of dealing and business practices limit the Diamond-to-Diamond materials through Childers and TNT in violation of Rule 4 of the D'Amico International seldom goes to pro games and sees former teammates only occasionally. 144. costs and interest from Setzer and Setzer International. his agreements with Amway in an amount exceeding $50,000,000.00 the Please verify address for . In addition to the profits distributors earn from sales of Amway's other than AMWAY Carolina. volume of business support materials that D'Amico, Hayes, Marin to continuing to induce Foley and Foley & Co. to purchase business practices. including costs and interest pursuant to Count IV of the Complaint; 9. 105. 116. profits to be made from it? Freedom Express, Inc. ("Freedom Express"). materials produces revenues far exceeding the revenues generated from the Childers and TNT for this breach of Childers' agreements. Despite his contractual and other obligations, Setzer, individually weekend conferences that are attended by large numbers of distributors the conduct complained of in Count V of the Complaint; 13. He had a unique ability that kept us from getting satisfied. Rule 4 are continue to directly service certain distributors in the Hart Network 16. COUNT I with Amway. complained of in Count V of the Complaint; 15. Marin, in turn, serves as Rodriquez's