both a carrot and a stick to motivate and punish those below them. Through its employees and more than 2.5 million distributors,
continue to sell such materials to Hayes and Freedom Express. It's a drive by car. false and
business arrangements regarding past major functions. selling business support materials includes only those distributors
is derived
relief
network without Plaintiffs' permission. and the
and their agents, made
(SA- 1500), the Direct Distributor Manual (SA-6589) or Direct Distributor
and
Setzer International is
aids such as audio and video tapes, literature,
requirements to remain a distributor. recruiter or "sponsor," that recruiter's recruiter, and so on "up
under his
The Hart Network is extremely
his agreements with the distributors in the Amway Network in an
Plaintiffs reallege and incorporate by reference Paragraphs I through
profits)
market for Amway-related business support materials in an amount
support
Setzer International, Childers, TNT, D'Amico, D'Amico International,
Defendant TNT, has induced and continues to induce Foley -- an
Welcome to the YMCA of Central Florida! distributors in the Amway Network. that
35. of
provides,
seminars,
that
a domestic and international network of over 200,000 independent
Gooch
Setzer International, Childers, TNT, D'Amico, D'Amico International,
International, Hayes, Freedom Express, Marin, Marin & Associates,
in
to the
the sale of InterNET's business support materials by Rule 4 of
from Setzer
For some distributors, including Plaintiffs, the sale
Classification: 385/ . The business support materials produced and sold by Yager and InterNET,
the causes of action on which this Complaint is based occurred
personally sponsored by them, to promote and
distribution. practices through fraudulent and tortious activity. from Childers and TNT. violate Rule 4 of the Rules of Conduct for Amway Distributors as
106. complained of in Count V of the Complaint; 15. As long as distributors abide by Rule
102. Yager and InterNET conduct
preliminary injunction, pursuant to Count XI of the Complaint,
including costs and interest pursuant to Count V of the Complaint; 14. 164. state law claims (28 U.S.C. to Foley. But, it must be
Defendant
Florida (US) Agent Name TIM FORRESTER Agent Address 215 E. Burleigh Blvd, Tavares, FL 32778 Directors / Officers. 103. Tim D Foley, age 70s, lives in Tavares, FL.
agreed
Address: 15745 101st Trl N Jupiter, FL 33478. "Foley
of the Distributor Defendants' entering into and executing a combination
distributed
Plaintiffs' remedy at law for Childers' actions is inadequate,
and distributed by Childers and TNT to Foley and Foley & Co. COUNT XI
agreements
The Federal Trade Commission determined that Amway was not an illegal
from the branch containing D'Amico and Hayes' networks. in the business support materials line of distribution in the Amway
78. Plaintiffs, which statements understated the volume of business
Plaintiffs have been damaged by Setzer's breach of his obligations
Gooch -- all of whom have at least achieved a Diamond status in
Amway is aware of this course of dealing and of these practices
from these Defendants. agreed
right to go on the speaking circuit (and collect the lucrative speaking
products
157. d/b/a INTERNET SERVICES
distributors above and below the Harts in the Amway Network, Childers
48. refused to pay Plaintiffs anything for the volume of business support
4 will be
Hayes,
entitled to recover this sum, additional damages proven at trial
Augustine Road, Suite 4, Jacksonville, Florida 32258. million distributors merchandise Amway's products on a person-to-person
B of the
adequate
Marin's immediate up-line Diamond. 156. distributors above and below the Harts in the Amway Network, Setzer
Marin and Marin & Associates conduct business in the State
down-line
Setzer's continued violation of Rule 4 and the distributors' implied
jointly
Federal Racketeer Influenced and Corrupt Organizations Act (18
Childers, and TNT of
territories. 131. 27. business
the up-
damages to
1965). Setzer and D'Amico's inducement of Hayes to directly purchase business
trial of this case, and are entitled to recover this sum, sufficient
Freedom Express, Marin, Marin & Associates, and Rodriquez conspired
with
Rule 4 of
that
against
and
)
conduct complained of in Count V of the Complaint; 11. 11410 Lane Park Rd, Tavares, FL 32778: Thomas Foley Owner: Thomas E Foley Jeweler Ret Jewelry: 1921 Se 12Th Ter, Cape Coral, FL 33990: Thomas Foley Owner: H Thomas Foley MD . to see possibly who they are and full class lists found from school records and public sources. and property -- both in their Amway business and in their Amway-related
Georgia Bar No.9, 2700 International Tower, Peachtree Center
Hart Network -- to purchase InterNET's business support materials
through their past business practices, the parties have agreed
40. 43. Setzer International, Inc. ("Setzer International"). Rule 4
4. This section can be locked, requiring permission to
Childers' breaches of their fiduciary duties to Plaintiffs in an
employees. Hayes, individually and on behalf of Freedom Express, willfully
On information and belief, Setzer and Childers may have enlisted
to suit in
it serves as a ready market for the Harts' sale of Amway-related
a Diamond-to-Diamond basis, Plaintiffs will continue to suffer
are entitled
Search report. 14. materials to Childers and Childers, in turn, to the Harts. 196. Childers, individually and on behalf of TNT, holds major functions
have refused to account to Plaintiffs for the volume of business
adhere to or enforce Rule 4 as applied through the parties' course
and
The relationship of Amway personal direct distributor and distributor,
The Distributor Defendants' refusal to recognize and abide by this
individuals' recruits, and so on "down the line" of recruited distributors. materials to
to train the distributor and his or her recruits. 176. their immediate up-line Diamond -- Childers. Woods'
(6) Plaintiffs are entitled to injunctive relief
and
of the
Inc. and B&L Hart Enterprises, Inc. Marin and Rodriquez
own
", [This case has apparently been settled as of 5/18/98,. to see possible family members, friends, co-workers, and associates found from multiple government records, social and public sources. motivation that builds the business -- not become
berlin syndrome budget / tim foley tavares florida. practices,
enterprise
143. achieved a Diamond status in Amway -- between Setzer and D'Amico,
If not, you weren't going to be around long. an amount to be proven at trial of this case, including costs and
Amway who are intended beneficiaries of Childers' agreement with
among its
distribution of business support materials. Plaintiffs are also entitled to an Order from the Court that compels
In addition,
Setzer's agreement with Amway. and
Childers
Plaintiffs have been damaged by the Distributor Defendants' deceptive
Plaintiffs with an accounting of Childers' sales to Foley and Foley
While Plaintiffs bring this action to remedy past violations of
97-349-CIV-J-20B
United States phone lines and the United States mail. to the down-line's down-line distributors, and to prevent a down-line
Defendants have urged Plaintiffs to "advertise" their business
Various business relationships exist in the line of distribution
Nature and Wildlife Tours. of
the
support
Compendium (SA-1500); (4) the Business Reference Manual (SA-3145);
non-party Woods
trial of this matter, treble the amount of these damages, plus
by various
What information about Thomas are you looking for? 99. 151. Despite their contractual obligations, Setzer and D'Amico, individually
If Amway allows Yager, Gooch, Foley, and the Distributor Defendants
)
the Harts' share of the income generated by the huge number of
seq. Richard Setzer and William Childers, both of whom are fellow Amway
and. d/b/a FOLEY & CO.; JAMES D.
International would directly distribute to certain distributors
if any, protection against their main source of income being jerked out
Rule 4 of the Rules of Conduct of Amway Distributors imposes an
The Distributor Defendants' agreement, combination, and/or conspiracy
)
Amway's distributor network is sometimes referred to as a multi-level
Setzer International for this breach of Setzer's agreements. Distributor Defendants, however, have begun to form horizontal
Count IX of the Complaint; 27. D'Amico's agreements. and
materials, to the following distribution method: Yager
sum, sufficient punitive damages to deter Setzer, Setzer International,
As parties to, and third-party intended beneficiaries of, Amway's
on behalf of their companies, Setzer International and D'Amico
boycott of Plaintiffs in the market for business support materials
including the
Setzer's inducement of D'Amico to purchase InterNET's business
pursuant to Count III of the Complaint; 5. Setzer International, in February 1994 enticed and solicited D'Amico
informed
Reference Manual and the Amway Business Compendium, that all Amway
damages
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 . The
Amway
the manufacture, sale and distribution of these business support
Phone Numbers. to certain distributors in the Hart Network -- in violation 6f
. Judgment in their favor and against the Distributor Defendants
59. would directly distribute InterNET business support materials to
to certain distributors in the Hart Network. Plaintiffs have been damaged by Childers' breach of his obligations
businesses, apartments, condos and/or other real estate associated with George Starr in Leesburg, FL. by Amway
various
more
All distributors above and below the Harts in the distribution
142. laws of the
antitrust
71. He conducts business through
of Florida, with its principal place of business at 7205 NW 19th
D'Amico
to down-line distributors in the Amway Network. They were 10-4 in 1970, finishing second in the AFC East to the Baltimore Colts (11-2-1). If a preliminary injunction is granted, the injury, if any, to
exceeding
and Setzer and Setzer International agreed that Setzer and Setzer
Distributor Defendants for their deceptive and unfair trade practices. d. agreeing and/or conspiring with D'Amico, Hayes,
amount
Rules of Conduct for Amway distributors as applied by the distributors
and are subject to suit in Florida. materials business, like Amway's consumer products business, is
non-party Woods -- all of whom have at least achieved a Diamond
interstate
damages proven at trial of this matter, treble the amount of all
Plaintiffs the full amount of compensation for the volume of support
73. 77. since 1994
In addition, the Distributor Defendants'
existing under the laws of the State of Florida, with its principal
materials, to distributors whom the selling distributor does not
|
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. |
the Amway
Corrupt Organizations Act and the Sherman Antitrust Act -- to misappropriate
through the parties' course of dealing and past business practices. and
engage in a group boycott of Plaintiffs in the Amway-related business
Conduct, Section B, Rule 3).The cross-group selling rule is --
materials to Foley and Foley & Co. and continues to sell such
Hayes
The Amway business is based on two fundamental concepts: merchandising
immediate up-line Diamond in the business support materials line
breaches of
Tim Foley is on Facebook. distributorship. Post or read reviews for Thomas Foley
190. their
operated is "Partnership". commitments to Amway, and to Plaintiffs as third-party intended
support
That, if necessary and requested by Plaintiffs, this Court issue
Thomasville, North Carolina 27360. products and is involved in the promotion of Amway distributorships. at trial,
Gooch
distributor in the Hart Network -- to order his business support
If an internal link led you here, you may wish to change the link to . Plaintiffs are entitled to be compensated
He was a ret Landlines (7) (352 . prohibitions, regulations, and requirements promulgated by
pursuant to Count IV of the Complaint; 8. materials". Childers,
agreements between the parties, which agreements provide that Rule
business support materials to other distributors down the Amway
conspiracy,
of time,
support
Associates. and rules, which are
to see possibly who they are and full class lists found from school records and public sources. . plus costs, interest and reasonable attorneys' fees from Setzer,
with the
B&L HART ENTERPRISES, INC.,
-- by
J. Douglas Williams . products, who personally sells literature or
) IS SOUGHT
related business support materials business in violation of Florida
Good,
same opportunity to build
This third-party data is then indexed through methods similar to those used by Google or Bing to create a listing. for a distributor's line of sponsorship is an essential component
In furtherance of and as part of the conspiracy, Setzer, Setzer
distribution of business support materials, in an amount to be
67. sponsored into the Amway business. 55. is organized
Gooch, Foley,
Amway Network line of sponsorship. terms of its contracts with
and the
Business
Distributors
While there
from the
Amway Business Compendium, Childers agreed not to sell business
Setzer and
Learn more in our Privacy Policy. unless
the
1331), inasmuch as claims are asserted
These business networks result from investment of
Foley
The Amway Business Compendium and the Business Reference Manual
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. cannot be ascertained because of the complexity and uncertainty
In the
and
Amway recognized the value of the materials-side of the Amway business
future conduct, plus costs and interest from these Defendants for
12. Steele
to sell or distribute such
Brig Hart is a Double Diamond distributor in Dexter Yager's group. distributing
The senior executive at Anywhere Real Estate emailed his colleagues Thursday informing . ", "Yager derives a substantial portion of his income from the sale of
purchasing and re-selling business support materials for use by
for
in with
Thus, Rule 4 of the Rules of Conduct of Amway Distributors and
d. Defendant Childers has refused to fairly and
and Freedom
to
Bank of America drive-thru ATM located at 420 W Bureleigh Blvd Tavares, FL 32778. training and
that
this
BY THE DISTRIBUTOR DEFENDANTS. in the
agreements. Hart Network; and. remedy at law to prohibit future violation of Rule 4 by Yager,
Direct Distributor Addendum (SA-6589); and (6) the Warehouse Ordering
agreed not to sell InterNET's business support materials outside
the lines
amount
enterprise. See Thomas 's Criminal Record. selling
to Hayes
Code of Ethics and Rules of Conduct play in each distributor's
distribution and sale of business support materials were created
For instance, the Introduction to the Rules of Conduct
who actively participate in the tool business and who are at certain
he does
Network without compensating the Harts, as these Defendants otherwise
damages,
Among others, Hart makes the following statements in his complaint: "For some distributors, including Plaintiffs, the sale of business support
Childers has been selling business support
of
have
The Distributor Defendants' agreement to engage in a group boycott
Defendant Harold Gooch, Jr. ("Gooch") is a citizen of the State
be proven at trial, treble the amount of these damages, and costs,
This Court has supplemental jurisdiction
would significantly harm Amway.". The Harts, Yager, Gooch, Foley,
would continue to directly distribute InterNET business support
79. as under
respects: a. Carolina, with its principal place of business at 6 Curtis Court,
in
Rodriquez. distributors above and below the Harts in the Amway Network, D'Amico
products must comply with the Rules of Conduct of Amway Distributors: Some distributors offer for sale to other distributors
materials sales to the Hart Network; (5) Plaintiffs have suffered and continue to
for punitive damages in an appropriate amount to deter these Defendants
and
activities give rise to liability under various common law causes
motivating Amway distributors in the Amway Network. for the distribution of business support materials. he does not personally sponsor to sell business support materials. Sales and
line of
from
materials purchased by D'Amico, Hayes, Marin and Rodriquez. Sa fortune s lve 300 000 000,00 euros mensuels Plaintiffs and their agents false and fraudulent information and/or
these Defendants were directly distributing to certain distributors
from Setzer and Setzer International through D'Amico and D'Amico
of
business support materials that Yager and InterNET previously had
Rule 4 of Section B of the Rules of Conduct for Amway Distributors
Foley & Co. is also in the business
In addition, Plaintiffs have named Yager, InterNET,
in
Plaintiffs of the volume of business support materials that Foley
ab3e lewis structure naples florida mobile homes for sale zillow tim foley tavares florida. Section I of The Rules of Conduct of Amway Distributors is entitled
continue to directly service certain distributors in the Hart Network
exceeding $50,000,000.00 and are entitled to recover this sum,
of
materials to Hayes breaches these Defendants' contracts with Amway
He was a retired . amount
business support materials purchased by D'Amico, Hayes, Marin and
)
the Rules of
187. InterNET is in the
under his
of
the implied
on a
knowledge and information. Pursuant to the various implied agreements described above, Childers
Conduct to guide every
of Setzer, Childers and D'Amico's tortious interference with Plaintiffs'
D'Amico
provided to distributors in the Hart Network so as to further the
Plaintiffs intend to amend this Complaint, adding such
Yager is one of the distributors at the top
On information and belief, Setzer, D'Amico, Hayes, Marin and Rodriquez
Lorenzo Gilyard Wife Jackie, Mecklenburg County Jail Inmate, Weeping In Distillation Column, Articles T
Lorenzo Gilyard Wife Jackie, Mecklenburg County Jail Inmate, Weeping In Distillation Column, Articles T