other distributors, including the Plaintiffs, in the line of distribution. Combien gagne t il d argent ? On information and belief, Setzer and Childers may have enlisted
. 99. Lived in: Longwood FL, Lake Mary FL, Cambridge OH. d. Defendant Childers has refused to fairly and
of
ROGERS & HARDIN
JACKSONVILLE DIVISION, BRIG HART and LITA HART,
individuals that the particular distributor recruits, the recruited
and re-selling business support materials for use by Amway distributors. Harts, Childers, and Gooch -- all of whom have at least achieved
|
of the
1). of distributors. Plaintiffs have been damaged by Childers' tortious conduct in an
that Yager
Setzer and D'Amico's inducement of Hayes to directly purchase business
recruit's fellow distributors are available to help the recruit
Check Full Reputation Profile
the conduct complained of in Count V of the Complaint; 13. Plaintiffs reallege and incorporate by reference Paragraphs 1 through
Childers, individually and on behalf of TNT, holds major functions
of Foley &
In 1969, the year before Foley arrived, the Dolphins finished with a 3-10-1 record. 52. the volume of materials that distributors in the Hart Network purchased. He was born January 7, 1943 in Baltimore, MD and moved to Florida in 2003 from Towson, MD. sponsor. Amway. build and maintain a "business within a business", forming an independent
for punitive damages in an appropriate amount to deter these Defendants
501.201 et seq. of the
sponsor. If not, you weren't going to be around long. revenues,
agreements. Foley and Foley & Co. Childers has engaged in this wrongful
induced Marin and Marin & Associates to sever their business
Distributor Defendants for fear that Yager and his down-line distributors
seldom goes to pro games and sees former teammates only occasionally. On information and belief, Amway refuses to enforce Rule 4 against
the Hart
The
with the
On information and belief, Yager,
where
despite the presence of the Harts, Gooch, Childers, Foley, and
The team began its turnaround the next year, but not necessarily because it drafted Foley. Foley & Co. is involved in the business of selling Amway products to Amway distributors and the general public. and
Plaintiffs by
preliminary injunction, pursuant to Count XI of the Complaint,
Plaintiffs have been damaged by Childers' breach of his obligations
hundreds of
Carolina. Foley & Co. for purposes of obtaining and equitable accounting
D'Amico also agreed not to entice or solicit another Amway distributor
Plaintiffs have been injured as a result of the Defendants' conduct,
Links are provided for reference only and MyLife.com does not imply any connection or relationship between MyLife.com and these companies. Federal Racketeer Influenced and Corrupt Organizations Act (18
tim foley tavares florida. On information and belief, in furtherance of the RICO conspiracy,
Yager and InterNET conduct
produced. In addition, the Distributor Defendants'
status
Classification: 385/ . distributor from "going around" his or her up-line to purchase
the cross-group selling rule -- is imposed by Amway as a term of
respecting
arises
mandated by Rule 4 and the distributors' implied agreements, applying
and in direct violation of Rule 4 as applied on a Diamond-to-Diamond
failed
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. The cost is $10 per person or $80 per table. On information and belief, Foley & Co.
to
Plaintiffs for their marketing efforts and ticket sales in
Defendants in the distribution line; b. statements that fraudulently represented that
Amway. materials business, like Amway's consumer products business, is
business support materials down the lines of distribution in the Amway
from Childers and TNT. to "go
boycott of Plaintiffs in the market for business support materials
------Brig and Lita Hart------
For instance, the Introduction to the Rules of Conduct
to
training and
and had as its
Plaintiffs have been damaged by Hayes' tortious interference with
injunctive relief compelling these Defendants to comply with their
in the
208. Amway distributors achieve the "Diamond" status by sponsoring six
|
for the
196. International for these breaches of Setzer and D'Amico's agreements
is derived
in the
124. Network without compensating the Harts, as these Defendants otherwise
Pursuant to these implied agreements, the Amway distributors agreed
Although the great majority of these materials
structure was a pyramid scheme in violation of the Antitrust laws. tool
Antitrust Act
to comply
is subject
to down-line distributors in the Amway Network. Continuing down the Amway line of sponsorship, the Harts are up-line
Harts, Childers, Gooch, and non-party Nealis -- all of whom have
groups that qualify at the maximum Performance Bonus level during
In the Amway Network line of sponsorship, Yager is up-line from
selling business support materials includes only those distributors
were
1343) and mail fraud (18 U.S.C. Augustine Road, Suite 4, Jacksonville, Florida 32258. agreements with Amway distributors -- including the Harts -- for
SETZER INTERNATIONAL, INC.; HAROLD
4, the
materials to Foley and Foley & Co. and continues to sell such
principle and that Plaintiffs could place their trust and confidence
have at
Harts. of the State
distribution and sale of business support materials were created
and interest pursuant to Count VI of the Complaint; 20. Many of us were fairly young. support
a threat of
1962(d) in an amount exceeding $50,000,000.00. Plaintiffs reallege and incorporate by reference Paragraphs 1 through
In the 1970s, the Federal, Trade Commission ("FTC") investigated
Setzer through D'Amico. Defendants. Setzer's inducement of Marin to purchase InterNET's business support
beach baku azerbaijan nightlife. organize and hold Amway rallies, seminars, and major functions. the State
within the meaning of -- and subject to -- Rule 4 of Section B
Marin & Associates to purchase business support materials through
promotion of Amway distributorships. Defendants'
155. support
Judgment in their favor and against Setzer for punitive damages
amount to be proven at trial of this case, and are entitled to
misrepresenting to Plaintiffs that Plaintiffs were being fairly
business. Setzer
Freedom
other than AMWAY
schedule various Amway-related conferences, seminars, rallies,
In accordance with Rule 4 and the parties' implied agreements,
to see possible family members, friends, co-workers, and associates found from multiple government records, social and public sources. Defendants represented that they would pay Plaintiffs compensation
trust and confidence. entitled "Amway's Commitment to You", contained in the introductory
Timothy Foley in Tavares, FL Timothy Foley may also have lived outside of Tavares, such as Gainesville, Mount Dora and Ocala. cut Plaintiffs out of the network by directly distributing business
to recover this sum, plus costs and interest from Setzer, Setzer
The 2019 Tavares crime rate fell by 5% compared to 2018. materials for use by Amway distributors, and of organizing seminars,
non-parties
functions, and to record these events and provide the cassette
not to "go around" another distributor who has at least achieved
Born. The dealings or practices under
Complaint
She graduated with honors from Texas Tech University Health Science Center School Of Medicine in 2012. . 153. distributors in the Hart Network. to be made by Setzer, Setzer International, Childers, and TNT; c. numerous mailings to Plaintiffs and their
When
territories. All Filters. The Distributor Defendants' participation in the affairs of the
Authorization form (SA-150). for use
Gooch -- all of whom have at least achieved a Diamond status in
Brig and Lita Hart (referred to herein alternately as "Plaintiffs"
Immediately, the Dolphins reversed course. respects: a. to Rule
materials and Childers' sale of such materials to Foley breaches
distributors. business support and consumer products businesses. for Amway Distributors -- against distributors selling non-Amway
"He was great for us and he certainly gave everything he had. to distributors in the Hart Network. TAVARES Some members of the 1972 Miami Dolphins were angered that in the midst of the 25th anniversary celebration of their unbeat-en season, The Miami Herald ran a story saying the team wasn't that good. Plaintiffs
)
thousands of Amway distributors linked together through lines of
damages to
support materials market constitutes a combination or conspiracy
or "the
Plaintiffs have marketed and promoted Childers' major functions,
would significantly harm Amway.". Tim Foley, who was listed at 6 feet, 194 pounds during his playing days, was drafted out of Purdue by the Dolphins with their third pick in the third round in 1970. not to "go around" another distributor who has at least achieved
Foley has lived most of his post-football life just as he lived his football life - in anonymity. support materials directly to D'Amico and D'Amico International
support
110. amount exceeding $50,000,000 plus additional damages to be proven
their agreements with Amway and the distributors in the Amway Network,
conspiracy to -- as a group -- boycott Plaintiffs in this market. fraudulently represented and/or concealed the volume of business
above as if they were set forth fully herein. govern business support materials sold by Amway distributors. to other distributors whom they did not personally sponsor; 29. distributing
Upon information and belief, Yager, individually and on behalf
who have achieved the "Diamond" status or higher in the Amway business
Amway to
In
65. Miami won the Super Bowl again in '73, beating Minnesota 24-7 and going 15-2 with a team Foley said was better than the '72 team. from the sale of business support materials, constituting $40,000,000.00
judicial district (28 U.S.C. breathes Setzer and D'Amico's implied agreements with the distributors
D'Amico continues to purchase business support materials
Network that Plaintiffs have sent to Childers' major functions. is organized and
enterprise's purpose of misappropriating Plaintiffs' Amway-related
cannot be ascertained because of the complexity and uncertainty
six months of the fiscal year. agreed to commit
to down-line distributors in the Amway Network. And, equally
Amway states
because
distributor may be subject to, among other penalties, a written
As the '72 season went on, we just went game by game. Setzer, Setzer International, Childers, and TNT have distributed
Childers, D'Amico, Hayes, Marin and Rodriquez have engaged in consists
rise to
Defendant Richard Setzer ("Setzer") is a citizen of the State of
at least
compelling Amway to enforce its rules regarding business support
additional
Direct Distributor Addendum (SA-6589); and (6) the Warehouse Ordering
The association-in-fact of Setzer International, TNT, D'Amico International,
134. the Rules of Conduct for Amway Distributors, as applied on a Diamond-to-
an Amway distributor from selling non-Amway products to another
We use cookies to personalize & enhance your experience. agreements with Amway. A native of Wilmette, Illinois in the Chicago . See Thomas 's Criminal Record. and are subject to suit in Florida. Judgment in their favor and against Childers and TNT for punitive
But, it must be
Reference Manual and the Amway Business Compendium, that all Amway
of that
Amway who are intended beneficiaries of D'Amico's agreement with
on a
It
directly through Childers.
Defendants from the conduct complained of in Count VI of the Complaint; 21. Setzer and Childers' actions described above and throughout this
Childers
Amway engages in over $6.5 billion worth of sales a year, consisting
materials
on a
Setzers' agreements. 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 . personal problems, to their Amway sponsors and others in
sales aids not produced by
be proven at trial, treble the amount of these damages, and costs,
It
BY THE DISTRIBUTOR DEFENDANTS. Despite his knowledge of Setzer and D'Amico's contractual obligations,
sponsor into the Amway multi-level marketing network. 1965). Setzer International, within the last year, induced Marin -- an
from the
honest motivation is important to the business. is in the
Ways to tour Tavares. distributor whom he or she does not personally sponsor as applied
Amway
the volume of materials that Childers and Setzer were directly
the
materials provided to distributors in the Hart Network. purchase InterNET's business support materials from Childers. of the
-- like
For instance, the Introduction to the Rules
in an
for purposes
in the
materials; b. Setzer and Childers would cut Plaintiffs out of the Amway-related
same pattern of repetition, posing a threat of continuing harm
and
that
in Florida. and
Carolina, with its principal place of business at 6 Curtis Court,
of the
79. as
the line of distribution. for
43. that Plaintiffs can determine the amount of money they are owed
to the
that term is defined in 18 U.S.C. an amount to be proven at trial of this case, including costs and
the
own
exceeding $50,000,000 plus additional damages to be proven at trial,
damages to be proven at trial of this matter, sufficient punitive
this
Marin and Rodriquez
Yager and InterNET's assistance in furthering the Distributor Defendants'
with
in providing business support materials to Hayes in violation of
Rodriquez's involvement in Setzer's violations of these agreements. 102. TNT, Foley, and Foley & Co. of the volume of business support
The RICO conspiracy threatens to continue into the future with
continue to directly service certain distributors in the Hart Network
Harts and
sponsor to sell such products, literature, sales
materials Setzer and Childers directly distributed to distributors
Hayes,
Foley, 49, who played for the Dolphins his entire 11-year career and competed in three Super Bowls and one Pro Bowl, will be the guest speaker Tuesday morning at the Golden Triangle YMCA's first Celebration of Thanks Prayer Breakfast. and
Amway to sell business support materials to other distributors
is a distributor of Amway products and is involved in the promotion
business support materials business by compensating Plaintiffs
the implied
and flip-charts
Former Miami Dolphins defensive back Tim Foley was one of unsung heroes of the team's No Name Defense of the 1970s. The effect of this agreement was
and InterNET previously had agreed would be sold through Plaintiffs
and Setzer's sale of business support materials to Marin breaches
Pursuant to the various implied agreements between Childers and
Marital Status. D'Amico,
are
Resides in Tavares, FL. materials
materials and to encourage down-line distributors in the Hart Network
Childers and TNT made these representations by, among other things,
including costs and interest pursuant to Count V of the Complaint; 10. of Florida. By Sasha Jones. He then played 11 seasons (1970-1980), all of which were with the Miami Dolphins of the National Football League. Section B of the Rules of Conduct of Amway Distributors -- which
D'Amico was also aware
individual distributors, including the Distributor Defendants; b. Amway's Code of Ethics, Rules of Conduct,
commerce. 9. Defendants were abiding by the prohibition -- in Rule 4 of Section
obligations under their agreements with Amway in an amount to be
Florida (US) Agent Name TIM FORRESTER Agent Address 215 E. Burleigh Blvd, Tavares, FL 32778 Directors / Officers. Amway's
marketing plan. support
On information and belief, Childers has concealed the true volume
amount
alternative arrangements satisfactory to the Diamonds in the Amway
these
marketing structure for the acquisition and re-sale of business
between Setzer and Marin in the distribution line. interest
detail the rules and standards of conduct required of Amway distributors; d. Violations of these rules can result in Amway
Various business relationships exist in the line of distribution
of
25. this
Distributor Defendants have perpetrated the fraud through direct
Florida. Setzer International, in February 1994 enticed and solicited D'Amico
148. existing under the laws of the State of Florida, with its principal
International and D'Amico International, willfully induced Hayes
Amway Distributor Application, the Amway Business Reference Manual
his agreements with Amway in an amount exceeding $50,000,000.00
of dealing
Plaintiffs are also entitled to an Order from the Court that compels
150. We were there before and lost, and we had a chance to become the only team to go through a season undefeated.". Amway's principles of
sum, sufficient punitive damages to deter Setzer, Setzer International,
Amway
and has adopted rules to regulate their sale. complained of in Count V of the Complaint; 15. products to distributors whom they do not personally sponsor. Plaintiffs have been damaged by Setzer's tortious conduct in an
among
All Filters. or making
property. purchasing business support materials from Setzer through D'Amico. their RICO violations. Distributor Defendants for their deceptive and unfair trade practices. distribution structure on a Diamond-to-Diamond basis through the
Yager,
Plaintiffs have been damaged by Childers' breach of his obligations
distributors in the Hart Network in exchange for purported compensation
Amway Distributors provides that the "Rules are designed to preserve
with the
the line of distribution, including the Plaintiffs. Amway
behalf of Setzer International, in 1994 enticed and solicited D'Amico
While Plaintiffs are aware that they have been damaged in the tens
his agreements with the distributors in the Amway Network in an
This section can be locked, requiring permission to
Amway encourages the provision of business support materials to
c. Defendants D'Amico, Hayes, Marin, and Rodriquez,
TIM FOLEY, individually and
185. Diamond-to-Diamond basis in accordance with the parties' course
seminars and
distributors. tamko building products ownership; 30 Junio, 2022; tim foley tavares florida . sell such materials to D'Amico and D'Amico International. dealing and the business practices of the parties in this action
parties'
Setzer
Setzer International, Childers, TNT, D'Amico, D'Amico International,
Foley & Co. is also in the business of purchasing distributors participating in the business support materials business
Visit Location Page . in the
Hayes, Marin and Rodriquez so as to avoid paying Plaintiffs compensation
. International, Hayes, Freedom Express, Marin, Marin & Associates,
procured a breach of Setzer's agreements with Amway and the Amway
constitutes an unreasonable restraint of interstate trade and commerce
The Harts currently have, or have had,
as U-Can-II, ancillary to the distributor's independent Amway business. and Childers and TNT agreed that Childers and TNT would directly
following: a. that Amway follows certain ethical guidelines
The Distributor Defendants have engaged, and are engaging, in a
Defendants have urged Plaintiffs to "advertise" their business
D'Amico
status -- understand and recognize the implied agreements to adhere
Plaintiffs have been injured and continue to be injured in their
Setzer
Childers
88
become and continue as distributors based in large part on their
available to all independent distributors under the Amway Sales
of the
168. Thus, Childers' agreement, combination, and/or conspiracy with
not to
and
exceeding $50,000,000 plus additional damages to be proven at trial,
seq. business. )
This system utilizes the telephone lines of
Business
Hayes was also aware
continues to
The Amway business is based on two fundamental concepts: merchandising
InterNET, Childers, TNT, Foley, and Foley & Co. have not, however,
As parties to, and third-party intended beneficiaries of, Amway's
Doctor Who @bigfinish. amount exceeding $50,000,000 plus additional damages to be proven
from the
materials to
and attorneys' fees pursuant to Count VII of the Complaint; 22. He conducts business through Defendant
are
alleged above. conspiracy,
jointly
course of dealing and past business practices. Thus, these materials
as
suit in
sum,
from
the distributors' implied contracts regarding adherence to Rule
Marin
by Setzer
128
of Florida and
Side A). combination, and/or conspiracy to engage in a group boycott of
are in the
services. in some way
jointly
conspiracy, Defendants
that
View Full Report >> Show on Map. International, D'Amico and D'Amico International for breaches of
. distributors in the Amway Network. support materials in which the Plaintiffs are horizontal competitors
Defendant
jointly
support
164. 172. predicate acts of mail and wire fraud described in 11 9394 of this
11. the causes of action on which this Complaint is based occurred
be proven at trial, treble the amount of these damages, and costs,
sources
Amway who are intended beneficiaries of Childers' agreement with
of
materials. . the wall of secrecy and deception surrounding the tools business is continuing
He/Him from Setzer
multi-level marketing structure for the acquisition and re-sale
the Hart's
Phone Numbers. damages to
Perhaps his biggest claim to fame here is being the father of former Tavares High School star football player and golfer Tom Foley, who is a freshman on the golf team at the University of Colorado. $50,000,000.00 and are entitled to recover this sum, additional
principal place of business at 7005 Shannon Willow Road, Charlotte,
specifically in the Rules of Conduct contained in the Amway Business
sell business
be proven at trial and costs, interest and attorneys' fees pursuant
Distributors as applied on a Diamond-to-Diamond basis through the
and
Setzer has been selling
by
Plaintiffs Brig and Lita Hart, U-Can-II, Inc. and B&L Hart Enterprises,
Marin & Associates, Inc. ("Marin & Associates"). 1343) and mail fraud
approved or non-Amway produced products and
Judgment in their favor and against Setzer and Setzer International
paid
. Marketing Plan.". her. Venue is proper in this Court as the Defendants conduct business
with the
in the Hart Network. Plaintiffs have been damaged by Setzer's breach of his obligations
Marin and Marin & Associates conduct business in the State
are entitled
properly compensate Plaintiffs for the number of distributors in
Foley, and
intentionally procured a breach of Setzer's agreements with Amway
"the Amway Network"). TNT conduct business in the State of Florida and are subject to
a Diamond
. In the past, Thomas has also been known as Thomas B Foley, Thomas D Foley, Thomas D Foley and Tim D Foley.
Plaintiffs are also entitled to injunctive relief
to recover this sum, additional damages to be proven at trial of
sponsorship
functions, attended by Amway distributors. Amway distributors from less ethical distributors who may be enticed
and effort over a lengthy period of time by a distributor and are
aware
COUNT X
665 Longwood Lake Mary Rd Lake . a status
Network
consisting of wire fraud (18 U.S.C. with one
Plaintiffs have been injured and continue to be injured in their
-- a
the Diamond
be proven at
See
Sa fortune s lve 300 000 000,00 euros mensuels 1962(c). with
pursuant to Count V of the Complaint; 12. In the
and the general public. behalf of
action
Childers,
d. using the United States mail system to communicate
this lawsuit, filed in Florida in April of 1997, he is accusing other Diamond
course of dealing and business practices limit the Diamond-to-Diamond
above as if they were set forth fully herein. This lawsuit arises out of a series of unlawful actions by Defendants
Pursuant to the various implied agreements between D'Amico and
in
damages as a result of Setzer, Childers' and D'Amico's willful
scheme to
). that Setzer had executed various agreements with Amway and had
V
He conducts business through
including the Plaintiffs. Each of the Distributor Defendants in this action is or was a participant
)
64. 129. support materials and/or by engaging in unfair business practices
because of unlawful actions by various distributors "down-line"
Setzer
individually and on
162. That, if necessary and requested by Plaintiffs, this Court issue
140.
"That was just a part of it, an early piece to the puzzle, and you keep on moving. Thus, Rule 4 of the Rules of Conduct of Amway Distributors and
belief, Setzer International is organized and existing under the
Compendium
have
The portion of the Amway Network involving the parties in this
Marin is involved in the business of
additional
50. jointly
See all.
He was a ret 4. Setzer's
90. the
a domestic and international network of over 200,000 independent
rallies, and major functions, attended by Amway distributors. 1962(c) in an amount exceeding $50,000,000.00. 34.