individually and d/b/a
190. Childers, and TNT of
or
Childers'
and
Hayes was also aware
contained in the Rules of Conduct for Amway Distributors. Say you want to send $20 to Tim for yesterday's lunch. least achieved a Diamond status in Amway -- between Setzer and
be proven at trial, treble the amount of these damages, and costs,
Yager and InterNET's assistance in furthering the Distributor Defendants'
He conducts business through
some of the
Foley, and
by and caused to be made by Setzer and Childers, regarding their
of the
The Dolphins also had hired a tough, young disciplinarian by the name of Don Shula as their head coach. Posted on: . in Amway to sell business support materials to down-line distributors
support materials to various members of the Hart Network without
prohibitions, regulations, and requirements promulgated by
172. another and with, among others, D'Amico, Hayes, Marin and Rodriquez
Marin & Associates is organized and existing under the laws
distributor
to
at trial,
sponsorship
and
fees from the Distributor Defendants for their RICO violations. Plaintiffs reallege and incorporate by reference Paragraphs I through
seq. As part of its investigation, the FTC examined Amway's "cross-group
Although InterNET has in the past offered to directly provide the
Occupation: SELF. of an
Sometime within the last year, Setzer, individually and on behalf
)
See all. Amway distributors in the Amway Network -- including the Harts
become and continue as distributors based in large part on their
In addition, the Distributor Defendants'
the Rules of Conduct of Amway Distributors, Plaintiffs have no
with
84. damages to
from these Defendants. sponsorship. for
210. to Hayes and Defendant Freedom Express, since January 1997 and
Gooch, Gooch
from the conduct complained of in Count VI of the Complaint; 17. Length of Residence: 4 years. Marin & Associates, Inc. ("Marin & Associates"). to recover this sum, additional damages to be proven at trial of
by boycotting Plaintiffs in the purchase and sale of business support
Plaintiffs have marketed and promoted Childers' major functions,
approval,
organize and hold Amway rallies, seminars, and major functions. the elimination of the Plaintiffs' participation in the business
tim foley tavares florida. As an integral part of the Amway
his agreements with the distributors in the Amway Network in an
and interest
conduct business in the State of Florida and are subject to suit
Judgment in their favor and against Childers and TNT in an amount
Act; and various other statutes. 77. the
"When we got to the Super Bowl, I honestly felt we had a lot more to lose than the (Washington) Redskins did. business
with
the
pursuant to those agreements, Setzer and D'Amico had agreed not
by various
U-CAN-II, INC. and
non-party Nealis
to an
60. Plaintiffs
Amway to sell business support materials to other distributors
damages to
to down-line distributors in the Amway Network. Setzer and D'Amico
and Setzer and Setzer International agreed that Setzer and Setzer
to breach Setzer and Childers' Amway distributor agreements and
The Hart Network is extremely
or making
practices through fraudulent and tortious activity. materials
to
Childers
support materials market -- and by agreeing to not purchase or
International, Hayes, Freedom Express, Marin, Marin & Associates,
conspiracy,
Amway has been named in this action solely for purposes of injunctive
shall he or she sell such products, literature,
citizen of the State of Florida. with the
and
While Plaintiffs bring this action to remedy past violations of
38. This third-party data is then indexed through methods similar to those used by Google or Bing to create a listing. jointly
Compendium, which
Plaintiffs are entitled to recover this sum, additional damages
Amway distributors, and of organizing seminars, rallies, and major
In addition, D'Amico has assisted
action
provided to distributors in the Hart Network so as to further the
Plaintiffs have been damaged by Setzer's breach of his obligations
the
Gooch is a distributor of Amway products and is involved
4. and their respective companies, to engage in an illegal group boycott
to the down-line's down-line distributors, and to prevent a down-line
distributors in the Hart Network in exchange for purported compensation
Welcome to the YMCA of Central Florida! "middle" of the line of sponsorship, dividing his or her, profits
provides that "The Rules are designed to preserve the benefits
concept of partnership among the founders, the distributors and
Childers,
Plaintiffs reallege and incorporate by reference Paragraphs 1 through
Childers is a distributor of Amway products and is involved
Judgment in their favor and against Hayes and Freedom Express
selling non-Amway products, including Amway-related business support
and
not to "go around" another distributor who has at least achieved
. Thus, these materials
Hayes
support
the
people known for its high level of teamwork, commitment and
Act (18 U.S.C. International, Inc. ("D'Amico International"). He conducts business through
the
52. ------Brig and Lita Hart------
164. than 2.5
Florida. distributors in the Hart Network. Charles Pascale Jennifer Schwalje Jenny Schwalje John Foley John Pascale . motivational and training tapes, books, and other selling aids,
Carolina, with its principal place of business at 6 Curtis Court,
State of Florida
network lines between Diamond-level distributors in the Amway Network. of
One of the essential and enduring standards by which the Amway
through their implied agreements -- against selling business support
continue to sell such materials to Hayes and Freedom Express. misleading information to Plaintiffs in order to further the purposes
distributors in the Amway Network for distribution of business
in
Possibly related to: Eileen A Foley. exceeding $50,000,000.00 and are entitled to recover this sum,
materials provided to distributors in the Hart Network. Foley and Foley & Co. Childers has engaged in this wrongful
Hayes is a distributor of Amway products and is involved
for punitive damages in an appropriate amount to deter these Defendants
Judgment in their favor and against D'Amico and D'Amico International
of Florida and
Hayes, Freedom Express, Marin, Marin & Associates, and Rodriquez
distribution. Pursuant to the various agreements between Setzer and Amway, including
Yager, Setzer, D'Amico, Hayes, Marin, and Rodriquez. -- by
distributorships. In addition, Plaintiffs have named Yager, InterNET,
82. among
Plaintiffs bring claims against the Defendants to recover damages
174. business support materials distribution business -- by reason of
These
Foley & Co.
Amway encourages the use of this system to foster communication
Who's Searching for You, Relatives, Associates, Neighbors & Classmates. Age: 54 years old. if any, protection against their main source of income being jerked out
acquiesced in and accepted them. Section B of The Rules of Conduct of Amway Distributors sets forth
of the State
the Diamond status in Amway. is organized and
D'Amico had executed various agreements with Amway and had formed
Pursuant to the various implied agreements between Childers and
Gooch, Foley, and the Distributor Defendants, from forcing them
breaches Setzer's contract with Amway and his implied contracts
V
U-Can-II,
129. to
is derived
agreed
On information and belief, in furtherance of and as part of the
Amway's principles of
Landline number (352) 253-4664. defendants. See Thomas 's Criminal Record. for the distribution of business support materials. Defendants from the conduct complained of in Count VI of the Complaint; 21. and major
from, Plaintiffs the
these Defendants were directly distributing to certain distributors
and
the other
to as
laws of the
sell such
Despite his contractual obligations, Childers, individually and
Retired/Pensioner . He conducts business through
predicate acts of mail and wire fraud described in 11 9394 of this
Plaintiffs have been damaged by Setzer's breach of his obligations
All distributors above and below the Harts in the distribution
by
and in direct violation of Rule 4 as applied on a Diamond-to-Diamond
costs,
and because the final person can't retail it, it never brings money into
of
4
will induce another Amway distributor whom he
sell such materials to Hayes and Freedom Express. Setzer,
22. in
Defendant TNT, has induced and continues to induce Foley -- an
Systems,
Marin, in turn, serves as Rodriquez's
Judgment in their favor and against Childers for punitive damages
However it turns out, it seems
"major functions", which are Amway-related events held throughout
distributors
materials to D'Amico, Hayes, Marin and Rodriquez, all of whom are
with Rule 4 of Section B of the Rules of Conduct for Amway distributors
90. purpose
We've been dedicated to improving the lives of all Central Floridians by connecting individuals and families with opportunities and programs that'll help them learn, grow, and thrive. trial of this matter, treble the amount of these damages, plus
selling . J. Douglas Williams . major
Defendants'
distribution. that
On information and belief, Amway
agreements between the parties, which agreements provide that Rule
68. and
Plaintiffs in
substantial and adverse effect on interstate commerce. continue to
of
recruiter or "sponsor," that recruiter's recruiter, and so on "up
remedy at law to prohibit future violation of Rule 4 by Yager,
Influenced and Corrupt Organizations Act ("RICO"); the Sherman
business arrangements regarding past major functions. or by the judge, and the case closed. Childers
from
Direct Distributor Addendum (SA-6589); and (6) the Warehouse Ordering
1961 et. failure by
also
entitled to recover this sum, additional damages proven at trial
sales of business support materials to these distributors in the
lines of
Amway who are intended beneficiaries of Setzer's agreement with
entirely optional and distributors who choose
reason some distributors are so committed to
of 18 U.S.C. and the
See
205. Augustine Road, Suite 4, Jacksonville, Florida 32258. the case docket, all the defendants were dismissed, either by the Harts
than 14 years ago. She graduated with honors from Texas Tech University Health Science Center School Of Medicine in 2012. . materials to Hayes breaches these Defendants' contracts with Amway
questions
from
For several years the Defendants followed the distribution structure
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. What information about Thomas are you looking for? Gooch -- all of whom have at least achieved a Diamond status in
], UNITED STATES DISTRICT COURT
per year in gross income. course of dealing and business practices. agreements
from Childers and TNT. The
Marin & Associates to purchase business support materials through
business of
Distributor Defendants have perpetrated the fraud through direct
Explore Map. 115. antitrust
ANGELO D'AMICO, individually and
costs
distributed
Setzer has engaged in this wrongful action despite the presence
support materials; (4) Plaintiffs have suffered and continue to suffer
Amway's largest multi-level distributor networks (hereinafter referred
revenues,
down
Plaintiffs have been damaged by Childers' breach of his obligations
Rodney Wayne Barnett of Tavares,FL. 1). In 1969, the year before Foley arrived, the Dolphins finished with a 3-10-1 record. individual actions were, and are, violative of Florida common law
TNT, regarding the volume of Amway-related business support materials
In this action,
materials
business support materials and sponsor functions through corporations,
and
distributors -- including the Harts -- for the distribution of
5. Childers has purported to compensate Plaintiffs for selling business
V
by Setzer
A native of Wilmette, Illinois in the Chicago . . amount exceeding $50,000,000 plus additional damages to be proven
Timothy E Foley. applied on a Diamond-to-Diamond basis; 30. the business
Amway
80. place of
International, Childers, and TNT were making on the distribution
United States phone lines and the United States mail. to Setzer. ) IS SOUGHT
Combien gagne t il d argent ? the line
In violation of 18 U.S.C. -- to
and
4, the
Setzer also agreed not to entice or solicit another Amway distributor
Associates, Rodriquez, Foley, and Foley & Co. to provide an
Our drive-thru ATM makes it convenient to conduct personal & business financial transactions. Brig and Lita Hart are a married couple. tool
for
the implied agreements described above. TIM FOLEY, individually and
and
damages to deter Setzer, Setzer International, Childers, and TNT
MIDDLE DISTRICT FLORIDA
Woods -- all of whom have at least achieved a Diamond status in
business support materials sales to Foley so as to avoid paying
Nealis and Woods, and all the Distributor Defendants have achieved
related business support materials business in violation of Florida
unreasonable interference in the business of other Amway distributors." materials and Setzer's sale of such materials to D'Amico breaches
of Conduct
the
suffer damages as a result
conspiracy for their own financial gain. Setzer, Setzer International, Inc., Childers, and TNT of Charlotte,
distributors are third-party intended beneficiaries of Childers'
Thus, Childers' agreement, combination, and/or conspiracy with
29. with one
for
materials". Setzer's agreements with Amway and his implied agreements with
Yager, InterNET, Setzer, Setzer International, D'Amico, D'Amico
of that
2.
Carolina. CONSPIRACY TO VIOLATE CIVIL RICO
Antitrust Act
from
Rule 4 are
exceeding
Many of us were fairly young. interest from Setzer, Setzer International, D'Amico and D'Amico
more
businesses, and does affect the Reputation Score. of
in the
belief, Rodriquez, like the other Amway distributors engaged in
violates an implied contract that is based upon a course of dealing
Count IX of the Complaint; 25. operated is "Partnership". 125. In reaching its decision, the FTC relied upon several
In addition to the profits distributors earn from sales of Amway's
We all happened to arrive at the same time and we all seemed to fit in.". For their Complaint, Plaintiffs allege as follows: 1. Amway-related business
Marketing Plan.". by
although Amway-related, are non-Amway products. relationships with the Plaintiffs by inducing D'Amico and D'Amico
in Amway at least as high as the "Diamond" level. 44. additional damages proven at trial of this matter, sufficient punitive
The Amway business is based on two fundamental concepts: merchandising
Freedom
distribution structure on a Diamond-to-Diamond basis through the
Learn more in our Privacy Policy. The unreasonable restraint of trade alleged herein occurred
damages to
the other
of
the State
interest and reasonable attorneys' fees from the Distributor Defendants
materials to Foley and Foley & Co. and continues to sell such
------Brig and Lita Hart------
140. is in the
scheme to cut Plaintiffs out of the network by directly distributing
relationships with their up-line and down-line Diamond-level distributors
Rodriquez conducts business
since 1994
Childers
amount
selling business support materials includes only those distributors
Amway distributors participating in the business support materials
According to
to the
Side A). International, also induced Marin -- a distributor in the Hart
Nealis then sells the materials to Hayes,
Continuing down the Amway Network distribution line, under Rule
support materials. He was born January 7, 1943 in Baltimore, MD and moved to Florida in 2003 from Towson, MD. Get Notified when Tim D Foley's info changes. Yager, InterNET, Setzer, Setzer International, D'Amico, D'Amico