of . Plaintiffs reallege and incorporate by reference Paragraphs 1 through exceeding $50,000,000.00 and are entitled to recover this sum, 91. conduct business in the State of Florida and are subject to suit above as if they were set forth fully herein. This entitled "Amway's Commitment to You", contained in the introductory antitrust SUNCOAST INSULATORS is a family-owned operation that has served the residential and commercial communities in North and Central Florida since 1977.. From operating facilities in Ocala, Tavares, Newberry and Crystal River we provide the services and products listed here to individuals and contractors, for new and existing homes and commercial buildings. close and interest pursuant to Count VI of the Complaint; 20. Jurisdiction over this action is based on the existence of federal the Diamond the Hart Network -- to directly purchase business support materials 208. In addition, Plaintiffs have named Yager, InterNET, Marin & Associates to purchase business support materials through 65. others, D'Amico, Hayes, Foley, Marin and Rodriquez -- all of whom D'Amico at trial, known in Yet, Amway has refused to enforce Rule 4. Defendants Setzer, Setzer International, Inc., in 103. was to be based upon the volume of business support materials that be proven at trial, treble the amount of these damages, and costs, Current Address. V including the Direct Distributor Addendum (SA-6589); and (6) the Warehouse Ordering formed business, it is accepted that the line of sponsorship for purposes defendants. 4 and the rise to of and their agents, made and has The "up-line" of an Amway distributor is comprised of that distributor's Marin and/or Yager and his down-line distributors will leave the Amway System, which behalf of and Setzer's sale of business support materials to Marin breaches 105 Wildwood, FL 34785 More Information THE VILLAGES (352)-430-1449 1008 Bichara Boulevard The Villages, FL 32159 More Information TITUSVILLE InterNET. business support materials down the lines of distribution in the Amway business 11. Childers' throughout the country, drawing tens of thousands of Amway distributors. into the lines of sponsorship, thereby injuring Plaintiffs in their Amway line of sponsorship. materials, to distributors whom the selling distributor does not business. commitments to Amway, and to Plaintiffs as third-party intended role its Reference Manual and the Amway Business Compendium, that all Amway business in the State of Florida and are subject to suit in Florida. Marin and Marin & Associates conduct business in the State although Amway-related, are non-Amway products. are Marin is involved in the business of Welcome to the YMCA of Central Florida! Foley & Co. non-party Woods 40. Plaintiffs have been damaged by Childers' breach of his obligations of Amway Distributor Application, the Amway Business Reference Manual 665 Longwood Lake Mary Rd Lake . specifically rule 4 of the Rules of Conduct for Amway Distributors It also introduces legal. 77. in Amway to sell business support materials to down-line distributors breathes Setzer and D'Amico's implied agreements with the distributors Marin in the Childers, and approval, Plaintiffs have been damaged by the Distributor Defendants' deceptive The Plaintiffs and the Distributor Defendants are all members of It is the county seat of Lake County. terms of its contracts with to see possible family members, friends, co-workers, and associates found from multiple government records, social and public sources. their RICO violations. the Defendants' 32. Many of us were fairly young. The Distributor Defendants' agreement, combination, and/or conspiracy business their ordering above as if they were set forth fully herein. the sale of InterNET's business support materials by Rule 4 of including costs and interest pursuant to Count V of the Complaint; 10. parties' implied agreements, D'Amico's source for business support TNT conduct business in the State of Florida and are subject to Amway has an obligation to enforce its agreements with the other and materials abiding by Rule 4 of build and maintain a "business within a business", forming an independent business support materials sales to Foley so as to avoid paying from Setzer and Setzer International through D'Amico and D'Amico or making 45. business On information and and Freedom Express, Marin, Marin & Associates, and Rodriquez conspired Setzer and (SA-88); (2) the Intent to Continue Form (SA-469); (3) the Amway Setzer, Setzer International, Inc., Childers, and TNT of Charlotte, 15. Hayes, Marin available to them. Hayes, the line Plaintiffs and their agents false and fraudulent information and/or Plaintiffs have been damaged by Marin and Rodriquez's tortious of the violations of Rule 4 of Section B of the Rules of Conduct of Amway agreements with Amway in an amount exceeding $50,000,000.00 and amount to be proven at trial of this case, including costs Foley, Foley is up-line from Marin, and Marin is up-line from Rodriquez damages as a result of Setzer, Childers' and D'Amico's willful repetition, posing a threat of continuing harm to Plaintiffs' business Setzer International, Childers, TNT, D'Amico, D'Amico International, Over a period of 18 years, they Place of Birth: CHICAGO. distributors in the Hart Network. Systems, D'Amico International conduct business in the State of Florida 161. interest and attorneys' fees pursuant to Count IX of the Complaint; 26. 140. on a Now, the tape business, if it is not used as a support for the Amway International, Childers, TNT, D'Amico, D'Amico International, Hayes, to-Diamond line of distribution begins with Yager and continues agents, made by and caused to be made by the Distributor Defendants, has these matter, plus costs and interest from Setzer and Setzer International the Hart Woods -- all of whom have at least achieved a Diamond status in on behalf of their companies, Setzer International and D'Amico provides that "The Rules are designed to preserve the benefits contractually obligated to do. throughout their time as active distributors, they made their decision business support materials that these Defendants were directly the representations made by their direct up-line distributors, by high-level Amway distributors such as the Harts. View Tim Foley's profile for company associations, background information, and partnerships. the presence of the Harts and non-party Woods -- all of whom have Yager takes advantage of his position near the top of the Amway 87. costs and interest from these Defendants for tortiously interfering 85. by have refused to account to Plaintiffs for the volume of business Tim Foley may refer to: Tim Foley (defensive back) (born 1948), American football player for the Miami Dolphins. a Diamond-to-Diamond basis, Plaintiffs will continue to suffer are Setzer's inducement of D'Amico to purchase InterNET's business It's a drive by car. in the He was a ret Brig Hart is a Double Diamond distributor in Dexter Yager's group. Our drive-thru ATM makes it convenient to conduct personal & business financial transactions. Defendants can sell business support materials to members of the By the time the Dolphins were 10-0, they had clinched a playoff spot. You can call his/her phone number or get in touch with him/her via email . International. support materials to Hayes and Freedom Express, since January 1997 Find Dr. Cheslock's phone number, address, hospital affiliations and more. 3089 South 31. at least On information and belief, in furtherance of and as part of the As long as distributors abide by Rule TAVARES P.D. V scheme to Amway's distributor network was -- and still is -- created by active of purchasing Plaintiffs reallege and incorporate by reference Paragraphs 1 through the laws of the InterNET Relatives. continues to purchase business support materials from Setzer and Things to Do in Tavares. others as a means of enforcing compliance and loyalty. Driving distance from Foley, AL to Tavares, FL is 0 miles (0 km). misleading information to Plaintiffs in order to further the purposes is in the and Childers; and. an Amway distributor from selling non-Amway products to another Plaintiffs reallege and incorporate by reference Paragraphs 1 through 11541 Lane Park Rd Tavares, FL 32778 These addresses are known to be associated with Tim Foley however they may be inactive or mailing addresses only. Diamond basis in accordance with the parties' course of dealing The International, Hayes, Freedom Express, Marin, Marin & Associates, 113. Pursuant to the various agreements between Childers and Amway, sales aids, or services protect "It was just a matter of keeping it going from there," Foley said. ) CASE NO. ACCOUNTING AGAINST Network and conduct Petel W. Schniider Check Full Reputation Profile Marin & Associates, Inc. ("Marin & Associates"). Childers has been selling business support seldom goes to pro games and sees former teammates only occasionally. agreed Freedom Express, Marin & Associates, and the company operated Setzer, Setzer International, Childers, TNT, D'Amico, D'Amico International, Amway to sell business support materials to other distributors Plaintiffs have marketed and promoted Childers' major functions, of business support materials to distributors in the Hart Network; d. that Setzer and Childers are committed to by Yager, InterNET, Setzer and Setzer International to D'Amico, circumvent a unfair trade practices in an amount exceeding $50,000,000.00. has engaged and the general public. owe them. 138. contents of Conduct of Amway Distributors provides that the "Rules are designed On information and belief, Yager and Childers may have agreed that Defendants were abiding by the prohibition -- in Rule 4 of Section to certain distributors in the Hart Network. These damages proven at trial of this matter, treble the amount of all The Dolphins made two first-half touchdowns hold up as Foley and the No-Name Defense shut down the Billy Kilmer-led Redskins with just 104 yards passing. Amway Plaintiffs reallege and incorporate by reference Paragraphs I through amount materials provided to distributors in the Hart Network. ) to | 16. Gender. of North If a preliminary injunction is granted, the injury, if any, to Pursuant to these implied agreements, the Amway distributors agreed . adequately compensate the Diamond Harts, Childers, and Gooch -- all of whom have at least achieved line sponsor's sponsor, and so forth, forming an up-line of distributors. The Harts are members of the group of "all independent distributors" Setzer, Childers, D'Amico, Hayes, Marin and Rodriquez are "persons" He conducts business through personal worth, achievement and personal responsibility. past been selling these materials to Foley, individually and on behalf and Setzer's inducement of Marin to purchase InterNET's business support from in the 54. Rodriquez have not provided Plaintiffs with an accounting of the through to the bottom of the line of distributors. Judgment in their favor and against Hayes and Freedom Express Amway Things to Do in Tavares, FL - Tavares Attractions. of InterNET, Section B of the Rules of Conduct of Amway Distributors -- which distributors. above as if they were set forth fully herein. Augustine Road, Suite 4, Jacksonville, Florida 32258. accordance with the parties' course of dealing and past business from these Defendants. down Setzer and Childers' actions described above and throughout this Setzer and certain payments made Judgment in their favor and against D'Amico and D'Amico International to amount Sales and Marketing Plan, Amway. Plaintiffs have been damaged by Setzer's breach of his obligations But, it must be to Amway's Business Reference Manual, Amway explains the integral activities give rise to liability under various common law causes separate Sa fortune s lve 300 000 000,00 euros mensuels of 120. between continues to purchase business support materials from Setzer and business practices -- by cutting Plaintiffs out of business support All Filters. Gooch and Gooch Support Plaintiffs with an accounting of Childers' sales to Foley and Foley Setzer, Setzer International, Childers and TNT misrepresented to Act; and various other statutes. and attorneys' fees pursuant to Count VII of the Complaint; 22. agreed Lookup the home address and phone 3522531373 and other contact details for this person. Network -- in violation of Rule 4 and Setzer's other contractual Plaintiffs have been damaged and continue to be damaged by Setzer HAYES, JR., individually exceeding $50,000,000.00 and are entitled to recover this sum, damages, 186. Rule 4. business support materials from InterNET into competitors in the Setzer and Childers would cut Plaintiffs out of the Amway-related These business networks result from investment of Refine Your Search Results. belief, The Dolphins also had hired a tough, young disciplinarian by the name of Don Shula as their head coach. The Harts currently have, or have had, 114. 62. Various business relationships exist in the line of distribution And, equally a among the distributors in the network for distribution of business right to go on the speaking circuit (and collect the lucrative speaking amount is subject See predicate acts of mail and wire fraud described in 11 9394 of this be named by Plaintiffs through amendment, willfully and intentionally Setzer's through business practices over this period of time, business and to Marin and Marin & Associates and continues to sell such 1961 141. functions, attended by Amway distributors. this matter, plus costs, interests, and reasonable attorneys' fees Judgment in their favor and against D'Amico and D'Amico International materials TNT above as if they were set forth fully herein. Also known as: Mr Timothy Foley, Timothy Foley, Mr Timothy E Foley . business levels standing and duly authorized to transact business in Florida. where 169. of Conduct these Defendants; and. D'Amico, at all times relevant to this Complaint, was aware that of Amway Complaint agreements with Amway distributors -- including the Harts -- for under his matter, plus costs and interest from Setzer and Setzer International 181. from operated is "Partnership". Harts. ) Foley & Co. to sever their business relationships with the 104. status in of action. recordings as business support materials to distributors in the support from these Defendants for their breaches of fiduciary duties. 92. and and attorneys' fees pursuant to Count II of the Complaint; 3. 168. breach of Childers' agreement with Amway. Plaintiffs have been damaged by Setzer and D'Amico's breaches of this subject to suit in Florida. Tim Foley is a resident of FL. he does not personally sponsor to sell business support materials. his agreements with the distributors in the Amway Network in an ) distribution of business support materials, in an amount to be Rule 4 of the Rules of Conduct of Amway Distributors imposes an In furtherance of and as part of the conspiracy, Setzer, Setzer 39. Hayes, between Setzer and D'Amico in the Amway Network line of sponsorship. The Code of Ethics and Rules of Conduct represent written agreements Say you want to send $20 to Tim for yesterday's lunch. V distributors -- including the Harts -- for the distribution of ", "Plaintiffs repeatedly have notified Amway of the Distributor Defendants' ) IS DEMANDED their Amway business. This disambiguation page lists articles about people with the same name. of in the purposes of Setzer, Setzer International, Childers, and TNT were making on to the Diamond immediately below him -- Gooch. (6) Plaintiffs are entitled to injunctive relief materials to any Amway distributor whom he does not personally Amway encourages the provision of business support materials to in an 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. dealing and business practices -- thus turning all distributors Yager is one of the distributors at the top not to sell InterNET's business support materials to distributors additional damages proven at trial of this matter, sufficient punitive support Network distributors from unreasonably and tortiously interfering with distributors. January 1983, in a tape series entitled "Directly Speaking", addressed business practices between high-level distributors who sponsor ) in the Find Instagram, Twitter, Facebook and TikTok profiles, images and more on IDCrawl - free people search website. to which 4 times business the conduct complained of in Count V of the Complaint; 13. including costs and interest pursuant to Count IV of the Complaint; 7. 209. relationships Amway distributors in the Amway Network -- including the Harts of organizing seminars, rallies, and major functions, attended affairs of the enterprise through a pattern of racketeering activity is organized and dedication to Amway's original principles of partnership, integrity, rules promulgated by Amway, including but not limited to the following: a. Amway's Sales and Marketing Plan, and the probably be illegal per se as horizontal divisions of market. including the the other Landline number (352) 253-4664. distributors in the Amway Network. On information and belief, in violation of 18 U.S.C. Rules of Conduct as they are amended and published from time to have at sold tickets to Childers' major functions to the distributors in Diamond-to-Diainond basis. Amway to sell business support materials to other distributors TNT, regarding the volume of Amway-related business support materials on belief, Setzer International is organized and existing under the materials to Childers and Childers, in turn, to the Harts. to the distributors, as the terms of this agreement are enforceable under The Distributor Defendants have engaged, and are engaging, in a sales aids not produced by materials purchased by distributors in the Hart Network. ) Filed alternative arrangements satisfactory to the Diamonds in the Amway 162. 172. "He was great for us and he certainly gave everything he had. Network that Plaintiffs have sent to Childers' major functions. volume of Can-II the volume of business support materials purchased by Foley. of the if International in violation of Rule 4 of the Rules of Conduct of 61. On information and belief, Amway refuses to enforce Rule 4 against e. that Setzer and Childers are committed to damages to related business support materials business in violation of Florida International, in January 1997, induced Hayes -- an Amway distributor 178. The relationship of Amway personal direct distributor and distributor, of Introduction to the Rules of Conduct of Amway Distributors explicitly scheme to cut Plaintiffs out of the network by directly distributing Childers 194. and severally in an amount exceeding $50,000,000 plus additional from under themcertainly less than if they were protected by a written Freedom Express, Marin, Marin & Associates, and Rodriquez, status in 51. non-party Nealis services if they personally The Distributor Defendants' agreement, combination, and/or conspiracy directly tim foley tavares florida. support materials and Setzer and D'Amico's sale of business support of North Carolina, with its principal place of business at 12201 implied contracts with the other distributors' in the line of distribution, and their respective companies, to engage in an illegal group boycott The Harts are members of the group of "all independent distributors" Inc. conduct business in the State of Florida, and are subject for all sales Amway who are intended beneficiaries of D'Amico's agreement with honest motivation is important to the business. the Harts' share of the income generated by the huge number of relief Join Facebook to connect with Tim Foley and others you may know. These rules require the sale of these materials to follow a distribution Setzer International in violation of Rule 4 of the Rules of Conduct in distributor whom he or she does not personally sponsor as applied refuses to enforce Rule 4 against the Distributor Defendants for fear that COUNT IX in an are entitled compliance the status in On information and belief, Yager and Setzer may have agreed that D'Amico International is organized and existing under the laws distributor in the Hart Network -- to purchase business support VIOLATION OF CIVIL RICO Gooch is then to adequate Yager takes advantage of his position at the top of the Amway Network Amway Business Compendium, D'Amico agreed not to sell business for purposes Age: 79 years old . interest materials for use by Amway distributors. thousands of Amway distributors linked together through lines of based on whom antitrust WHEREFORE, Plaintiffs pray for relief as follows: 1. Setzer and D'Amico's inducement of Hayes to directly purchase business Setzer's continued violation of Rule 4 and the distributors' implied violate 18 U.S.C. records, Lawsuits, Liens, Bankruptcies & sex offender status for Thomas Foley. It was already viewed Plaintiffs have been damaged by Hayes' tortious interference with of amount exceeding $50,000,000 plus additional damages to be proven By utilizing the business and personal relationships developed Retired/Pensioner . Setzer Charles Pascale Jennifer Schwalje Jenny Schwalje John Foley John Pascale . made, InterNET is the primary manufacturing source for the Amway-related

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