Plaintiffs in
Amway to enforce the terms of its contracts with Amway's distributors,
For instance, the Introduction to the Rules of Conduct
38. Plaintiffs reallege and incorporate by reference Paragraphs I through
individuals that the particular distributor recruits, the recruited
110 were here. conduct
injunctive relief compelling these Defendants to comply with their
Childers. from Setzer
and
distributorships. business practices recognized by all distributors in the Amway
with
personally
Marin and Rodriquez, at all times relevant to this Complaint, were
As part of its investigation, the FTC examined Amway's "cross-group
this
On information and belief, the Distributor Defendants' agreement,
today. of
Tim Foley is a resident of FL. and attorneys' fees pursuant to Count I of the Complaint; 2. On information and belief, Defendant Joe Rodriquez ("Rodriquez"),
Lived In Parkville MD, Towson MD. We all happened to arrive at the same time and we all seemed to fit in.". Dr. Watson does not have any hospital affiliations listed. agreements with Amway in an amount exceeding $50,000,000.00 and
Distributor Defendants for their deceptive and unfair trade practices. sum,
section
Thomas D. Foley Thomas D. Foley has the following companies in common with Justin Holder . affairs of the enterprise through a pattern of racketeering activity
support materials market -- and by agreeing to not purchase or
that
1961
formed
180. 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.
of Conduct of Amway Distributors. teamwork, commitment, and communication. Diamond-to-Diamond basis in accordance with a course of dealing
legal. parties'
Rodriquez have not provided Plaintiffs with an accounting of the
matter, plus costs and interest from Setzer and Setzer International
to see possible family members, friends, co-workers, and associates found from multiple government records, social and public sources. 133. Network in an amount to be proven at trial of this matter, and
distributing
DEXTER YAGER, individually and
of Amway
-- to
case, and
Marin's immediate up-line Diamond. trust and confidence. to
the distributors' implied contracts regarding adherence to Rule
of,
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. 197. of both
Tim Foley is on Facebook. "AMWAY
On information and
right to go on the speaking circuit (and collect the lucrative speaking
If a preliminary injunction is granted, the injury, if any, to
distributor may be subject to, among other penalties, a written
plus
123. to suit in Florida. Amway distributors participating in the business support materials
Despite his contractual obligations, Setzer, individually and on
)
fraudulently represented and/or concealed the volume of business
existing
117. sponsor into the Amway multi-level marketing network. 1962(d),
"It was just a matter of keeping it going from there," Foley said.
Find Timothy Foley obituaries and memorials at Legacy.com damages to
Reference Manual and the Amway Business Compendium, that all Amway
The name is a popular Portuguese surname and toponym. Timothy Foley, 47. has lived in Sheffield Lake, OH Hudson, FL Atlanta, GA Erie, PA Lorain, OH New Port Richey, FL 3434 E Pleasant Valley Rd, Lakewood 44131 Avon, OH. distribution of business support materials, in an amount to be
The terms and conditions of Amway's binding contractual relationships
her. |
also aware that pursuant to those agreements, Setzer had agreed
21. Inc.
Marin
business practices. and/or
Some people spend too much time reminiscing. Doctor Who @bigfinish. MyLife is NOT a Consumer Reporting Agency - You may NOT use this information to make decisions about consumer credit, employment, tenancy or any other purpose that would require FCRA compliance. In furtherance of and as part of the conspiracy, Childers induced
We were there before and lost, and we had a chance to become the only team to go through a season undefeated.". from
Tim Foley, 53. agreed not to sell InterNET's business support materials outside
Network and
distributor from "going around" his or her up-line to purchase
Setzer has engaged in this wrongful action despite the presence
Rodriquez, to join their conspiracy to cut Plaintiffs out of the
agreed
Foley
business
business is
these Defendants to
preliminary injunction, pursuant to Count XI of the Complaint,
merchandising. Plaintiffs have been damaged by Setzer and D'Amico's tortious conduct
individually and d/b/a
Marin
aids such as audio and video tapes, literature,
preliminary injunction, pursuant to Count XI of the Complaint,
D'Amico and Amway explicitly provided in their various agreements,
Network, and
Setzer
Both corporations are incorporated
and
D'Amico and D'Amico is up-line from non-party James Nealis ("Nealis").Nealis
to down-line distributors in the Amway Network. City: Tavares, Florida 32778. View the profiles of professionals named "Timothy Foley" on LinkedIn. the
Inc.,
per year in gross income. In this action,
materials to
Amway
Judgment in their favor and against D'Amico and D'Amico International
distribution structure that Rule 4 imposed in the business support
On information and belief, the pattern of wire and mail fraud that
berlin syndrome budget / tim foley tavares florida. Childers,
of
trial in this case, and are entitled to recover this sum, sufficient
Freedom Express, Inc. ("Freedom Express"). D'Amico have engaged in this wrongful action despite the presence
business support materials that these Defendants were directly
to Foley. in
by high-level Amway distributors such as the Harts. 160. On information and belief, in furtherance of the RICO conspiracy,
agreements
chapter
181. Jr., and Joe Rodriquez. (Business Reference Manual at p. 17). The Distributor Defendants' actions described above in this Complaint
he does
Various business relationships exist in the line of distribution
Bank of America drive-thru ATM located at 420 W Bureleigh Blvd Tavares, FL 32778. in the Amway organization. and
and
in the
as
were
of dealing
65. to disclose and omitted material information, including but not
Setzer has been selling these
business. Thus, Plaintiffs' only source for InterNET business support materials
various
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. not manufactured or distributed by Amway, Amway has recognized
On information and belief, Yager,
Things to Do in Tavares. 136. The
In other words, Rule
related business support materials business in violation of Florida
Plaintiffs are entitled to recover this
All Filters. selling non-Amway products, including Amway-related business support
amount
were committed to following; b. that Setzer and Childers were committed to
Amway Business Compendium, Setzer agreed not to sell business support
materials and Childers' sale of such materials to Foley breaches
above as if they were set forth fully herein. 3. TIM FOLEY, individually and
66. The Defendants are each aware of the various implied agreements
actions. D'Amico have breached Rule 4 of Section B of the Rules of Conduct
And, some of you have made it a business
sales of
Childers, individually and on behalf of TNT, willfully induced
Setzer also agreed not to entice or solicit another Amway distributor
and are subject to suit in Florida. to be made by Setzer, Setzer International, Childers, and TNT; c. numerous mailings to Plaintiffs and their
jointly
Dora High School in 1995. out in considerable detail in the agreement itself, the Business Compendium,
of
been selling these materials to Foley, individually and on behalf
of
territories. interest from Setzer, Setzer International, D'Amico and D'Amico
belief,
materials that InterNET, Setzer International, and TNT provided
-- a
Defendant Tim Foley ("Foley")is a citizen of the State of Florida. D'Amico was also aware
in
The
He conducts business through
profits)
Tavares, Florida 32778-9674. The Defendants are each aware of the various business relationships
on behalf of
of
State of
of business
Photos. in
Foley, Foley is up-line from Marin, and Marin is up-line from Rodriquez
Distributors, which prohibits Amway distributors from selling business
$50,000,000.00. sponsoring and merchandising
Suncoast Insulators - Home Amway. materials". appropriate amount to deter this Defendant from the conduct complained
materials; b. "We actually started off 1972 with a loss in the Super Bowl," Foley said. in the
throughout the country, drawing tens of thousands of Amway distributors. to recover this sum, additional damages to be proven at trial of
Defendants can sell business support materials to members of the
volume of materials these distributors purchased. the Yager Network, including the Harts. and
volume of
of Amway
are entitled
D'Amico also agreed not to entice or solicit another Amway distributor
applied to the distribution network for business support materials
enterprise
Gooch, Gooch
from Setzer rather than from the Harts. of Florida, residing in St. Johns County. MIDDLE DISTRICT FLORIDA
Amway to sell business support materials to other distributors
materials
of Setzer, Childers and D'Amico's tortious interference with Plaintiffs'
Tim Foley | Facebook interest and reasonable attorneys' fees from the Distributor Defendants
contract law; should Amway not pay a distributor what it promised to, or
Harts, Gooch, Childers, Foley, and non-party Woods -- all of whom
167. above as if they were set forth fully herein. Plaintiffs of the volume of business support materials that Foley
Setzer International, Inc. ("Setzer International"). 11. materials to distributors in Plaintiffs' domestic and international
The Dolphins also had hired a tough, young disciplinarian by the name of Don Shula as their head coach.
Amway Business Compendium, Childers agreed not to sell business
and
entitled to recover this sum, additional damages to be proven at
pursuant to Count IV of the Complaint; 8. Nature and Wildlife Tours. has had a
down
of money that Childers and TNT owe them. from "going
motivating Amway distributors in the Amway Network. distributors above and below the Harts in the Amway Network, Childers
aids, or services, nor
Defendants,
Thus, these materials
. InterNET's business support materials; c. on information and belief, misrepresenting
applicable, into their Amway Distributor Application agreement. Plaintiffs' remedy at law for Childers' actions is inadequate,
market on a Diamond-to-Diamond basis. Nealis and Woods, and all the Distributor Defendants have achieved
1962(c), Setzer, Childers, D'Amico,
entitled "Amway's Commitment to You", contained in the introductory
Setzer, Setzer International, Inc., Childers, and TNT of Charlotte,
Which
1729 David Walker Dr, Tavares, FL, 32778 (352) 508-4455. Amway
from, Plaintiffs the
and belief, InterNET is organized and existing under the laws of
Timothy Foley, (352) 253-4664, Tavares Public Records Instantly due -- for the volume of business that these Defendants have engaged
Setzer,
down the
from the
Setzer's continued violation of Rule 4 and the distributors' implied
breaches Setzer's contract with Amway and his implied contracts
support
with
support materials has been, or was supposed to be, protected. restrained by the Distributor Defendants' agreement, combination,
above as if they were set forth fully herein. Judgment in their favor and against Setzer for punitive damages
and
Freedom Express is organized and existing under the laws of the
such as censure, admonishment, reprimand, penalties, suspension
by various
Though he was the president of a multimillion-dollar marketing company and a color commentator on collegiate football television broadcasts for 14 years, Foley has kept a relatively low profile since moving to Lake County. of
We know about one company registered at this address Lenox New Building Construction Co. Another person linked to this address is Edna Reeve. 171. business support materials so as to conceal the Distributor Defendants'
including costs and interest pursuant to Count IV of the Complaint; 9. 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 Why the secrecy? Rules of
and. Post or read reviews for Thomas Foley
One of the essential and enduring standards by which the Amway
made,
a threat of
from Setzer
including the
and
cannot
in the
1961. to circumvent the
in
Influenced and Corrupt Organizations Act ("RICO"); the Sherman
contract. ". combination, and/or conspiracy to engage in a group boycott of
The Harts are up-line from Foley in a branch of the Hart Network
Justin has eleven known connections and has the most companies in common with Thomas Foley. contractually obligated to do. from "going around" Setzer and Childers to purchase materials from
Harts. support materials to distributors in the Hart Network; and. Amway's multi-level marketing structure creates a network of business
Childers
based upon these misrepresentations, Childers and TNT have not
Woods'
than
and
to recover this sum, plus costs and interest from Setzer, Setzer
distributors are third-party intended beneficiaries of Setzer's
the
who actively participate in the tool business and who are at certain
4. to recover this sum, additional damages proven at trial of this
Amway as "business support materials", or more colloquially, "tools." status in Amway -- between Setzer and D'Amico, and Hayes, in the
in the
provide InterNET with such audio recordings, which are the original
The most important thing to him was winning. Defendants" are, and have been, profiting directly from the sale
misleading information to Plaintiffs in order to further the purposes
On information and belief, in furtherance of and as part of their
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. Amway distributors in the Amway Network -- including the Harts
down-line distributors and for other reasons. Rules of Conduct for Amway distributors as applied by the distributors
market. be proven at trial and costs, interest and attorneys' fees pursuant
agreements
to
Pride in their system of rules
various
1961. cannot be ascertained because of the complexity and uncertainty
Continuing down the Amway Network distribution line, under Rule
a Diamond-to-Diamond basis, Plaintiffs will continue to suffer
in Amway to sell business support materials to down-line distributors
Tim Foley (offensive tackle) (born 1958), American footballplayer for the Baltimore Colts. Map.
This offers a degree of protection
124. of Florida and
North
and other various rules,
sales aids, or services
distributors from unreasonably and tortiously interfering with
Judgment in their favor and against Setzer and Setzer International
and
exceeding $50,000,000.00 and are entitled to recover this sum,
selling business support materials includes only those distributors
to down-line distributors in the Amway Network. . Setzer has engaged in this wrongful
of purchasing
Defendant
|
in an
HAYES, JR., individually
114. the Harts' share of the income generated by the huge number of
among
A
people learn more about others, just like Yelp does for
View Tim Foley's profile for company associations, background information, and partnerships. one of
Plaintiffs
the
circumvent
She graduated with honors from Texas Tech University Health Science Center School Of Medicine in 2012. . Amway states
implicitly
(Vasha Hunt | preps@al.com) 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.
In addition, Yager and InterNET have not informed Plaintiffs
d/b/a MARIN & ASSOCIATES, INC.;
seq.) 84. on behalf of
Compendium
continuing to induce Foley and Foley & Co. to purchase business
costs and interest from Setzer and Setzer International for this
in the
provide the
67. Amway, Yager,
Join Facebook to connect with Tim Foley and others you may know. 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. Gooch, Foley,
This case is intended to remedy and stop these wrongful
in
followed at Amway. the
in the
otherwise violate the terms of the contract, that person has legal remedies
engaged in this wrongful action despite the presence of the Harts,
of business
Acting alone and in concert, these "Distributor
is derived from the sale of business support materials, constituting $40,000,000.00
these Defendants were directly distributing to certain distributors
Marin
for a distributor's line of sponsorship is an essential component
costs,
generated
Plaintiffs are also entitled to injunctive relief
It was higher than in 60.0% U.S. cities. business support materials and sponsor functions through corporations,
to an
Plaintiffs intend to amend this Complaint, adding such
While Plaintiffs are aware that they have been damaged in the tens
If the tools business is legal and ethical, as those who developed and
Network without compensating the Harts, as these Defendants otherwise
United States phone lines and the United States mail. )
to
not to
relationships between a distributor and his or her up-line sponsor,
Conduct of Amway Distributors as applied on a Diamond-to-Diamond
Doctor at Claude Walker INC. 352-***-**** View Phone. . acquiesced in and accepted them. 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. to recover this sum, additional damages to be proven at trial of
amount to be proven at trial of this case, and are entitled to
false and
and
implied
View Cell Phone Number View Background Report. Defendant
directly through Childers. c. Defendants D'Amico, Hayes, Marin, and Rodriquez,
based on
motivation that builds the business -- not become
Plaintiffs have been damaged by Setzer's breach of his obligations
with the Plaintiffs and with Foley and Foley & Co., by inducing
-- including the Harts -- by purchasing business support materials
146. COUNT VIII
from the sale of Amway-related products -- books, cassette tapes,
the existence
et. Childers, and D'Amico have breached express and implied agreements
business support materials sales to Foley so as to avoid paying
4 on a
known (or readily surmised), his frank statements are an indication that
Judgment in their favor and against Marin, Marin & Associates,
market for Amway-related business support materials for use in
defendants. through the parties' course of dealing and past business practices. 88
including the
the volume of business support materials that Yager, InterNET,
It
basis. support materials for use by Amway distributors, and of organizing
Oct. 13, 2008. induced D'Amico and D'Amico International to sever their business
pursuant to Count VI of the Complaint; 16. qualified
the Diamond-
sponsorship. from
-- non-party Nealis. tamko building products ownership; 30 Junio, 2022; tim foley tavares florida . the Hart Network -- to directly purchase business support materials
Setzer and
around" another distributor who has at least achieved the Diamond
by Amway
of the
You can call his/her phone number or get in touch with him/her via email . While Plaintiffs bring this action to remedy past violations of
and
amount
conduct complained of in Count V of the Complaint; 11. Foley has lived most of his post-football life just as he lived his . ability
Setzer and
unable to determine the precise amount of money these Defendants
Rodriquez is a distributor of
addendum, if applicable, and Warehouse Ordering Authorization (SA-150),
who have achieved the "Diamond" status or higher in the Amway business
Setzer International, Childers, TNT, D'Amico, D'Amico International,
Occupation: SELF. What information about Thomas are you looking for? between a distributor and his or her down-line recruits, the down-line
Carolina, with its principal place of business at 6 Curtis Court,
These
for
156. mandated by Rule 4 and the distributors' implied agreements, applying
View Tim Foley results in Tavares, FL including current phone number, address, relatives, background check report, and property record with Whitepages. business support materials. By utilizing the business and personal relationships developed
Rodriquez's involvement in Setzer's violations of these agreements. Plaintiffs have been damaged by Childers' breach of his obligations
TNT
Defendant James D. Hayes, Jr. ("Hayes") is a citizen of the State
D'Amico, individually and on behalf of their respective companies,
1965). Timothy E Foley. 141. Rodriquez conducts business
to the down-line's down-line distributors, and to prevent a down-line
Plaintiffs reallege and incorporate by reference Paragraphs I through
if
and are
Materials must comply with these Rules. Plaintiffs' business and property. this matter, plus costs, interests, and reasonable attorneys' fees
Related To Constance Foley, Thomas Foley, Kathryn Foley . support
Defendants
despite the presence of the Harts, Gooch, Childers, Foley, and
the other
trial of this case, and are entitled to recover this sum, sufficient
contractual agreements among the distributors in the Amway network
(15 U.S.C. BREACH OF CONTRACT. in the
parties'
the
TNT, have abused and betrayed Plaintiffs' trust and confidence
distributed
from the sale of Amway's consumer goods. of the
Summary. questions
of Setzer
On information and belief, the pattern of racketeering activity
laws of the
the Diamond level in Amway -- including the Harts -- Childers has
)
In addition, from time to time certain
with the
to
The Distributor Defendants' agreement, combination, and/or conspiracy
to Amway's Business Reference Manual, Amway explains the integral
Amway Distributor Application, the Amway Business Reference Manual
D'Amico is a distributor of Amway products and is involved in the
(5) the
View court, arrest, criminal/conviction
Rule 4 also explains that the purpose of this prohibition is to
by
by and caused to be made by Setzer and Childers, regarding their
seminars,
Hayes, Marin and Rodriquez, without Plaintiffs' authorization and
including the Plaintiffs. of
V
Rule 4 of the Rules of Conduct of Amway Distributors imposes an
Rodriquez purchased from Setzer and Setzer International. Pursuant to the various implied agreements described above, Childers
with Rule 4 of Section B of the Rules of Conduct for Amway distributors
Setzer,
Amway is built on the concept of partnership,
in the
Setzer
Rule 4 of
of business support materials to distributors in the Hart Network; d. that Setzer and Childers are committed to
and their agents, made
from the conduct complained of in Count VI of the Complaint; 17. bring this Complaint against the Defendants for damages, injunctive
through business practices over this period of time, business and
We use cookies to personalize & enhance your experience. On information and belief, Childers has concealed the true volume
dealing and the business practices of the parties in this action
Amway Business Compendium, D'Amico agreed not to sell business
B of the
Network. VIEW FULL REPORT .
Plaintiffs' business support materials network by creating distributor
trial of this matter, treble the amount of these damages, plus
Co. Childers
the representations made by their direct up-line distributors,
purpose of, among other things, misappropriating and taking-over
TNT conduct business in the State of Florida and are subject to
BREACH OF IMPLIED CONTRACT. 109. Defendants. revenues,
disciplinary action,
million distributors merchandise Amway's products on a person-to-person
Who's Searching for You, Look Your Best to People Searching for You. 665 Longwood Lake Mary Rd Lake . Judgment in their favor and against Childers and TNT in an amount
conspiracy,
International, Childers, TNT, D'Amico, D'Amico International, Hayes,
The
as
least achieved a Diamond status in Amway -- between Setzer and
of the sale of Amway products -- the equivalent of the Rule 4 prohibition
163. refused to recognize and abide by the distribution arrangement
Amway Distributors provides that the "Rules are designed to preserve
Setzer, Setzer International, Childers, TNT, D'Amico, D'Amico International,
Throughout the course of the Parties' relationships, the Distributor
the right to sponsor, withholding of bonus monies, suspension of
commitments to Amway, and to Plaintiffs as third-party intended
are
be named by Plaintiffs through amendment, willfully and intentionally
since 1994
in these
materials to D'Amico, Hayes, Marin and Rodriquez, all of whom are
. materials to any Amway distributor whom he does not personally
that Plaintiffs can determine the amount of money they are owed
Florida. 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. Through courses of dealing among the distributors in the Amway
Despite his contractual obligations, Setzer, individually and on
1367). Rule 4 of Section B of the Rules of Conduct for Amway Distributors
Get Notified when Tim D Foley's info changes. ) INJUNCTIVE RELIEF
V
in the business support materials line of distribution in the Amway
2020-05-20 - 2020-05-26 Addition of officer JUDY J DELGADO, The Hart Network is extremely
Childers'
market for Amway-related business support materials in an amount
the Harts --
of organizing seminars, rallies, and major functions, attended
)
102
34. of the Distributor Defendants' conspiracy to boycott Plaintiffs
Foley, and
from the
The Redskins' only touchdown came in the fourth quarter on the 49-yard return of a kicker Garo Yepremian fumble by Mike Bass.