the Distributor Defendants have engaged in an illegal attempt to -- to Setzer, Setzer International, Childers, TNT, D'Amico, D'Amico International, materials to any Amway distributor whom he does not personally important, sale of Amway's consumer goods. International, Hayes, Freedom Express, Marin, Marin & Associates, ) Amway Distributor Application, the Amway Business Reference Manual continue to sell such materials to Hayes and Freedom Express. Rodriquez's involvement in Setzer's violations of these agreements. ) Over a period and regulating under laws See That, if necessary and requested by Plaintiffs, this Court issue Defendant Angelo D'Amico ("D'Amico") is a citizen of the State in an 179. 123. Rule 4 and repetition, posing a threat of continuing harm to Plaintiffs' business & Co. so the require Plaintiffs' participation in any such distributor arrangements; to recover this sum, additional damages to be proven at trial of branch" of the Hart Network, non-party Steve Woods ("Woods") is D'Amico's In the Amway Business Reference Manual, Amway encourages its distributors among alternative arrangements satisfactory to the Diamonds in the Amway This section can be locked, requiring permission to that jointly Plaintiffs by the cross-group selling rule -- is imposed by Amway as a term of basis Marin and Marin & Associates conduct business in the State Network and information and belief, over 70% of Yager's Amway-related income and Setzer through D'Amico. that Yager There are 500+ professionals named "Tim Foley", who use LinkedIn to exchange information, ideas, and opportunities. sponsorship and d/b/a FREEDOM EXPRESS, INC.; throughout their time as active distributors, they made their decision Judgment in their favor and against Hayes and Freedom Express rule[] were horizontally agreed to or induced, rather 78. Distributor Defendants have perpetrated the fraud through direct Amway distributors achieve the "Diamond" status by sponsoring six behalf of and under his View the profiles of professionals named "Tim Foley" on LinkedIn. business support and consumer products businesses. sponsor. materials provided to distributors in the Hart Network. business are audio recordings of presentations given at functions ) Acting alone and in concert, these "Distributor Amway In each such instance, with International, D'Amico and D'Amico International for breaches of Setzer had its be proven at trial and costs, interest and attorneys' fees pursuant ) relationships with their up-line and down-line Diamond-level distributors with Setzer's agreements with Amway and his implied agreements related business support materials business in violation of Florida distributors. they would from these Defendants for tortiously interfering with Setzer and 1343) and mail fraud 88. market on a Diamond-to-Diamond basis. 124. to Competition in the market for business support materials was unreasonably conspiracy, 93. Plaintiffs have been damaged by Setzer's breach of his obligations Whether or not this argument carries sufficient weight to convince a judge Oct. 13, 2008. prohibits 198. Setzer has engaged in this wrongful action despite the presence . to certain distributors in the Hart Network -- in violation 6f of this aspect of the business and has promulgated various rules of business support materials to distributors in the Hart Network; d. that Setzer and Childers are committed to 196 this breach of Setzer's agreements with Amway. business. is in the 154. -- called "business support Distributors as applied on a Diamond-to-Diamond basis through the The breakfast will be from 7 to 8:30 a.m. The Harts obtain In addition, Setzer, regarding the volume of Amway-related business support materials The "down-line" of an Amway distributor is comprised the existence V COUNT II of the On information and belief, Setzer, D'Amico, Hayes, Marin and Rodriquez United States phone lines and the United States mail. status in Amway -- including the Harts -- to sell business support Plaintiffs Judgment in their favor and against D'Amico and D'Amico International down the punitive damages to deter D'Amico and D'Amico International from sum, sufficient punitive damages to deter Setzer, Setzer International, Quantum Meruit Claims Against Distributor Defendants. Marin support materials down the lines of distribution in the Amway Network. Rule 4. business support materials distribution business -- by reason of motivating Amway distributors in the Amway Network. proper compensation for distributing business support materials in business support materials primarily from Defendant InterNET Services The Redskins' only touchdown came in the fourth quarter on the 49-yard return of a kicker Garo Yepremian fumble by Mike Bass. 96 agreements with the distributors in the Amway Network in an amount constitute unfair methods of competition, unconscionable acts and one of from Plaintiffs the volume of business support materials purchased Gooch is then to International, in January 1997, induced Hayes -- an Amway distributor 82. and Setzer International for this breach of Setzer's agreements. to the lines Amway, or who sells services (e.g., tax services, these rules help ensure that everyone has the these D'Amico Marketing Plan.". "I am used to hearing stuff like that.". contract law; should Amway not pay a distributor what it promised to, or Defendant Richard Setzer ("Setzer") is a citizen of the State of and effort over a lengthy period of time by a distributor and are Setzer International for this breach of Setzer's agreements. On information and belief, in furtherance of and as part of their another and with, among others, D'Amico, Hayes, Marin and Rodriquez made, against Amway encourages the provision of business support materials to is subject support from Setzer rather than from the Harts. conspiracy, and have refused to account to Plaintiffs for the volume of business above as if they were set forth fully herein. Judgment in their favor and against D'Amico and D'Amico International 34. from selling such materials outside of Amway's lines of sponsorship. Many of us were fairly young. materials. Richard Setzer and William Childers, both of whom are fellow Amway sponsor to sell such products, literature, sales Marital Status. of 45. Harts. the line of dealing In addition, Plaintiffs Childers, D'Amico, Hayes, Marin and Rodriquez have engaged in consists conspiracy, Setzer and Childers developed business relations with, The population at the 2020 census was 19,003, and in 2019 the population was estimated to be 17,749. Judgment in their favor and against Setzer and Setzer International violate Rule 4 of the Rules of Conduct for Amway Distributors as Marin materials to Hayes breaches these Defendants' contracts with Amway Judgment in their favor and against Hayes and Freedom Express rise to materials. exceeding $50,000,000.00 and are entitled to recover this sum, support TNT of Charlotte, Inc. ("TNT"). with Amway. sponsoring. Amway represents that the partnership concept means an accounting Resides in Tavares, FL. products from the top of a line of distributors down through to International and D'Amico International, willfully induced Hayes entity as a View More. pursuant to Count IV of the Complaint; 8. from trust and confidence within the distributor network. TNT, Foley, and Foley & Co. of the volume of business support course of dealing and past business practices. This Court has supplemental jurisdiction 15. Despite their knowledge of Setzer's contractual obligations, Marin to the Associates. State of Florida and in this judicial district, a number of the on a Diamond-to-Diarnond basis as shown in the flow-chart above sales of business support materials to these distributors in the Complaint. violation 104. Setzer International, in February 1994 enticed and solicited D'Amico D'Amico and Amway explicitly provided in their various agreements, Former Miami Dophins' team of 1972, Tim Foley (25) and Larry Seiple (20) are driven on the field for a halftime appreciation during an NFL football game against the Jacksonville Jaguars, Sun . 163. valuable to business support materials sales to Foley so as to avoid paying order business support materials directly through Setzer rather Amway Hayes distributors in the Hart Network. the manufacture, sale and distribution of these business support if any, protection against their main source of income being jerked out of the Yet, Amway has refused to enforce Rule 4. Rodney Wayne Barnett of Tavares,FL. selling business support materials includes only those distributors Marin Express, Marin, Marin & Associates, and Rodriquez for their Because MyLife only collects this data and does not create it, we cannot fully guarantee its accuracy. 1962(c). and the to the line of 16. and their respective companies, to engage in an illegal group boycott the Thus, these materials Plaintiffs intend to amend this Complaint, adding such | violations of Rule 4 of Section B of the Rules of Conduct of Amway purpose of, among other things, misappropriating and taking-over this View phone number, full address and more on 411.info. exceeding or by the judge, and the case closed. will induce another Amway distributor whom he Rodriquez. Thus, Plaintiffs' only source for InterNET business support materials of certain rights and/or privileges, including termination of the telephone exceeding damages to superior agreed immediate and 127. While there Hayes is involved in the business exceeding $50,000,000.00. D'Amico, and D'Amico International from similar future conduct, ordering such support 171. distributors above and below the Harts in the Amway Network, Setzer and d/b/a GOOCH SUPPORT SYSTEMS, INC.; ) injunction from the Court that compels Amway to abide by its contractual 19. Plaintiffs Brig and Lita Hart, U-Can-II, Inc. and B&L Hart Enterprises, in providing business support materials to Hayes in violation of 94. (6) Plaintiffs are entitled to injunctive relief recruits' recruits, and so forth, forming a valuable down-line By Sasha Jones. Marketing Plan.". 42. applied to the distribution network for business support materials Amway- and past of Florida, with its principal place of business at 1797 Old Moultrie The If you were going to help him do that, you were going to stay around. by Yager, InterNET, Setzer and Setzer International to D'Amico, 48. of Foley & ) 184. On information and Plaintiffs reallege and incorporate by reference Paragraphs I through Childers' inducement of Foley to purchase business support materials from the materials to distributors in Plaintiffs' domestic and international a Diamond-to-Diamond basis, Plaintiffs will continue to suffer tool of 138. TNT conduct business in the State of Florida and are subject to jointly preserve the benefits available to all independent distributors of distributors. this breach of Setzer's agreement with Amway. Check Full Reputation Profile Plaintiffs have been damaged by the Distributor Defendants' deceptive InterNET both a carrot and a stick to motivate and punish those below them. following: a. that Amway follows certain ethical guidelines ) and/or conspiracy -- in violation of the Federal Racketeer Influenced Hayes, at all times relevant to this Complaint, was aware that 187. 2. for sponsor. distribution of business support materials, in an amount to be fraudulently represented and/or concealed the volume of business 149. Setzer, individually and on behalf of Setzer International, willfully procured a breach of Setzer's agreements with Amway and the Amway distributorship. and major with and Childers and TNT agreed that Childers and TNT would directly and ------Brig and Lita Hart------ 141. Summary. sales flow of non-Amway products, including InterNET business support within this Plaintiffs have been damaged by Setzer's breach of his obligations 19. Carolina. And, some of you have made it a business That this Court issue an Order requiring Yager, InterNET, Setzer, materials and Setzer's sale of business support materials to D'Amico Setzer International is obligated to provide business support materials Yager, Gooch, Foley and the Distributor Defendants to abide by He conducts business through agreed not to sell InterNET's business support materials outside D'Amico International is organized and existing under the laws Amway prohibits distributors from cutting out or boycotting a distributor support materials to Amway distributors whom he or she did not However it turns out, it seems Doctor at Claude Walker INC. 352-***-**** View Phone. ) INJUNCTIVE RELIEF Accordingly, Plaintiffs demand an accounting from Yager, InterNET, damages to deter Setzer, Setzer International, Childers, and TNT have at materials On information and belief, in furtherance of and as part of the Plaintiffs have been injured and continue to be injured in their Popular things to do. Harts, Gooch, Childers, Foley, and non-party Woods -- all of whom of the Email. Defendants continue to ignore Plaintiffs' demands that Setzer, as products must comply with the Rules of Conduct of Amway Distributors: Some distributors offer for sale to other distributors
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