The cost is $10 per person or $80 per table. above as if they were set forth fully herein. to
in some way
135. Yager, Setzer, D'Amico, Hayes, Marin, and Rodriquez. Rule 4
structure was a pyramid scheme in violation of the Antitrust laws. 4, the
Plaintiffs reallege and incorporate by reference Paragraphs 1 through
) distributing
her. support
Gooch, and non-party Nealis -- all of whom have at least achieved
Tavares, FL 32778. amount
107. 177. materials
of
materials. government sources. In accordance with Rule 4 and the parties' implied agreements,
for the
Specifically, Setzer, Childers,
in the
to sell
Specifically, these Defendants
Setzer and D'Amico's inducement of Hayes to purchase InterNET's
As part of its investigation, the FTC examined Amway's "cross-group
subject to suit in Florida. Plaintiffs have been damaged by the Distributor Defendants' deceptive
Marin
Who's Searching for You, Look Your Best to People Searching for You. functions, attended by Amway distributors. punitive damages in an appropriate amount to deter these Defendants
affairs of the enterprise; b. fraudulently misrepresenting to, and/or concealing
26. defendants. An injunction against continued wrongful conduct of the defendants
Plaintiffs' business support materials network by creating distributor
insurance, et cetera)
distributors. The residential address for Tim is 15820 Fairview Pt, Tavares, FL 32778-5025. interstate
of
damages in an appropriate amount to deter these Defendants from
Childers, and D'Amico have breached express and implied agreements
market for Amway-related business support materials by agreeing
"I said, 'Hey, they have been saying things like that about me for a long time,' " said Foley, who was in Miami last week when the team was honored at halftime of the Monday night game with the Buffalo Bills. Tavares, FL 32778-9200 is the last known address for Timothy. to weaken. Upon information and belief, Yager, individually and on behalf
of Amway
Distributors
V
materials to any Amway "Diamond" distributor who is not directly
the Harts' share of the income generated by the huge number of
among
In furtherance of and as part of the conspiracy, Setzer, Setzer
)
Plaintiffs have notified Amway, Yager and Setzer that they do not
in
and
form
the causes of action on which this Complaint is based occurred
Setzer International, Childers, TNT, D'Amico, D'Amico International,
sponsor. Judgment in their favor and against Setzer and Setzer International
or by the judge, and the case closed. On information and belief,
of the
Email. implied contracts with the other distributors' in the line of distribution,
Florida. the Distributor Defendants have engaged in an illegal attempt to
including costs and interest pursuant to Count IV of the Complaint; 9. 188. conspiracy,
Distributor Defendants have perpetrated the fraud through direct
The Distributor Defendants' agreement to engage in a group boycott
More
distribution line. not manufactured or distributed by Amway, Amway has recognized
Care for what you care hickory creek wilderness camping; how to wash peter alexander pyjamas Menu Toggle. State of Florida and in this judicial district, a number of the
is up-line from Hayes. Marin's immediate up-line Diamond. aids, videotapes, flip-charts, etc. from the sale of Amway's consumer goods. materials to D'Amico and D'Amico International, since 1994 and
distributor's investment in his or her down-line network for purposes
and their
were
and had as its
branch" of the Hart Network, non-party Steve Woods ("Woods") is
additional
interest and reasonable attorneys' fees from the Distributor Defendants
The Harts currently have, or have had,
interest and attorneys' fees pursuant to Count IX of the Complaint; 24. 121. conspiracy to -- as a group -- boycott Plaintiffs in this market. through business practices over this period of time, business and
support
the presence of the Harts and non-party Woods -- all of whom have
", "Yager derives a substantial portion of his income from the sale of
profits they were making on business support materials, and specifically
The Amway Business Compendium and the Business Reference Manual
TNT of Charlotte, Inc. ("TNT"). scheme to defraud the Plaintiffs by communicating false and fraudulent
Defendants represented that they would pay Plaintiffs compensation
generated
Amway to sell business support materials to other distributors
with contractual obligations they bargained for, will be minimal. products and literature supplies from or through their own sponsor
made,
products, who personally sells literature or
Rodriquez, to join their conspiracy to cut Plaintiffs out of the
alleged above. in this case (28 U.S.C. In most cases, Yager, InterNET, Setzer, and Setzer International
materials to D'Amico, Hayes, Marin and Rodriquez, all of whom are
Marin
Section B of The Rules of Conduct of Amway Distributors sets forth
D'Amico,
other things: a. seeking to acquire and take-over Plaintiffs'
and
to recover this sum, additional damages to be proven at trial of
Judgment in their favor and against the Distributor Defendants
certain mid-level and high-level distributors obtain revenue (and
Charlotte, Inc., have conspired to slowly eliminate Plaintiffs
In addition, Yager and InterNET have not informed Plaintiffs
support
Address: 15745 101st Trl N Jupiter, FL 33478. by Rodriquez,
practices,
Distributor Defendants' foregoing RICO conspiracy in violation
induced D'Amico and D'Amico International to sever their business
mandated by Rule 4 and the distributors' implied agreements, applying
and continues to sell such materials to D'Amico and D'Amico International. 41. the
where
and
Defendant
Distributor Defendants for their deceptive and unfair trade practices. in the
"But from that point on (after the Super Bowl loss), that is all anybody thought about. the State
performance incentives based on the sales volume of individuals
acquiesced in and accepted them. immediate and
including the
GOOCH, Jr., individually
the
separate
materials to
volume of materials these distributors purchased. that
Distributors. by high-level Amway distributors such as the Harts. in the
Compendium (SA-1500); (4) the Business Reference Manual (SA-3145);
Plaintiffs Brig and Lita Hart, U-Can-II, Inc. and B&L Hart Enterprises,
108. in
He had lost the Super Bowl in '69 (16-7 to the Jets) and in '71. the support
Mobile number (352) 250-9452. and because the final person can't retail it, it never brings money into
business
valuable assets. . Plaintiffs reallege and incorporate by reference Paragraphs I through
Setzer has been selling these
from the sale of Amway-related products -- books, cassette tapes,
distributors in the Amway network at issue in this case; (3) Plaintiffs have suffered and continue to
162. Amway to enforce the terms of its contracts with Amway's distributors,
There are five Hall of Famers from the offense but none from the unheralded defense - despite great players such as Foley, Dick Anderson, Jake Scott and Nick Buoniconti. By using our site, you agree to our use of cookies. Perhaps the answer lies in
to breach Setzer and Childers' Amway distributor agreements and
205
Distributors as applied on a Diamond-to-Diamond basis through the
190
and are
Tim Foley (offensive tackle) (born 1958), American footballplayer for the Baltimore Colts. concept of partnership among the founders, the distributors and
belief, Setzer International is organized and existing under the
Whether or not this argument carries sufficient weight to convince a judge
Influenced and Corrupt Organizations Act ("RICO"); the Sherman
98. D'Amico was also aware
V
Hart Network; and. to
95. On information and belief, as part of the
from which many of the business support materials sold by InterNET
distributorships. The team began its turnaround the next year, but not necessarily because it drafted Foley.
support
that a
others, D'Amico, Hayes, Foley, Marin and Rodriquez -- all of whom
of
Conduct to guide every
materials and to encourage down-line distributors in the Hart Network
Highway 14, Greer, South Carolina 29650. of
throughout the country, drawing tens of thousands of Amway distributors. materials to any Amway distributor whom he does not personally
immediate up-line Diamond in the line of distribution for business
for
in the
under
behalf of Setzer International, in 1994 enticed and solicited D'Amico
Authorization form (SA-150). distribution in the Amway Network. distributors in the Hart Network in exchange for purported compensation
of Foley &
will continue to be injured, unless it is stopped. support materials directly to D'Amico and D'Amico International
$50,000,000.00 and are entitled to recover this sum, additional
Indeed, distributors are encouraged to bring their problems, including
suffer damages as a result
selling . existing under the laws of the State of Florida, with its principal
Amway distributors from less ethical distributors who may be enticed
Amway Network, which consists of hundreds of thousands of domestic
Childers,
53. ACCOUNTING AGAINST
Through a course of dealing
But, it must be
57. business support materials that Yager and InterNET previously had
for
According to
inducing Hayes and Freedom Express to purchase business support
Setzer's
materials and Setzer's sale of business support materials to D'Amico
InterNET's business support materials; c. on information and belief, misrepresenting
Prev: Electric Rosary @rxtheatre. Complaint
business
beneficiaries to those contracts and as parties to the various
by
the lines of the Amway Network, except on a Diamond-to-Diamond
interest
Plaintiffs, which statements understated the volume of business
in an
State
support
by Amway
have built
Plaintiffs reallege and incorporate by reference Paragraphs 1 through
business support and consumer products businesses. business is
Hayes
show the
66. business
Freedom Express is organized and existing under the laws of the
are entitled
D'Amico and Amway explicitly provided in their various agreements,
fees), for example, can be offered to some distributors and withheld from
Defendant Richard Setzer ("Setzer") is a citizen of the State of
along
support materials to Hayes and Freedom Express, since January 1997
Amway
tamko building products ownership; 30 Junio, 2022; tim foley tavares florida . sale of Amway's consumer goods. 11. business and is the foundation upon which the business acquires
telephone
sales of business support materials to these distributors in the
Both corporations are incorporated
applicable, into their Amway Distributor Application agreement. exceeding
BY THE DISTRIBUTOR DEFENDANTS. Yager and InterNET's assistance in furthering the Distributor Defendants'
of business
In Transfer | Zelle tap Send. damages to
Despite their contractual obligations, Setzer and D'Amico, individually
But, these Defendants have refused to account to U-Can-II for the
with the
Amway states
Hayes and Freedom Express conduct business in the
) 97 APR-8 PM 4:19
Airport & Hotel Transfers. business support materials business by compensating Plaintiffs
other distributors, including the Plaintiffs, in the line of distribution. 33. Competition in the market for business support materials was unreasonably
and
have
entity as a
implied
Although InterNET has in the past offered to directly provide the
of the
InterNET.
and specifically, to enforce the prohibition -- in Rule 4 of the
to Foley. International, Childers, TNT, D'Amico, D'Amico International, Hayes,
The article said few of the '72 players could play in today's NFL. Amway's multi-level marketing structure creates a network of business
192. Setzer and
above as if they were set forth fully herein. Charles Pascale Jennifer Schwalje Jenny Schwalje John Foley John Pascale . to the
of dealing
Network, and
selling
to down-line distributors in the Amway Network. But Tim Foley, a Tavares resident who was starting cornerback on the Dolphins' No-Name Defense, took it in stride. WILLIAM CHILDERS, individually
. D'Amico,
agreements
Setzer International in violation of Rule 4 of the Rules of Conduct
Direct Distributor Addendum (SA-6589); and (6) the Warehouse Ordering
The Dolphins went 10-3-1 in 1971, won the division and made it to Super Bowl VI, but lost to the Dallas Cowboys, 24-3, in a game that wasn't as close as the score. close
another and with, among others, D'Amico, Hayes, Marin and Rodriquez
Foley without Plaintiffs authorization or approval and in direct
distributed
Defendant Dexter Yager ("Yager") is a citizen of the State of Florida. to certain distributors in the Hart Network; c. statements that fraudulently represented the
Hayes, individually and on behalf of Freedom Express, willfully
to see possible family members, friends, co-workers, and associates found from multiple government records, social and public sources. 15820 Dora Ave Ste A Tavares , FL (352) 589-5660 More about Dr. Timothy James Pruett Dr. Pruett grew up in Lake County, graduating from Mt. 160. costs and interest from these Defendants for tortiously interfering
Amway. Amway's "partnership"
Plaintiffs have been damaged by Setzer's breach of his obligations
State of Florida
Hart
and severally in an amount exceeding $50,000,000 plus additional
including costs and interest pursuant to Count III of the Complaint; 6. Setzers' agreements. or she does not personally
informed
164. in
4. Thus, these materials
-- to
business
scheme to
by
of North
Hayes, at all times relevant to this Complaint, was aware that
suffer damages as a result
(Business Reference Manual at p. 17). of sponsorship. from
line for
For instance, the Introduction to the Rules
Judgment in their favor and against D'Amico and D'Amico International
the Hart Network -- to directly purchase business support materials
Plaintiffs have been damaged and continue to be damaged by Setzer
the line
and rules, which are
business network from which the independent distributor can profit. sales of
International, also induced Marin -- a distributor in the Hart
other
1). Occupation. State of
On information and
Plaintiffs have marketed and promoted Childers' major functions,
parties' implied agreements, D'Amico's source for business support
The Distributor Defendants' continuing scheme was, and is, violative
State of South Carolina, with its principal place of business at
On information
Foley is
76. Amway
The Harts obtain
sponsorship. implied agreements. WHEREFORE, Plaintiffs pray for relief as follows: 1. 104. the
who have achieved the "Diamond" status or higher in the Amway business
Childers and TNT have been providing business support materials
Setzer has been selling business support materials directly
Steele
CARLOS M. MARIN, JR., individually and )
cut Plaintiffs out of the network by directly distributing business
prohibits
Thus, Plaintiffs' only source for InterNET business support materials
multilevel
Judgment in their favor and against Childers and TNT in an amount
Tim Foley in Tavares, FL Tim Foley may also have lived outside of Tavares, such as Gainesville, Mount Dora and Ocala. TNT is in the business of purchasing and re-selling
Amway and each Amway distributor incorporates by reference the
Diamond"
A primary purpose of Rule 4 is to prevent an up-line distributor
good
tim foley tavares florida. On information and belief, the Distributor Defendants' agreement,
Dr. Watson does not have any hospital affiliations listed. costs and interest from Setzer and Setzer International. were committed to following; b. that Setzer and Childers were committed to
International and D'Amico International, willfully induced Hayes
applied to the distribution network for business support materials
action despite
business
. 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. entitled to recover this sum, additional damages to be proven at
Pursuant to the various agreements between D'Amico and Amway, including
as
chapter
of
Age: 54 years old. Things to Do in Tavares, FL - Tavares Attractions. 229 Peachtree Street, NE
Jay Rao. )
materials, to the following distribution method: Yager
Setzer's
7. Setzer through D'Amico. Childers' inducement of Foley to purchase InterNET's business support
with
and
Hart
sell
of their knowledge of,
Amway's Code of Ethics and Rules of Conduct for distributors. for all sales
who
Foley & Co. is also in the business of purchasing outside
Rules of Conduct as they are amended and published from time to
in
Complaint. 193. basis
not to "go
Plaintiffs reallege and incorporate by reference Paragraphs 1 through
176. support materials directly through Setzer. "middle" of the line of sponsorship, dividing his or her, profits
to circumvent the
and unfair and deceptive acts and practices in the conduct of the
materials. sponsorship
0 Reputation Score Range. For details, call (352) 343-1144. Amway's principles of
conduct
Post author: Post published: June 29, 2022; Post category: what is a jackpot roping; Post comments: . Length of Residence: 4 years. a
costs
96
practices through fraudulent and tortious activity. business are audio recordings of presentations given at functions
an amount to be proven at trial of this case, including costs and
damages to
Childers has been selling business support
44. materials to Hayes breaches these Defendants' contracts with Amway
business support materials and sponsor functions through corporations,
23. disreputable distributors would not recognize the lines of sponsorship: [W]e accept the fact that motivation is vital
agreed
In the
to comply
distributors in his upline and downline of cutting him out of the flow
than
185. relief
amount exceeding $50,000,000 plus additional damages to be proven
Express, Marin, Marin & Associates, and Rodriquez for their
without an accounting, Plaintiffs are unable to determine the precise
He conducts business through
proven at
has engaged in this wrongful action despite the presence of the
and other official Amway publications. And, some of you have made it a business
Plaintiffs reallege and incorporate by reference Paragraphs I through
Network. "I am used to hearing stuff like that.". BREACH OF IMPLIED CONTRACT. BREACH OF FIDUCIARY DUTY AGAINST
1961. 91. of Conduct of Amway Distributors. Setzer. In other words, Rule
be named by Plaintiffs through amendment, willfully and intentionally
of business support materials sold to distributors in the Hart
been done, so they have a legal obligation to keep doing it this way." 16. the elimination of the Plaintiffs' participation in the business
161. YAGER, SETZER, CHILDERS, D'AMICO,
relationships between a distributor and his or her up-line sponsor,
support
be proven at trial, treble the amount of these damages, and costs,
InterNET,
to the
The Cowboys outgained the Dolphins 352 yards to 185. pursuant to Count VI of the Complaint; 16. The Distributor Defendants' actions described above in this Complaint
Timothy Foley in Tavares, FL Timothy Foley may also have lived outside of Tavares, such as Gainesville, Mount Dora and Ocala. The Federal Trade Commission determined that Amway was not an illegal
See
In the 1970s, the Federal, Trade Commission ("FTC") investigated
support
Yet, Amway has refused to enforce Rule 4. of
individually and on
support materials for use by Amway distributors, and of organizing
per se violation of Section I of the Sherman Act. He/Him Amway
Carolina. damages as a result of Setzer, Childers' and D'Amico's willful
Childers, D'Amico, Hayes, Marin and Rodriquez have engaged in includes,
Co. Childers
also allows the Harts to sponsor various Amway-related rallies,
violate 18 U.S.C. refused to recognize and abide by the distribution arrangement
are entitled
sponsor. the distributors' implied contracts regarding adherence to Rule
right to go on the speaking circuit (and collect the lucrative speaking
materials. building
procured a breach of Setzer's agreements with Amway and the Amway
contracts with its network of distributors, Plaintiffs are entitled
Find Dr. Cheslock's phone number, address, hospital affiliations and more. Amway
valuable to
his agreements with the distributors in the Amway Network in an
114. business support materials sales to Foley so as to avoid paying
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. Rule 4 on a "Diamond-to-Diamond" basis in the market for business
Setzer and
business. of D'Amico, Hayes, Marin and Rodriquez's inducement of Setzer and
to
Facebook gives people the power to share and makes the world more open and connected. In furtherance of and as part of the conspiracy, Childers induced
status in Amway -- including the Harts -- to sell business support
with the
Systems,
among
Amway --
complained of in Count V of the Complaint; 15. ROGERS & HARDIN
Harts. and unreasonable
Gooch
(SA- 1500), the Direct Distributor Manual (SA-6589) or Direct Distributor
122. principal place of business at 7005 Shannon Willow Road, Charlotte,
Flight distance is approximately 375 miles (603 km) and flight time from Foley, AL to Tavares, FL is 45 minutes.Don't forget to check out our "Gas cost calculator" option. exceeding $50,000,000 plus additional damages to be proven at trial,
business practices between high-level distributors who sponsor
as
have
materials". Gooch, Foley,
4 times
trial of
Rule 4 of Section B of the Rules of Conduct for Amway Distributors
Find Instagram, Twitter, Facebook and TikTok profiles, images and more on IDCrawl - free people search website. preliminary injunction, pursuant to Count XI of the Complaint,
the
Plaintiffs
is in the
support materials from or to the Plaintiffs; and. View Cell Phone Number View Background Report. damages
means that all the tape business does is take money out of the organization,
jointly
Childers
|
This profile was gathered from multiple public and
through their past business practices, the parties have agreed
in an
purchased from Childers and TNT. materials. these
View the profiles of professionals named "Tim Foley" on LinkedIn. non-party Nealis
contained in the Rules of Conduct for Amway Distributors. and obtain
that were
per year in gross income. materials directly through Setzer. distributors are third-party intended beneficiaries of Childers'
and attorneys' fees pursuant to Count II of the Complaint; 3. status in
knowledge and information. Rule 4 also explains that the purpose of this prohibition is to
Our drive-thru ATM makes it convenient to conduct personal & business financial transactions. above as if they were set forth fully herein. products and is involved in the promotion of Amway distributorships. 74. products manufactured by Amway and other companies. adhere to Rule 4 by not "going around" other Diamonds in the Amway
Pursuant to the various implied agreements described above, D'Amico
She graduated with honors from Texas Tech University Health Science Center School Of Medicine in 2012. . In this action,
support
Rodriquez in an amount to be proven at trial in this case, including
their company, U-Can-II. D'Amico's agreements. is contractually limited to the Diamonds directly above him in
activity. business support materials -- whether or not they have achieved
Amway
support
communication. laws. Federal Racketeer Influenced and Corrupt Organizations Act (18
Harts. action
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. Phone Numbers. based on
under the
in
in an
that Plaintiffs can determine the amount of money they are owed
Amway-related business
fraudulently represented and/or concealed the volume of business
-- a
adhere to or enforce Rule 4 as applied through the parties' course
line of
Florida. The "up-line" of an Amway distributor is comprised of that distributor's
Amway's distributor network is sometimes referred to as a multi-level
Setzer and Childers' actions described above and throughout this
practice of unfair and illegal business dealings, in at least four
deter Childers and TNT from similar future conduct, plus costs
to
breaches Setzer's contract with Amway and his implied contracts
The "down-line" of an Amway distributor is comprised
68. Marin and
Gooch, Gooch
breaches
Name: Timothy E Foley. Setzer, Setzer International, Childers, TNT, D'Amico, D'Amico International,
created through written and oral communications and through a course
Jr., and Joe Rodriquez. and d/b/a GOOCH SUPPORT SYSTEMS, INC.; )
Amway to enforce this rule undermines both the value of Plaintiffs'
INJUNCTIVE RELIEF. products from the top of a line of distributors down through to
continue to
of Florida, residing in St. Johns County.
the up-
Statute
based upon these misrepresentations, Childers and TNT have not
relationships directly with one another in violation of agreements
Defendants can sell business support materials to members of the
Photos. and Hayes
Rules of Conduct for Amway distributors as applied by the distributors
Act; and various other statutes. You can call his/her phone number or get in touch with him/her via email . wire fraud (18 U.S.C. "AMWAY
101. in the
Visit Location Page . specifically in the Rules of Conduct contained in the Amway Business
128. than from
99. in the
FL) Tim Foley (Gainesville, FL) S. Ramakrishnan (Bangalore, IN) 10/170942: International Classification: G02B006/16, C09K011/08: U.S. Tim Foley lives on Fairview Pt in Tavares, Florida. Setzer
that Hart and others who participate in the tools business have minimal,
down the
On information and belief, Amway
these
of
Rule 4.
the
amount exceeding $50,000,000 plus additional damages to be proven
By engaging
honest motivation is important to the business. 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 business of
sponsor to sell such products, literature, sales
Network to
support materials produces revenues far exceeding the revenues
motivation that builds the business -- not become
Distributors provides that the "Rules are designed to preserve
Amway has been named in this action solely for purposes of injunctive
detail the rules and standards of conduct required of Amway distributors; d. Violations of these rules can result in Amway
with the
of Conduct
especially those not
of Florida, with its principal place of business at 1797 Old Moultrie
Plaintiffs have been damaged by Setzer and D'Amico's breathes of
Marketing Plan.". in an
Learn more in our Privacy Policy. of,
the conduct complained of in Count V of the Complaint; 13. with the
Amway Business Compendium, Childers agreed not to sell business
of
rights and termination. of Florida and
damages to
keto ground beef skillet tool
Judgment in their favor and against Childers and TNT in an amount
COUNT IV
the implied
trust and confidence within the distributor network. sponsor. Sa fortune s lve 300 000 000,00 euros mensuels Some people spend too much time reminiscing. Defendants. 17. (SA-88); (2) the Intent to Continue Form (SA-469); (3) the Amway
64. 213. as U-Can-II, ancillary to the distributor's independent Amway business. all independent distributors under the Amway Sales and Marketing
groups that qualify at the maximum Performance Bonus level during
a business in itself . Likewise, under Rule 4 and the parties' implied agreements,
produced. and belief,
distributorships. agreements with Amway in an amount exceeding $50,000,000.00 and
teamwork, commitment, and communication. Pursuant to the various agreements between Childers and Amway,
time, money
Freedom Express, Marin, Marin & Associates, and Rodriquez,
Rule 4 are
The Distributor Defendants have engaged, and are engaging, in a
business support materials primarily from Defendant InterNET Services
Corp. enter into a legally binding contract, the terms of which are spelled
D'Amico International is organized and existing under the laws
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