1 Type of Action
1 Jurisdiction and Venue
2 Parties
General Allegations
9 The Amway Business and the Essential "Line of Sponsorship."
12 The Stewart Organization's Line of Sponsorship.
14 Development of the Amway-Related Tool and Function Business Known as the Business Support Materials ("BSMs") Industry.
14 The Promulgation of Rules Governing the BSMs Industry.
18 Defendants' Recognition of the BSMs Rules and Course of Dealing.
20 The Promotion of the BSMs Industry.
21 Amway's Recognition and Tacit Consent of the BSMs Industry.
22 The Myths Created and Fostered by the Upline Defendants.
23 Amway Co-Founder's Early Concern for BSMs Abuses.
24 The Stewart Organization's Successful Business Operations.
27 The Conspiracy to Violate the BSMs Rules and Long-Standing Course of Dealing and to Injure Stewart and the Stewart Organization.
28 1996: BSMs Rules Abuses Begin at the Behest of the Conspiracy.
30 The Formation of Global and ProNet in February 1998.
33 ProNet and Global Used to Further the Objectives of the Conspiracy.
40 ProNet's More Recent Efforts to Direct-Ship Tools to Distributors.
41 Invalidity or Inapplicability of any Purported Arbitration Clause.
41 ProNet is an Illegal Pyramid in Violation of R.S.Mo. § 407.400 et seq.
42 The Secret Formation of ProNet Profit.
43 The Amway "Amvox" Voice-Mail Messaging System.
43 The ProNet Profit "EasyTel" System.
45 The ProNet Profit Website.
46 "Secret Pots."
46 The ProNet Charity Fund.
47 The Conspiracy's Tool Pricing Scheme.
48 The Conspiracy's Destruction of the Stewart Organization.
51 Defendants Have Superior Knowledge About BSMs Activity Involving Plaintiffs' Downline and Owe Plaintiffs an Accounting.
Liability
51 COUNT I: Unlawful Pyramid Scheme
53 COUNT II: Tortious Interference
54 COUNT III: Breach of Implied in Fact Contract Concerning the Tool Business
55 COUNT IV: Breach of Duty of Good Faith and Fair Dealing Concerning the Contract Governing the Tool Business
56 COUNT V: Breach of Implied-in-Fact Contract Concerning the Function Business
57 COUNT VI: Breach of Duty of Good Faith and Fair Dealing Concerning the Contract Governing the Function Business
58 COUNT VII: Breach of Duty of Good Faith and Fair Dealing Concerning Nitro's Consignment of BSMs Inventory to ProNet
59 COUNT VIII: Violation of R.S.Mo. § 416.031.1 -- Vertical Price Fixing
60 Requests for Relief
- Amway v Scheibeler
- Stewart v Gooch, Childers et al, Third Amended Complaint, January 2003
- Hart v Gooch, Childers et al, First Amended Complaint, January, 2003
- Netco v Dunn, Gooch, Childers et al, First Amended Complaint, January, 2003
- Hart v Gooch, Childers et al, April 19, 2002
- Stewart v Gooch, Childers et al, January 2002
- Scheibeler v Harteis, November, 2001
- $16 Million in Damages Sought in AMO "Tools" Squabble, August 3, 2000
- Canadian Tax Authorities v Distributors, July 14, 2000
- IRS v Distributors, June 2, 2000
- Fish Deposition
- Team Resources v Fish and Andrews
- Morrison et al v. Wilson et al, June 22, 2000
- Woods v Britt, August 1998
- Musgrove v Amway, June 1998
- Griffith v Amway, May 1998
- Taylor v Duncan, March 1998
- Hayden v DiSalvatore
- Touchton v Amway, Gooch et al
- Lavoie v Yager, January, 1998
- Hart v Gooch et al, April 1997
- Setzer v Amway, 1985
- Stewart v Gooch, Childers et al, Third Amended Complaint, January 2003