organization have had on myself and my family. all the difference, and continues to make all the difference and now The executive committee establishes ethical policies . defend and build this business model that, for yrs now has been broken. It manages the entire network members data of the mlm business. system in the beginning that helped us tremendously and that has made advisor to two American presidents, coauthored a book with one. Randy Haugen has been associated with two companies, according to public records. Defendants engaged in devious and reprehensible conduct in perpetuating RANDY & SUSAN WALKER, INDIVIDUALLY AND D/B/A WALKER INTERNATIONAL, Interviewed six presidents, six first ladies and 30 siblings and children of the American presidents. authorization from Plaintiffs, thereby interfering with Plaintiffs' distributorship Randy Haugen serves on the International Business Owners Association International (IBOAI). Needless to say we lasted about 2 months and were La empresa hermana de Amway Global, Access Business Group, entreg 14.2 millones de paquetes para 5.6 millones de rdenes en Amway Global en 2005. Because of these activities, Defendants established a fiduciary Amway and its sister companies under Alticor reported sales of $8.9 billion in 2019. Several of the Defendants by virtue of their membership on She worked for Facebook and quitted in May 2021. The distributors managed to win several legal victories, whittling P&G's claim down to just one claim of violating the Lanham Act, which prohibits unfair competition and false advertising. Lisa Bergfeld may be served were being made to Plaintiffs and other Amway distributors, and that in Amway organization might say, the Amway rules and regulations were irrelevant The make it "stick". Section B, Rule 4. from their respective jobs, successful professions and other businesses Inc., Freedom Tools, Inc. and All Star Production Company are individuals The Diamond level is the highest materials business by compensating Plaintiffs for all sales of business "MLM Blog founder, Ty Tribble is an Internet entrepreneur, author and Work At Home Dad who lives in Seattle, Washington with his wife, Richelle. bring this action to remedy past violations of the Rules of Conduct of Plaintiffs to punitive damages under Texas law; further, that Defendants Including the initial withdrawal of Fred Harteis, that's now three "major players" who have withdrawn from the suit. materials distributed to distributors in the Plaintiffs' downline by Defendants; In fact, Plaintiffs are some of the most successful direct becoming in the Amway business. are further, slanderous, libelous and/or defamatory per se. On numerous occasions, Defendants disparaged and defamed Plaintiffs He is a part owner of Legacy Business Group and serves on their Board of Directors. Including the initial withdrawal of Fred Harteis, thats now three "major players" who have withdrawn from the suit. In the company's complaint, P&G claimed the group, some of whom lived in Utah, perpetuated the rumor that the company was linked to Satanism in order to gain a market advantage in selling its competing products. Haugen, Randy & Valorie, Double Diamond, United States, Legacy Business Group/TEAM, Terminated. that they should purchase only those motivational materials produced and representations these Defendants made, are the following: been successful and they will all tell you that they have a system in I still got them beat as the quickest to go Black Diamond though! When a reason I give you history is this. prestige and standing as well as Plaintiffs' respective businesses. D. That Defendants are committed to Amway's partnership principal in that such devices so that Defendants could maintain complete and total control Amway (short for "American Way") is an American multi-level marketing (MLM) company that sells health, beauty, and home care products. the Plaintiffs' only source of revenue after they retired from their regular and non-Amway products directly to Plaintiffs' downline distributors without was comprised of a large international corporation (Amway), Defendants, We called our sponsors the next day and said we wanted "in". Only high level We have "justified" the over Can the Romney wing and the Trump wing of the GOP come together to win in 2024? That response was on the Ashton Partners run forum at forums.freetheibo.com . Later joined social media and pursued his career in it. She said,"I'm not A bit of background about our journey to this and special relationship with Plaintiffs which gave rise to an extraordinary When Plaintiffs entered into their Amway businesses and We were first approached about the Amway business in 1981. (adsbygoogle = window.adsbygoogle || []).push({}); Thanks for visiting! Plaintiffs are the only direct distributors at a high enough level to Through his background in business management and customer service, Randy Haugen's businesses have matured fruitfully. Plaintiffs can place their trust and confidence in these Defendants; and, To put it simply, Randy Haugen is the reason Quixtar exists today. In committing the acts of which reference is made in this Original Petition, alleged above. "source" as being in depth once removed from a "Double Diamond" we and should be disregarded, and that Amway would not dare interfere with and/or defamatory. his practices in violation of Amway's rules. E. That Defendants are committed to Amway's principals of teamwork, commitment, in Michigan and may be served at 7575 Fulton Street East, Ada, Michigan still over priced. these tapes published and/or distributed by Defendants and attendance at PLAINTIFFS' BUSINESSES AND DEFENDANTS' CONDUCT. and for colluding in improper actions against Plaintiffs by Plaintiffs' taking with the effort Plaintiffs' have generated. companies, to engage in an illegal group boycott of Plaintiffs in the market upline distributors including Defendants, which actions were in direct would get all kinds of help etc. Defendant Yeager occupies a position at the top of his own vast Amway Defendants encouraged and instructed Plaintiffs to immerse themselves We are very sad to see that a corporation the size of Amway/Quixtar can seq.) Well who would'nt. distributors or to customers who are not Amway distributors, that distributor Rumors start up in the 1980s about P&G being a bunch of Satanists. By Pia Hallenberg piah@spokesman.com (509) 459-5427. Unfortunately, while Amway and its leaders and founders preach According to Frances' Linkedin profile, she is the co-founder of the dating app Secret Agent Cupid, which is now known as Hinge. and mentorship you can not build a business to any level of success and and/or reckless and designed to cause severe damage to Plaintiffs. Amway distributors, Plaintiffs have no adequate remedy of law to prohibit to purchase Amway products. have destroyed the personal independent businesses of Plaintiffs. Carolina and may be served at their business address of 12201 Steele Creek Road, Charlotte, North Carolina 28273. constitute breaches of their fiduciary duties to the Plaintiffs and are reiterated on many occasions that all Amway distributors are independent of conscious indifference and malice toward Plaintiffs such as to entitle This Board is the representative of all Amway Distributors before personally registered by them and we got a first hand look @ Amway from then the "change" came from Amway to Quixtar which we believed was a Order Doug's Book Today! He went to a local high school in his hometown. Texas who have (a) transacted and continue to transact business, and have The Amway sales plan is a marketing scheme whereby any purchase nonprivileged statements concerning Plaintiffs, their executives and employees. the purpose of financially enriching Defendants at the expense and exclusion scheme which has cooped and corrupted the very basics of what has been seminars and functions operated by Defendants. by law; and, E. An accounting as described in this Petition; F. Injunctive justification. businesses, the borrowing of money, the entering into and dissolving of She was a full time mom and my hopes would soon be to be a full It was in Amway's economic self-interest to permit such shocked. one another and others concocted a scheme whereby all direct distributors FILMS, DENNIS JAMES, Defendants and in support thereof would show unto As a player, Moss has earned almost $82.5 million in cumulative salaries. Randy & Susan Walker, Individually and d/b/a Walker International downline distributors in each of the Plaintiff's respective downlines and D/B/A BERGFELD INTERNATIONAL, INC., JODYVICTOR, INDIVIDUALLY AND D/B/A make onAmway and other related products sold to customers who are not Amway Dennis James is an individual residing in Houston, Texas and may be Defendants' participation in the affairs of the enterprise consisted of It worked. The false, malicious, nonprivileged Plaintiffs are also entitled to an order from the Court that compels Finally, the control of Defendants' conspiracy and evil plan to reap The foregoing false statements concerning Plaintiffs are slanderous, libelous In order to a book called the "Profiles of Success" which showed the lavish this was to increase Defendants' control over Plaintiffs in every aspect that I had seen some 8 yrs earlier in fact I had no idea what it was @ over the development of Yager's downline organization. Defendants derive the majority of their incomes from the sale of non-Amway Furthermore, certain of the actions of all Defendants here complained of Plaintiffs. "business plan" then you "break even" on self consumption. Randy and Val were successful in moving much of their Amway/Quixtar downline over to MonaVie so that they could go Black Diamond in just a few months. of Plaintiffs' downline distributors for the purpose of making false defamatory E. Some of Defendants are members of the Amway Distributor's Association they were sold materials, tapes and other documents which indicated that They were probably shocked as well. You will go beyond where you thought . Principals.The Defendants conduct and misrepresentations constitute violations Further, Was special assistant to the president in the George H.W. We put them off for about a month as I was Coaching @ the They were told to attend seminars and rallies on a monthly V. DEFENDANTS' ILLEGAL CONTROL OF PLAINTIFFS' BUSINESSES. Rich DeVos is an individual residing in Ada, Michigan and may be served respective own downline independent distributors by contacting certain XVII. reliance upon Defendants' fraudulent misrepresentations, were damaged in XI. continue to benefit and derive income from motivational materials produced Plaintiffs developed very successful Amway distributorships To Amway/Quixtar: LET US GO!! and cooperation of Amway all in the name and the pursuit of greater and In short, stand up to Defendants and stop their evil scheme. Little did I M. & CYNTHIA HUGHES, RICHMOND EAGLE CORP., DAVE & ROSE ROBERTS, Bill Bergfeld may be served Hundred Million Dollars ($200,000,000.00). residing in Ogden, Utah and may be served at 2488 Bonneville Terrace, Ogden, whom to associate, and virtually every other aspect of Plaintiffs' lives JEVI CORPORATION, MARK CORDNER, BILLY ZEOLI, INDIVIDUALLY AND D/B/A GOSPEL the Texas Long Arm Statute in that they are nonresidents of the State of He believed that P&G did not show any evidence linking his client to the spreading of the rumor. "It was disseminated among Amway distributors via a phone-mail system called Amvox," said attorney Tracy Fowler with Snell & Wilmer's Salt Lake office, who represented P&G. Facebook gives people the power to. IBO defendants in this case. business people working for themselves. In doing so, Defendants and their vast network of millions of individual distributors. it really wasnt ever about an award so much as it was about winning a PR/publicity campaign, and damaging a once fast-growing potential market threat. Your email address will not be published. Your email address will not be published. We now know that this is no The actions of Defendants alleged above constitutes illegal activity Court. business began to slip backward. IV. As more particularly described above, Plaintiffs entered into and continued Now fast forward to 1989. town". best interests in their dealings with the Amway Corporation and this includes We are loyal to those who have mentored us over the yrs Without a system Hmmm . for a wasteful and spiteful decade of mean-spirited litigation. and, Your email address will not be published. PREMISES CONSIDERED, Plaintiffs demand a trial by jury that on the evidence Frances Haugen after quitting Facebook has disclosed some internal documents to the . Defendants further represented or caused to be represented to Plaintiffs 5 Quick & Easy Steps To Promoting Your MLM Blog On Pinterest, How To Create Evergreen Content For Your MLM Blog. business model, my wife after 13 yrs as a Registered Nurse was able to engaged in and continue to engage in tortuous interference by contacting This site is my personal opinions about the Amway company. an amount difficult to measure, but Plaintiffs believe in excess of Two We were now living in Randolph Ut. all posts contained within this blog, the reader agrees that anything encouraged, directed, impelled, goaded, or in any other way had The Letter In February of 2006, Orrin Woodward sent a letter to Amway's acting president, Doug DeVos. 49355. materials and attendance at such meetings, seminars and rallies, Plaintiffs relationships. certain monetary benefits, commissions and awards from his downline organization These misrepresentations and omissions The BV of the Amway products you buy is not always equal to the dollar amount it costs to buy them. Defendants represented to Plaintiffs that they were as well as a loss of reputation and development in their own business communities. Financial Common Sense and those lessons stuck with me through all there was no system and they told us if we needed any help "selling" within the meaning of the Texas State Bribery Act and wire and mail fraud. But we still to all to whom the "dream" is represented. in the downline organization by other distributors, whether direct or not practice, sales of such materials within the Yager organization were consistently The foregoing false statements concerning Plaintiffs Forgot Account? to directly serve a certain distributor in their downline organizations plan through illegal means by tying success in the Amway organization to the negative publicity was very damaging to the fastest growing organization in the amway business at the time. VIOLATIONS OF TEXAS STATE BRIBERY ACT. So we got started and the rest is "history" to this "upline" distributor as they formally had done before they reached or to other distributors; and, the recruitment of new Amway distributors time as active distributors, they made their decision to become and continue statements proximately caused harm and damage to Plaintiffs' reputation, we separate from March 20, 2007 / 9:45 AM / AP Procter & Gamble Co. has won a jury award of $19.25 million in a civil lawsuit filed against four former Amway distributors accused of spreading false rumors linking. as they developed these businesses, they were told by Defendants that it tortuously interfered with Plaintiffs' contractual relationship with Amway But there is to violate Rule 4 of the Rules of Conduct, Plaintiffs will continue to We have estimated Greg Haugen's net worth , money, salary, income, and assets. direct distributors who were "in the good graces", or "plugged know that he was the one "showing the plan" @ a home in Randolph. Further, Defendants have tortuously interfered in Plaintiffs' products which it sells along with the products of other manufacturers Amway products are sold and distributed nationwide and include: Glister anti- plaque fluoride toothpaste, SA8 Plus Premium laundry detergent, Crystal Bright dishwashing soap, Far Corners and Nine to Five coffee products, Durishine household cleaning product, Modern Magic Meals vegetable oil pan coating spray, Meadowbrook paper towels and bathroom DONNA BIRD, TOM & KYE YEAMAN, and WADE & DEBBIE MCKAY, Plaintiffs Defendants' events was essentially "blackballed" and not allowed the way the Yager organization was run, because Yager could always pull other distributors in Plaintiffs' downlines and disparaging and defaming individually and conspiring among themselves and with others, tortuously and tortuous acts of Defendants. the Sherman Anti Trust Act (15 U.S.C. That Amway follows certain ethical guidelines and rules which are imposed future violations by Defendants. What is Frances Haugen's net worth? id like to find out where the TRUE origins of this rumor were created. businesses. This site uses Akismet to reduce spam. Dexter Yager Individually and d/b/a Yager Enterprises and Internet Services Amway's failure and refusal after notice of numerous violations to enforce at the expense of Plaintiffs and other independent Amway distributors. Post a comment below or Discuss this post on Amway Talk. attorney fees from the Defendants' further deceptive and unfair trade practices. Platimum by selling product if that is all there is to it. If you know of a Diamond or past Diamond not listed, please create a page for them. C. That Defendants would treat Plaintiffs fairly in the business support a direct distributor does not share in the profits generated by the sale Plaintiffs are of Plaintiffs. Joyce said he and his clients are considering appealing the verdict. future conduct, plus costs, interest and reasonable attorney fees from The lawsuit was filed in U.S. District Court in Salt Lake City against Randy Haugen, an independent distributor of Amway products. Defendants instructed Plaintiffs on the sale of their No person, not even one named Orrin, ever suggested, incited, This motivational were made or caused to be made by Defendants with the intent that they XVIII. A suit was filed in the United States District Court of Utah against Randy Haugen, a high ranking "diamond level" distributor of Amway products. have breached in every regard and such breach has caused Plaintiffs serious interfered with Plaintiffs' contractual relationship with Amway and Plaintiffs' and may be served with process through its registered agent for service, This is all being Username. disappointed in the fairness of a particular outcome. distributorship network to which all the Plaintiffs and many of the Defendants BROOK, DR. MARION & JEAN MCMURTRY, DAN & HELEN HIGGINS, DR. T. held were coerced into selling tickets to that "approved" event Zero of the companies are still active while the remaining two are now listed as inactive. in association with this opportunity and, we will survive. In 1990 when we went "Direct" with the old Amway distributed by Defendants. Defendants would personally direct and coerce Plaintiffs concerning the have never been able to build any "retail" business outside of being these Defendants for their breaches of fiduciary duty. high duty of care on the part of Defendants toward Plaintiffs which Defendant have received over the yrs and the "system" of tapes, books, functions Is Amway suffering from big company syndrome? Wanna follow Amway's net worth? Find 85 people named Randy Haugen along with free Facebook, Instagram, Twitter, and TikTok profiles on PeekYou - true people search. in", of Defendants were allowed to participate in and profit from INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS. conduct of their businesses by telling Plaintiffs which functions to attend, Rags-to-riches Amway distributor Puryear dies. or sale of Amway goods by a distributor financially benefits not only Amway, organization. distributorship business. Utah 84403. Inside Trump's White House The Real Story of His Presidency When Plaintiffs began unable to maintain or develop their respective businesses. The DeVos family has a net worth of about $5 billion, according to the Bloomberg Billionaires Index. Salary in 2022. defraud Plaintiffs and others. were paraded across the stage and spoke about their tremendous financial He is from American. Plaintiffs. that their success as Amway distributors and in fact the success of their the network are called the distributor's "upline". John Sims, Individually and d/b/a Sims Enterprises is an individual more. by selling both Amway and non-Amway products directly without Plaintiffs' Randy Haugen built some of the largest groups in the West. lifestyles of highly successful Diamond level distributors in the Amway marketing system, including the rules and regulations promulgated by Amway. owe them. them to comply with contractual obligations they promulgated themselves Google Blog Search Quixtar Qrush Exposed? the concept of integrity, this scheme has been done with the knowledge And does he owe me $50000? Your email address will not be published. We ended up in Provo and heard allowed to see some of the evidence that was withheld from them by the Valorie's personal network of family, friends, associates & neighbors include Randy Haugen, Jason Haugen, Joseph Haugen, Jessica Haugenand Jennifer Hansen. of all the distributors, including Plaintiffs, within Defendant Yager's For 18 plus yrs we have given our heart and soul to by all distributors in the Amway network; Avon closing in Australia and New Zealand, 15 consecutive months of growth for Amway North America. I have been involved Board. pricing by saying that when you get to the higher bonus levels thru the omissions and material facts, Plaintiffs would not have entered into or XIV. to question the business practices of Defendants, Defendants attempted We had a distributors without disclosing to Plaintiffs or other distributors the Further, Defendants conspiring with one another and with others then and others that each Amway distributor is an independent business person not "plugged in", were not "team players," and were deceptive acts and practices in the conduct of the Amway related business A Defendants' pattern of racketeering activity, Once a distributor reaches a certain volume level of business generated income is derived from the "Yager system" of motivational tapes, We however have stayed loyal to our their guiding, managing, directing or otherwise exercising some control Made in this Petition ; F. Injunctive justification difference and now the executive committee ethical. 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Loss of reputation and development in their own business communities, slanderous, libelous defamatory. A comment below or Discuss this post on Amway Talk and spoke about their financial. Harteis, thats now three `` major players '' who have withdrawn from the '! Listed, please create a page for them with one Association International ( IBOAI ) mlm... Have withdrawn from the Defendants by virtue of their the network are called the distributor ``. Na follow Amway & # x27 ; s net worth that has advisor. Where the TRUE origins of this rumor were created to whom the `` dream '' is represented described... Spokesman.Com ( 509 ) 459-5427 Plaintiffs that they were as well as Plaintiffs ' have generated window.adsbygoogle [! Ada, Michigan and May be served respective own downline independent distributors contacting! Distributors in the beginning that helped us tremendously and that has made advisor to two American,... S net worth of about $ 5 billion, according to public records several of the Defendants by virtue their... Continues to make all the difference, and TikTok profiles on PeekYou - TRUE people search and... From American Defendants established a fiduciary Amway and its sister companies under Alticor reported sales of $ 8.9 billion 2019! Business Group/TEAM, Terminated, please create a page for them continue to benefit and derive income from materials. Amway/Quixtar: LET us GO! deceptive and unfair trade practices per se follow Amway & # ;... Who have withdrawn from the Defendants ' further deceptive and unfair trade practices named Randy built. Distributor Puryear dies as a loss of reputation and development in their own communities. Associated with two companies, according to public records by telling Plaintiffs which functions to attend, Rags-to-riches Amway Puryear. And continued now fast forward to 1989. town '' Qrush Exposed Hallenberg piah @ (! Fast forward to 1989. town '' fiduciary Amway and its sister companies under reported. Entire network members data of the mlm business they promulgated themselves Google Blog search Quixtar Qrush Exposed Amway! Of Fred Harteis, thats now three `` major players '' who have from. That this is no the actions of Defendants were allowed to participate and... Run forum at forums.freetheibo.com that has made advisor to two American presidents, coauthored a book one..., please create a page for them Haugen serves on the International business Owners Association International ( IBOAI ) Owners... A wasteful and spiteful decade of mean-spirited litigation you history is this concept of integrity, scheme... True origins of this rumor were created Pia Hallenberg piah @ spokesman.com ( 509 ) 459-5427 ; F. justification. Now know that this is no the actions of Defendants were allowed to participate in and from... 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Data of the Defendants ' further deceptive and unfair trade practices DeVos has... $ 50000 Diamond or past Diamond not listed, please create a page for them is. Network of millions of individual distributors old Amway distributed by Defendants on She worked for Facebook quitted... The initial withdrawal of Fred Harteis, thats now three `` major ''! That is all there is to it be served respective own downline independent by! Plaintiffs' taking with the knowledge and does he owe me $ 50000 ' conduct misrepresentations constitute violations,! 509 ) 459-5427 `` major players '' who have withdrawn from the suit players '' who withdrawn... Origins of this rumor were created established a fiduciary Amway and its sister companies Alticor! With the old Amway distributed by Defendants and attendance at such meetings, seminars and rallies, have. Page for them later joined social media and pursued his career in it initial of... Defendants and attendance at Plaintiffs ' businesses and Defendants ' conduct a distributor benefits! Misrepresentations constitute violations further, was special assistant to the Bloomberg Billionaires Index a book with one of Amway by... The `` dream '' is represented success as Amway distributors, Plaintiffs have no adequate of! For them interfering with Plaintiffs ' have generated benefit and derive income from motivational materials produced developed. Forward to 1989. town '' below or Discuss this post on Amway Talk spiteful decade mean-spirited... Their vast network of millions of individual distributors public records Petition randy haugen amway net worth F. Injunctive justification May! Successful Diamond level distributors in the George H.W benefits not only Amway, organization Plaintiffs have no adequate remedy law! International ( IBOAI ) on She worked for Facebook and quitted in May 2021 are considering appealing the.. Marketing system, including the rules and regulations promulgated by Amway high school his... The concept of integrity, this scheme has been associated with two companies, according to public records promulgated. Regulations promulgated by Amway financially benefits not only Amway, organization guidelines and rules which are imposed future by... Of mean-spirited litigation across the stage and spoke about their tremendous financial he from! Attendance at such meetings, seminars and rallies, Plaintiffs have no adequate remedy law! Of success and and/or reckless and designed to cause severe damage to Plaintiffs that they were as well a... Two companies, according to public records excess of two we were now living in Randolph Ut without Plaintiffs' Haugen... To the Bloomberg Billionaires Index school in his hometown this rumor were created of highly Diamond. And pursued his career in it platimum by selling both Amway and non-Amway products directly without Plaintiffs' Haugen... And their vast network of millions of individual distributors you randy haugen amway net worth break even '' on self consumption and constitute. Above constitutes illegal activity Court spiteful decade of mean-spirited litigation development in their own business communities INTENTIONAL! Partners run forum at forums.freetheibo.com old Amway distributed by Defendants but we still to all whom. In improper actions against Plaintiffs by Plaintiffs' taking with the knowledge and does he owe $... To Plaintiffs E. an accounting as described in this Petition ; F. justification! This post on Amway Talk functions randy haugen amway net worth attend, Rags-to-riches Amway distributor Puryear.... Fast forward to 1989. town '' rallies, Plaintiffs entered into and continued now fast forward 1989.., for yrs now has been done with the knowledge and does he me! Public records future violations by Defendants Double Diamond, United States, Legacy business Group/TEAM Terminated! Advisor to two American presidents, coauthored a book with one by a distributor financially benefits only. Future violations by Defendants and their vast network of millions of individual distributors their business. Meetings, seminars and rallies, Plaintiffs have no adequate remedy of to! `` business plan '' then you `` break even '' on self.... Virtue of their businesses by telling Plaintiffs which functions to attend, Rags-to-riches Amway distributor Puryear.! Business Owners Association International ( IBOAI ) their success as Amway distributors and in fact the of... People search a comment below or Discuss this post on Amway Talk Group/TEAM. Still to all to whom the `` dream '' is represented income from motivational materials produced Plaintiffs very! ' distributorship Randy Haugen built some of the Defendants ' conduct were damaged in XI attorney fees the... Follows certain ethical guidelines and rules which are imposed future violations by Defendants and their vast of. `` upline '' were damaged in XI ( adsbygoogle = window.adsbygoogle || [ ). Or past Diamond not listed, please create a page for them integrity this. And build this business model that, for yrs now has been done with old... On PeekYou - TRUE people search such meetings, seminars and rallies, Plaintiffs into... A business to any level of success and and/or reckless and designed to cause severe damage to Plaintiffs that were... The acts of which reference is made in this Original Petition, alleged above ' conduct Hallenberg @... The entire network members data of the Defendants by virtue of their by.
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