Jeunesse co-founder Ogale Erandal Ray, aka Randy Ray, has filed a lawsuit alleging tens of tens of millions of {dollars} in theft.
Ogale’s sixty-one web page lawsuit was filed in Seminole County, Florida on October 1st, 2024.
The thirty-seven named defendants in Ray’s go well with are:
- Kevin Giguere (prime Jeunesse distributor turned govt, presently Chairman of Jeunesse)
- Bailey Giguere
- Austin Giguere
- B&G Group Inc. (Florida)
- Huge Nation Acres LLC (Florida)
- VT3 LLC (Florida)
- Wager Excessive LLC (Florida)
- KNC Enterprises INC. (Florida)
- KALB Enterprises Worldwide (Florida)
- Group Future LLC (Florida)
- Gato Grande LLC (Florida)
- Pamela McKinney and Pamela R. Mckinney CPA
- Brook McKinney
- Courtney Prepare dinner
- William Robert Dawson
- Carol Dawson
- CD Asset Holdings LLC (Florida)
- Barbara Dawson
- Geri Dorman
- Debbie Kurley
- Jennifer Lu Naciri
- Taylor Norvell
- Joseline Buscampell
- United Sturdy LLC (Florida)
- Christopher Munizzi
- K2 Quest LLC (Florida)
- Canna Cope Wellness LLC (Florida)
- Covenant House Safety LLC (Florida)
- Hollie Mancini
- Youth Inside Out LLC (Florida)
- Ruth Northvell
- Ricketts Administration LLC (Florida)
- Dolan Ricketts
- Brenda Ricketts
- Foubi Cleansing Providers LLC (Florida)
- Myrna Nash and
- Allebas AES LLC (Florida)
Earlier than we get into Ray’s claims, I wish to be aware that Ray and Wendy Lewis (proper) bought Jeunesse off to LaCore Enterprises in January 2023.
Nothing a lot occurred with the enterprise and Jeunesse was once more bought to Velovita in October 2024. An up to date BehindMLM evaluation of Jeunesse below VeloVita’s possession is pending.
I additionally wish to be aware essentially the most outstanding defendant Ray has sued is Kevin Giguere. Giguere was a prime Jeunesse distributor earlier than transitioning to the chief aspect of issues.
As on the time of publication, Giguere is believed to nonetheless be Chairman of Jeunesse.
In a nutshell Ray, citing himself as an “83-year outdated profitable entrepreneur”, alleges the above defendants “stole tens of millions of {dollars}” from him.
As a part of this scheme, Ray singles out Pamela McKinney and her CPA firm, Kevin Giguere and Robert Dawson because the “Kingpin Defendants”.
This motion seeks the restoration of tens of millions of {dollars} that the Kingpin Defendants stole from Mr. Ray and laundered into their very own pockets (or these of their shut households, pals, or enterprise associates).
“Operational Defendants” and “Community Defendants” are additionally outlined.
Mentioned Naciri, Taylor Norvell, Ashley Frost and Joseline Buscampbell make up the Operational Defendants.
The Community Defendants basically make up the remainder of the named defendants.
To perform their scheme to steal Mr. Ray’s cash, the Kingpin and Operational Defendants used straw corporations and people—the Community Defendants— to appear like precise Jeunesse Impartial Distributors.
In actuality, they have been sham entities utilized by the Kingpin and Operational Defendants to launder cash taken from Mr. Ray.
The Community defendants both offered no reputable companies to Jeunesse in any respect, or solely essentially the most minimal of companies, and, as an alternative have been utilized by the Kingpin Defendants to funnel the tens of millions of {dollars} extracted from Mr. Ray all through a number of years.
The Community Defendants included a number of sham corporations (arrange or repurposed by Mrs. McKinney), in addition to relations and/or confidants of the Kingpin Defendants, comparable to Mrs. McKinney’s husband and kids, Mr. Giguere’s youngsters, and Mr. Dawson’s mom.
Ray states that after struggling a stroke in 2018, he “took a backseat to the day-to-day actions of Jeunesse”. That is when the laundering of Ray’s cash is alleged to have begun.
The Kingpin Defendants inserted themselves into Mr. Ray’s life and into positions of belief and confidence to empty Mr. Ray of his private wealth.
Mr. Ray’s private accountant (Mrs. McKinney/McKinney CPA), trusted enterprise advisors (Mr. Giguere and Mr. Dawson), and authorized counsel and trustee (Mr. Dawson).
Mr. Giguere was so intimately concerned in Mr. Ray’s life that he coordinated the acquisition of Christmas presents for Mr. Ray’s household and the acquisition of Mr. Ray’s automobiles.
To maintain management of Mr. Ray as Mr. Ray aged, Mr. Giguere bought a house in the identical neighborhood as Mr. Ray and would usually, and unexpectedly, drop in on Mr. Ray at his house.
With their positions of belief, Mr. Ray appeared to, and relied on the Kingpin Defendants to information him in just about each facet of his monetary life.
The Kingpin Defendants abused Mr. Ray’s belief, by, most egregiously, deceiving Mr. Ray about his publicity to prison legal responsibility if he did not personally, and instantly, infuse Jeunesse with money to cowl its payroll.
Counting on their representations, tens of tens of millions of {dollars} have been infused into Jeunesse.
In actuality, this supposed want for payroll was a ploy by the Kingpin Defendants to launder the cash via Jeunesse after which finally steal it for themselves and their co-conspirators.
For instance, in 2022 alone, the Kingpin Defendants effectuated the switch of not less than $35,000,000 out of Mr. Ray’s accounts and into Jeunesse.
As additional defined beneath, the Kingpin Defendants additionally focused, and liquidated, Mr. Ray’s different private property in assist of their scheme.
The alleged monetary misconduct came about via a “spider net of corporations” arrange by Giguere and McKinney.
Ray alleges the Kingpin Defendants labored instantly with Jeunesse executives as a part of a conspiracy to defraud him.
The Kingpin Defendants recruited and conspired with key Jeunesse workers to change company paperwork and information to be able to allocate these funds instantly out of Jeunesse and into the palms of the Community Defendants.
The cash allegedly stolen from Ray is claimed to have primarily benefited the Kingpin Defendants.
In 2022 … Mrs. McKinney was added onto Mr. Ray’s PNC Financial institution accounts so she may deal with all of Mr. Ray’s direct residing bills.
This gave Mrs. McKinney full capability to maneuver and switch cash out of Mr. Ray’s financial institution accounts – a capability she abused again and again to maneuver tens of millions of {dollars} out of Mr. Ray’s accounts with out his permission or below false pretenses.
This cash ultimately ended up laundered to the Kingpin Defendants, together with Mrs. McKinney’s, her husband’s and her youngsters’s, personal pockets.
The third Kingpin Defendant, William Robert “Rob” Dawson, is alleged to have been in enterprise with Ray since “not less than 2005”.
Mr. Dawson can be a co-founder/partial proprietor of Jeunesse and served as Jeunesse’s Chief Authorized Officer since its inception and till 2020.
Along with serving as Jeunesse’s Chief Authorized Officer, Mr. Dawson additionally oversaw Jeunesse’s funds (together with Jeunesse’s Chief Monetary Officer Ryan Ogden) and would monitor money move, home/worldwide financial institution accounts, working accounts, depository accounts, and service provider processing.
Mr. Dawson is a licensed legal professional in Nebraska who additionally owns a controlling curiosity in Pathway Financial institution, a group financial institution positioned in Cairo, Nebraska, that he used as a part of his scheme.
In January 2023, Pathway Financial institution was included in Florida, with its principal handle positioned at Mr. Dawson’s private residence in Longwood, Florida.
Ray accuses Dawson’s relations of profiting via bogus Jeunesse distributor positions.
Ray additional accuses Dawson of “providing [him] a supply of cash … in alternate for closely discounted worth on investments”, and “promote[ing his] curiosity in industrial property … for a steep low cost and below false pretenses”.
Mr. Dawson additionally misled Mr. Ray to buy Mr. Dawson’s curiosity in Jeunesse for a lot beneath its precise [worth].
Relations of Ray’s are additionally implicated. Geri Dorman and Debbie Kurley are nieces of Wendy Williams, spouse of Ray and a Jeunesse co-founder.
Together with Jennifer Luce, Dorman and Kurley are accused of “supervising and directing” Mentioned Naciri, Taylor Norvell, Ashley Frost and Joseline Buscampbell (the Operational Defendants), to control Jeunesse payouts (the “Level Scheme”).
The Kingpin Defendants applied the Level Scheme by recruiting and directing members of the Operational Defendants to fraudulently add tens of millions of unearned factors onto sham accounts—the Community Defendants’ Jeunesse accounts.
This resulted within the Community Defendants being paid commissions that represented exorbitant multiples of the quantity of “gross sales” they recorded.
For instance, Community Defendant Youth Inside Out Inc., whose company id was shielded by username “Moxie1720”, recorded complete gross sales of roughly $10,000 in 2022 however acquired practically $250,000 in commissions throughout the identical interval.
In actuality, lots of the Community Defendants had no precise gross sales in any respect.
Ray cites defendant Jennifer Luce is cited as an integral a part of the alleged Level Scheme.
Jennifer Luce was Jeunesse’s Director of Human Sources and a long-time, trusted worker of Jeunesse.
Jennifer Luce additionally participated within the scheme by including unearned factors to the Community Defendants and was compensated by Kingpin Defendant Kevin Giguere instantly for doing so.
Jennifer Luce additionally assisted the Kingpin Defendants’ efforts to keep away from authorized legal responsibility for his or her Level Scheme as soon as the Kingpin Defendants believed the Level Scheme was uncovered by notarizing sham releases for improper funds to the Community Defendants.
One instance of Ray’s alleged Jeunesse nepotism is Kevin Giguere’s daughter Bailey Giguere.
Between November 2019 and September 2022, Geri Dorman (recognized as “geri” in Jeunesse’s system) added 56,000,000 complete factors to the Jeunesse username “ABKG.”
The payee of the ABKG account was Defendant Bailey Giguere – the daughter or Kevin Giguere, who was instantly paid nearly $2,000,000 to a Suncoast Checking account throughout the identical time interval.
Upon info and consider, Bailey Giguere by no means bought any Jeunesse merchandise and was by no means a Jeunesse Impartial Distributor.
To assist receiving $2,000,000 in fee funds, she would have needed to be accountable for tens of tens of millions of {dollars} in Jeunesse product gross sales.
Particular to the Kingpin Defendants threatening Ray with imprisonment if he didn’t fund Jeunesse’s payroll;
On a number of events, the Kingpin Defendants alerted Mr. Ray of the speedy and urgent want for an infusion of money into Jeunesse.
The Kingpin Defendants, Mr. Ray’s most trusted advisors, justified the necessity by explaining that Jeunesse didn’t have ample funds to cowl its payroll obligations.
Mr. Dawson, a skilled and licensed legal professional, went so far as telling Mr. Ray that if Jeunesse’s payroll was not lined, Mr. Ray could be arrested, criminally charged, and despatched to jail.
All through their relationship, Mr. Dawson advised a number of means by which Mr. Ray may shield himself, together with buying a residence in, and acquiring citizenship in, the nation of Cyprus – a rustic Mr. Dawson suggested Mr. Ray had no extradition treaty with america.
Mr. Dawson informed Mr. Ray he had bought property in Cyprus for that very same purpose.
Mr. Giguere, on June 23, echoed the payroll imprisonment menace.
To Mr. Ray, an aged Floridian, any potential imprisonment time period meant he would seemingly spend the remainder of his life behind bars, a scenario the Kingpin Defendants knew would induce Mr. Ray to behave upon their recommendation.
However like all “good” advisors, the Kingpin Defendants offered Mr. Ray with a “resolution” that may cowl Jeunesse’s payroll and relieve Mr. Ray from potential jail time.
The answer was easy: Mr. Ray would promote to the Kingpin Defendants his shares in a number of funding funds, that have been no readily dispensable in the marketplace, for cents on the greenback.
The Kingpin Defendants particularly focused Mr. Ray’s illiquid funding funds, coupled with the Payroll Imprisonment Risk, to induce Mr. Ray to promote the funds nicely beneath market worth.
In flip, the Kingpin Defendants would deal with liquidating the shares and infusing Jeunesse with the ill-gotten proceeds.
Ray alleges
- $2.5 million was liquidated from seven partnership funding funds (Ray alleges his capital within the funds “exceeded $3.8 million)
- $2.5 million was liquidated from one other 5 partnership funding funds (over $3 million in alleged capital)
Mr. Ray by no means noticed a single cent of the cash owed to him by Mr. Dawson below both switch; quite, Mr. Dawson paid that cash over to Jeunesse figuring out the proceeds could be laundered via Jeunesse and paid out to the Kingpin Defendants and Community Defendants (together with his personal sham entity) via the Level Scheme.
- $700,000 was liquidated from a Charles Schwab margin account
- “not less than $35 million” was transferred out of PNC Financial institution accounts
Ray alleges imprisonment threats have been additional used to coerce him into promoting his personal Challenger jet to “improve to a much bigger mannequin (the “G550 Jet”).”
The Kingpin Defendants satisfied Mr. Ray that upgrading the Challenger Jet would enable for a better chartering capability and extra earnings.
The Kingpin Defendants additionally knowledgeable Mr. Ray that the proceeds of the Jet sale might be used to cowl the acquisition value of the G550 Jet.
Nonetheless, whereas Mr. Ray sought a purchaser for the Challenger Jet, Mr. Dawson satisfied Mr. Ray to buy the alternative G550 Jet via a mortgage from his Nebraska-based financial institution, Pathway Financial institution.
To effectuate the roughly $21,000,000 buy of the G550 Jet, Mr. Dawson precipitated a number of loans for tens of millions of {dollars} to be issued by Pathway Financial institution.
Furthermore, the three loans have been collateralized by Mr. Ray’s actual property.
In April 2022, the Challenger Jet was bought for roughly $23,000,000.
Nonetheless, the proceeds of the Challenger Jet sale weren’t used to fulfill the three Pathway Financial institution loans.
Somewhat, upon info and perception, the proceeds of the Jet sale have been diverted into Jeunesse by the Kingpin Defendants to proceed funding their Level Scheme and launder the cash and steal it for themselves.
Ray goes on to assert he was unable to afford upkeep on the bought G550, and bought the jet lower than a 12 months later for a “$6 million loss from the acquisition value”.
On this course of, Mr. Ray was saddled with tens of millions of {dollars} of fraudulently induced debt.
In one other alleged scheme Dawson is accused of “capitalizing on the information” Ray was paying tens of millions to cowl Jeunesse’s payroll, to persuade him to promote his curiosity within the holding firm that owned the land Jeunesse’s headquarters was constructed on.
Ray alleges his curiosity was bought for “considerably much less” than it was valued at.
Dawson is alleged to have extracted one other $60 million out of Ray by promoting him his Jeunesse possession shares in 2020. Ray claims the sale was negotiated on “misrepresentations”.
Mr. Dawson falsely represented to Mr. Ray that Mr. Dawson’s shares have been price roughly $60,000,000.00.
This was false, and Mr. Dawson knew, or ought to have identified, it was false, as he was Jeunesse’s Chief Authorized Officer and accountable for Jeunesse’ funds.
The Level Scheme devalued the corporate and despatched Jeunesse on a downward spiral. Mr. Dawson did not disclose the Level Scheme to Mr. Ray, and as an alternative misrepresented the worth of Jeunesse to induce Mr. Ray to enter into the transaction.
Ray claims all the alleged conduct got here to mild after he appointed his grandson, Phillip Wallace, as Energy of Legal professional in 2022.
Within the latter half of 2022, exhausted from the fraudulently induced multi-million greenback infusions, Mr. Ray determined to promote his curiosity in Jeunesse.
Throughout this era, Mr. Wallace started discovering the suspicious addition of factors on the Community Defendants’ Factors Log.
As Mr. Wallace started asking questions, the Defendants grew to become conscious their Level Scheme was, or would quickly be, uncovered.
In a matter of mere days, Mr. Giguere mobilized and secured for himself and his co-conspirators, what he believed, have been reputable and enforceable releases from Jeunesse – and don’t purport to be releases by Mr. Ray – from their scheme to
steal cash.
Strikingly, the releases additionally embrace lots of the Community Defendants herein and function extra proof of the Kingpin Defendant’s and their co-conspirators’ involvement within the Level Scheme.
After securing his launch, which for some purpose Ray’s spouse Wendy Lewis signed off on, Giguere despatched Wallace an e-mail.
Having allegedly misappropriated tens of millions and obtained a launch, Giguere informed Wallace he needed to “get this behind us earlier than this blows up [into] one thing that no one needs” (click on to enlarge beneath).
Within the e-mail Giguere seems to implicate a number of extra names as being a part of Ray’s alleged Factors Scheme.
Begin with a 5 greenback cycle that value the corporate $8.9 million a 12 months that 44 persons are getting.
As soon as once more you’re gonna inform me you don’t know something about it or the ten maxed out positions from Damien Eric fear Cliff Walker Teresa Gregory and 1000 different individuals and 6000 pretend positions that Doug whitehead attempt to get you to terminate for 2 years.
I’m not 100% positive on who “Damien” is however I consider “Eric fear” refers to disgraced MLM coach Eric Worre.
Cliff Walker and Theresa Gregory are/have been Jeunesse prime earners. Gregory was sentenced to 31 months in jail for tax fraud in 2021.
Wallace continued to research and, working with Jeunesse’s compliance crew, suspended recognized Community Defendant “sham accounts” in direction of the tip of 2022.
Retaliation from Giguere was swift.
Inside hours of the suspension, Kingpin Defendant Mr. Giguere ordered the suspended accounts to be reinstated.
Then, that following Monday, Jeunesse’s total compliance crew was terminated.
Whereas this was happening, Debbie Kurley and the opposite Operational Defendants are alleged to have been “deleting the factors” they’d added to the sham accounts.
Internally, nothing extra would come of the alleged misconduct.
Ray in the meantime went on to promote his curiosity in Jeunesse to LaCore Enterprises “for a loss”.
The sale to the Purchaser required Mr. Ray to infuse Jeunesse with a ultimate fee of $5,000,000.00.
Ray alleges Jeunesse’s sale to LaCore Enterprises was “the ultimate stage of his plan … to usurp Jeunesse”.
In lower than a 12 months after the sale, the brand new “proprietor” of Jeunesse has been faraway from company information and changed with Mr. Giguere, the mastermind of the scheme.
In actual fact, a December 15, 2023 modification to Jeunesse’s public company information eliminated the Purchaser and added Kingpin Defendants Kevin Giguere and Pamela McKinney as Jeunesse Administrators.
Neither LaCore Enterprises or proprietor Terry LaCore (proper) are named defendants.
It’s unclear whether or not LaCore had information of the alleged misconduct.
Throughout fifteen counts, Ray has accused the defendants of:
- fraudulent inducement (Kingpin Defendants)
- tortious conspiracy (Kingpin Defendants)
- conspiracy to commit fraudulent inducement (all defendants)
- aiding and abetting fraudulent inducement (all defendants)
- negligent misrepresentation (Kingpin Defendants)
- breach of fiduciary responsibility (Kingpin Defendants)
- conspiracy to commit breach of fiduciary responsibility (kingpin defendants)
- skilled malpractice (Pamela McKinney and Pamela R. McKinney CPA)
- civil theft (Kingpin Defendants nad Debbie Kurley and Geri Dorman)
- conspiracy to commit civil theft (Kingpin Defendants and Debbie Kurley and Geri Dorman)
- conversion (all defendants)
- conspiracy to commit conversion (all defendants)
- unjust enrichment (all defendants)
- fraudulent inducement (Robert Dawson)
Within the two months since Ray filed his Grievance, 100 and thirty-four docket entries have been generated. As a result of sheer quantity of defendants, many of the entries are administrative in nature.
- on November fifteenth the court docket clerk recorded Entries of Default in opposition to Dolan Ricketts, Brenda Ricketts and Ricketts Administration LLC
- over 100 pages of subpoenas to numerous non-parties have been filed by Ray
Keep tuned for updates as BehindMLM continues to trace the case.