Dating back to mid 2025, Ogale Erandal Ray (aka Randy Ray), has been trying to get a court order holding defendant Kevin Giguere in contempt.

Now in an Amended Motion for Sanctions filed on March 30th, Ray alleges a web of lies supported by a former defendant and Giguere co-conspirator.

Ray filed suit in 2024 and accuses Giguere and several co-conspirators of cheating him out of tens of millions.

In an Amended Complaint filed in February 2026, Ray added allegations of an “out of market” scheme predating Giguere’s money laundering scheme.

Ray also claims Giguere orchestrated both schemes by manipulating his wife Wendy Lewis, who suffers from dementia.

Proceedings are ongoing. On June 25th, 2024, Ray filed a “show cause” motion alleging Giguere had threatened a witness with murder.

The court ordered Giguere’s lawyer to instruct him “not to communicate with co-defendants or witnesses”, as it pertained to Ray’s case.

On December 29th, 2025, Ray filed a second contempt motion, this time accusing Giguere of tainting his son and daughter-in-law.

Four months later the court has yet to rule on the motion. This brings us to Ray’s March 30th amended motion, which provides additional context to the allegations.

In his second contempt motion, Ray alleged Giguere tainted his son and daughter-in-law by instructing them on how to evade service.

Ray sought to depose Austin and Dakota Giguere after learning they had “received over a million dollars” through the conspiracy detailed in Ray’s Complaint.

Austin and Dakota were eventually deposed, with disclosure of Kevin Giguere’s tampering forming the basis of Ray’s second contempt motion.

As alleged by Ray in his amended contempt motion (technically the third filing in the Kevin Giguere contempt series);

Kevin Giguere’s instructions to evade service raised the question of why it was so important for Kevin Giguere to try to interfere with these depositions:

The answer is that he laundered millions of dollars in Austin and Dakota’s names for his and their benefit and he wanted to prevent them from testifying truthfully about this.

Ray’s contempt allegation against Kevin Giguere extends not only to evasion of service, but to the answers Austin and Dakota gave during their respective depositions.

He was ultimately unsuccessful in preventing the depositions, and so instead, at their depositions, Austin Giguere and Dakota Giguere gave flippant answers denying any knowledge of wrongdoing and of the millions of dollars that moved in their names as part of the money laundering conspiracy.

Dakota Giguere even denied filing tax returns and denied receiving money from Jeunesse during the years at issue.

Dakota Giguere said all this despite being shown an example of a 1099 at her deposition, issued in her name for $337,890.10, and other 1099 examples with her as the issuing party to one of her father-in-law, Mr. Giguere’s companies for $129,485.00 and $713,913.19.

How did this money move then? How did Dakota Giguere’s tax returns get filed? How were the various 1099s issued and filed with the IRS?

As Austin Giguere recounted, if anyone had knowledge, it was not his father Kevin Giguere, but rather their bookkeeper Pamela McKinney.

What makes this claim particularly strange is Austin and Dakota both knew McKinney had made an appearance at their depositions and was watching remotely.

Sometime during Austin and Dakota Giguere’s depositions or thereafter, McKinney realized she’s unknowingly been appointed “the designated fall person for [Kevin] Giguere’s money laundering scheme”.

To that end McKinney seems to have carved out a quid pro quo arrangement with Ray. McKinney was a named defendant in Ray’s filed Complaint. Ray moved to voluntarily dismiss McKinney and several family members as defendants on March 24th, 2026.

In return, Ray’s latest allegations against Kevin Giguere are accompanied by an exhibited affidavit from McKinney.

As it pertains to Austin and Dakota Giguere, here is the money side of Kevin Giguere’s conspiracy against Ray, as sworn by McKinney in her affidavit;

Kevin Giguere gave my family distributor positions within the Jeunesse genealogy. We did not have to pay for these positions. Most of us did not fill out paperwork to sign up for these positions.

Kevin did instruct us to send W-9s and our banking information to … Jeunesse.

Kevin said he purchased these positions for me and my family, We did not obtain any distributors in our downlines on our own, and we sold virtually no products.

From these positions, the only quantity of products that we sold was less than 10 individual items for a total of less than $500. After these small sales, we made no additional sales.

Despite this, money would flow to my family on a weekly basis from Jeunesse for the positions that Kevin gave us.

This occurred from 2019 through 2022. Kevin allowed us to keep a set weekly amount of money, and then the remainder of the money would be transferred to Kevin or one of the companies he owns, controls, and/or otherwise maintains.

My family and I prepared 1099s to record the movement of money from my family’s positions to Kevin.

At the time, I raised my suspicions with Kevin about whether he could receive the proceeds from all these positions, but he assured me that this was standard in network marketing and that people at Jeunesse were aware of this.

I raised these concerns with him multiple times, and he would become irritated by my questions and told me it was appropriate and had been approved by Wendy Lewis, who was an owner of Jeunesse at the time.

As a result, I believed these were legitimate expenses requiring 1099s to be sent to the IRS when someone is paid commissions and/or for contract labor.

To explain the justification for the expenses, Kevin said that, for our positions, he was travelling and going to meetings, he was meeting with potential distributors, and he said he obtained new distributors to add to our “downlines” or “legs”.

In short, we were told he was obtaining new distributors for our positions and this is why my family received funds from the positions.

Due to this justification from him for the expenses, we wrote off the money transferred to Kevin as either commission expense or contract labor.

Kevin told my family and I that if we were to go work these positions, ourselves, then we would be able to keep the majority of the money that was flowing in, rather than transferring it to Kevin and deducting it as an expense.

Based on these statements we believed that real work was being done for these positions, and thus real expenses were being incurred.

McKinney goes on to detail amounts received by herself and family:

  • McKinney’s daughter received $459,037 in 2020, of which she kept $14,595 and transferred $444,442 to Kevin Giguere
  • McKinney’s daughter received another $126,034 in 2021, of which she kept $2750 and transferred $123,285 to Kevin Giguere
  • McKinney’s second daughter received $207,273 in 2021, of which she kept $8,704 and transferred $198,569 to Kevin Giguere
  • McKinney’s husband received $303,906 in 2020, of which he kept $8908 and transferred $294,998 to Kevin Giguere
  • McKinney’s husband received another $603,346 in 2021, of which he kept $8600 and transferred $594,746 to Kevin Giguere
  • Pam McKinney received $127,055 in 2020, of which she kept $1600 and transferred $125,455 to Kevin Giguere
  • McKinney’s son-in-law received $28,887 in 2020, of which he kept $8309 and transferred $20,578 to Kevin Giguere
  • McKinney’s son-in-law received another $8960 in 2021, of which he kept “all of it because it was a small amount”
  • McKinney’s daughter’s boyfriend at the time received $75,620 in 2021, of which he kept $7261 and transferred $68,359 to Giguere
  • Summit Quest Inc., a company under McKinney’s control, received $503,640 in 2021, of which it (McKinney) kept $189,697 and transferred $313,942 to Kevin Giguere
  • Summit Quest Inc. received another $351,047 in 2022, of which it (McKinney) kept $282,121 and transferred $68,926 to Kevin Giguere

Being somewhat familiar with MLM, these are obviously promoter positions Giguere has stacked under himself and has tried to mask ownership of.

All up McKinney claims the positions she and her family held received “about 3.57%” of the funds deposited into them. Giguere was the sole recipient of the remaining 96.43%.

McKinney also confirms Wendy Lewis’ role in Giguere’s alleged scheme;

Kevin told me that people at Jeunesse were aware of our positions. I do know that Wendy Lewis was aware of the positions as I was in a meeting when Kevin and Wendy discussed the percentages or dollar amounts that Wendy and her son Scott Lewis would receive for their portion of the positions.

Wendy, specifically, talked about the percentages of money that Kevin would send her for her benefit from the positions.

Wendy Lewis, through a guardianship, and Scott Lewis were added as defendants in Ray’s February 13th Amended Complaint.

I also know that Kevin used many other people besides my family to receive money from Jeunesse and compensate him in the same way.

I am not sure about all the other people as I don’t know how or what his deal was with each person. I just paid who he told me to pay and prepared 1099s as required by IRS law based on expenses that he told me were incurred.

The people that I know that were involved include Kevin’s children Austin and Bailey Giguere, Austin’s wife Dakota Giguere, Kevin’s girlfriend Hollie Mancini, Kevin’s former girlfriend Chantel Lowen, and Chris Munizzi.

Like my family, they would either directly, or through companies they controlled, receive payouts from Jeunesse, keep a small weekly portion as directed by Kevin, and then transfer the rest of the money to Kevin or his companies.

Similarly, I was also asked to create two companies, one for Wendy Lewis and one for her son Scott Lewis, to receive portions of these payouts funneled through Kevin’s companies.

These companies were WL Enterprises LLC and S Lewis Enterprises LLC.

As Giguere’s alleged Jeunesse money laundering empire expanded, his bank became suspicious.

For many of these people and for Kevin and his companies, accounts were maintained at Capital City Bak.

Capital City Bank became concerned about the frequent and large transfers of money from all these people to Kevin and his companies, so Capital City Bank closed all the accounts at their bank and sent letters explaining these account closings.

I spoke to the bank manager on the phone who told me the accounts were being closed due to the bank’s suspicions of money laundering.

In the lead up to Austin and Dakota’s depositions, McKinney alleges;

Prior to the depositions, Kevin told me someone was trying to get service on Dakota so that she would appear for the deposition.

He told me that Austin and Dakota should avoid being served by going on vacation.

I later shared that comment with my lawyer who agreed with Kevin’s comment that Austin and Dakota should go on vacation to avoid service.

On that same phone call with Kevin, Kevin told me that Austin and Dakota were living in Miami and that they could not really afford to live there and that it was expensive. Kevin said he would likely need to buy a condominium for them.

I took this to mean Kevin was going to buy a condominium for Austin and Dakota so that they would testify the way Kevin wanted them to at their depositions. He later did buy this condominium for them at the end of October 2025.

These types of communications were common from Kevin as he had frequently told me and others to try to evade service.

On the depositions themselves, and keeping in mind both Austin and Dakota were under oath;

During Dakota’s deposition, I watched Dakota deny having any knowledge of any money being received in her name from Jeunesse and deny having knowledge of transferring any of this money to Kevin and/or his companies.

What she said is false. More than one million dollars moved from Jeunesse to Dakota for a position that Kevin inserted Dakota into, and ultimately the majority of this money flowed to Kevin and his companies.

I had conversations with Dakota about this position and about this money I had meetings with Kevin and Dakota about this money.

Dakota, like my family, was allowed to keep a small amount of this money in exchange for moving the money to Kevin.

I know this occurred because I was directly involved in communicating with Kevin and Dakota about it, and because I was involved in helping to move the money and record it with 1099s.

Dakota also sent me communications asking me for my help to create a bank account for Dakota at Capital City Bank, so that she could receive this money from Jeunesse. She was also the recipient of one of the letters from Capital City Bank closing her account.

After Dakota received this letter, she used a bank account at Trust Bank, that she had created on her own, to continue receiving money from Jeunesse and to transfer it to Kevin.

Also at the deposition, I watched Dakota deny having filed tax returns during the years in which she received money from Jeunesse and specifically denied signing any tax returns during these years.

This is also false. I know this is false because I prepared her tax returns and sent it to Dakota for her signature before filing those tax returns with the IRS.

Dakota signed these tax returns with her own wet ink signature. I did not sign her tax returns for her.

At the depositions, Austin and Dakota were also both asked, and answered questions, about a company called B&G Team Inc.

Austin and Dakota both denied having any knowledge of B&G Team Inc. receiving money from Jeuensse. This is false.

Austin and Dakota both received money from payments that B&G Team Inc. received for a position that Kevin inserted it into at Jeunesse.

Austin was the President of B&G Team Inc. and his sister Bailey Giguere was the Vice President of B&G Team Inc. Dakota was at times an employee and at times a contractor of B&G Team Inc.

While Austin claimed during his deposition that B&G Team Inc. was only involved in doing landscaping work for Kevin’s personal residence, this is false.

Despite what was said at the depositions, I have never seen any records of B&G Team Inc. receiving money for doing landscaping work for Kevin’s personal residence.

Of the money it received from Jeunesse, a portion was transferred to Kevin or one of his companies.

Austin,Bailey, and Dakota received much of the rest of the money through salaries and retirement benefits funded from the money that B&G Team Inc. received from Jeunesse.

I have firsthand knowledge of this because I was directly involved in helping to move the money and record it with 1099s and W-2s and to ultimately prepare the tax returns for these individuals and for B&G Team Inc.

I did this at Kevin’s direction, and in communications with Austin and Dakota, and with Kevin’s assurances that these were all ordinary practices for network marketing.

Dakota and I emailed discussing her benefits and whether this money should be hers or Kevin’s.

I believed she did not know what money Kevin actually considered to be his versus what he was allowing her to keep.

Either way, she knew she was receiving money and benefits through B&G Team Inc, that originated from funds that came from Jeunesse.

Kevin Giguere also knew McKinney was watching Dakota’s deposition and called her after it.

On December 5, 2025, Kevin called me asked me what I thought of the depositions.

I told Kevin that I was shocked that Dakota and Austin lied about the money they knew they received from Jeunesse and, for Dakota, about her lying about whether she signed tax returns.

I asked Kevin why Austin and Dakota did not tell the truth. Kevin replied to me that Austin and Dakota did not tell the truth because Kevin “told them to keep their mouths shut.”

Giguere allegedly went on to tell McKinney that his lawyer and their lawyers thought Austin and Dakota “did great”.

Shortly thereafter, I shared Kevin’s comments about him telling Austin and Dakota to “keep their mouths shut” to my lawyer.

My lawyer said that keeping their mouths shut is what Austin and Dakota should have done, which I thought was horrible.

At the time McKinney was represented by Steven Kalishman (right) of Kalishman Law. Shortly after sharing the remarks above, McKinney fired Kalishman.

This prompted another call from Giguere;

On February 24, 2026, Kevin called me and told me he heard that I fired my lawyer. I said that was correct, as Kevin had been paying for my lawyer and I no longer trusted that arrangement, especially given what had transpired during the depositions of Dakota and Austin, Kevin then asked me if I had been talking to counsel for Randy Ray.

I felt that he was trying to intimidate me to not cooperate towards resolving this case for my family and myself.

Kevin had previously asked me, after Austin and Dakota’s depositions, whether I would tell the truth if I was ever deposed. I said that I would tell the truth.

I believe this concerned him that I would not lie under oath like he was able to get his son, Austin, and daughter-in-law, Dakota, to do.

Summarising her dealing with Giguere, McKinney states;

In the end, my position working for Kevin and his family was clerical. I was asked to form LLC’s and transfer money that I was assured was legitimate by Kevin in the network marketing world.

Kevin kept me in the dark about many things, and I relied on what he told me.

I transferred money or wrote checks to others per Kevin’s request and prepared tax returns and 1099s as required by IRS tax law. I also made Kevin pay tax on any cash that I knew about.

Again, under the common work practices of multi-level marketing, this appeared to be legitimate to me. Therefore, at the time, I didn’t believe there to be misrepresentations by Kevin Giguere.

Furthermore, my family and I recorded our income on our tax returns and paid income taxes as required by law.

Pending further orders from the court, it remains unclear whether Kevin Giguere will be sanctioned for witness tampering. Ditto whether Austin and Dakota Giguere will face penalties for allegedly lying under oath.

While I’m not accountant, I can’t help but feel this is also probably something the IRS should look into.