Jeunesse co-founder alleges tens of millions in theft
Jeunesse co-founder Ogale Erandal Ray, aka Randy Ray, has filed a lawsuit alleging tens of millions of dollars in theft.
Ogale’s sixty-one page lawsuit was filed in Seminole County, Florida on October 1st, 2024.
The thirty-seven named defendants in Ray’s suit are:
- Kevin Giguere (top Jeunesse distributor turned executive, currently Chairman of Jeunesse)
- Bailey Giguere
- Austin Giguere
- B&G Team Inc. (Florida)
- Big Country Acres LLC (Florida)
- VT3 LLC (Florida)
- Bet High LLC (Florida)
- KNC Enterprises INC. (Florida)
- KALB Enterprises International (Florida)
- Team Destiny LLC (Florida)
- Gato Grande LLC (Florida)
- Pamela McKinney and Pamela R. Mckinney CPA
- Brook McKinney
- Courtney Cook
- William Robert Dawson
- Carol Dawson
- CD Asset Holdings LLC (Florida)
- Barbara Dawson
- Geri Dorman
- Debbie Kurley
- Jennifer Lu Naciri
- Taylor Norvell
- Joseline Buscampell
- United Strong LLC (Florida)
- Christopher Munizzi
- K2 Quest LLC (Florida)
- Canna Cope Wellness LLC (Florida)
- Covenant Home Security LLC (Florida)
- Hollie Mancini
- Youth Inside Out LLC (Florida)
- Ruth Northvell
- Ricketts Management LLC (Florida)
- Dolan Ricketts
- Brenda Ricketts
- Foubi Cleaning Services LLC (Florida)
- Myrna Nash and
- Allebas AES LLC (Florida)
Before we get into Ray’s claims, I want to note that Ray and Wendy Lewis (right) sold Jeunesse off to LaCore Enterprises in January 2023.
Nothing much happened with the business and Jeunesse was again sold to Velovita in October 2024. An updated BehindMLM review of Jeunesse under VeloVita’s ownership is pending.
I also want to note the most prominent defendant Ray has sued is Kevin Giguere. Giguere was a top Jeunesse distributor before transitioning to the executive side of things.
As at the time of publication, Giguere is believed to still be Chairman of Jeunesse.
In a nutshell Ray, citing himself as an “83-year old successful entrepreneur”, alleges the above defendants “stole millions of dollars” from him.
As part of this scheme, Ray singles out Pamela McKinney and her CPA company, Kevin Giguere and Robert Dawson as the “Kingpin Defendants”.
This action seeks the recovery of millions of dollars that the Kingpin Defendants stole from Mr. Ray and laundered into their own pockets (or those of their close families, friends, or business associates).
“Operational Defendants” and “Network Defendants” are also defined.
Said Naciri, Taylor Norvell, Ashley Frost and Joseline Buscampbell make up the Operational Defendants.
The Network Defendants essentially make up the rest of the named defendants.
To accomplish their scheme to steal Mr. Ray’s money, the Kingpin and Operational Defendants used straw companies and individuals—the Network Defendants— to look like actual Jeunesse Independent Distributors.
In reality, they were sham entities used by the Kingpin and Operational Defendants to launder money taken from Mr. Ray.
The Network defendants either provided no legitimate services to Jeunesse at all, or only the most minimal of services, and, instead were used by the Kingpin Defendants to funnel the millions of dollars extracted from Mr. Ray throughout several years.
The Network Defendants included a host of sham companies (set up or repurposed by Mrs. McKinney), as well as family members and/or confidants of the Kingpin Defendants, such as Mrs. McKinney’s husband and children, Mr. Giguere’s children, and Mr. Dawson’s mother.
Ray states that after suffering a stroke in 2018, he “took a backseat to the day-to-day activities of Jeunesse”. This is when the laundering of Ray’s money is alleged to have begun.
The Kingpin Defendants inserted themselves into Mr. Ray’s life and into positions of trust and confidence to drain Mr. Ray of his personal wealth.
Mr. Ray’s personal accountant (Mrs. McKinney/McKinney CPA), trusted business advisors (Mr. Giguere and Mr. Dawson), and legal counsel and trustee (Mr. Dawson).
Mr. Giguere was so intimately involved in Mr. Ray’s life that he coordinated the purchase of Christmas gifts for Mr. Ray’s family and the purchase of Mr. Ray’s vehicles.
To keep control of Mr. Ray as Mr. Ray aged, Mr. Giguere purchased a home in the same neighborhood as Mr. Ray and would regularly, and unexpectedly, drop in on Mr. Ray at his home.
With their positions of trust, Mr. Ray looked to, and relied on the Kingpin Defendants to guide him in virtually every aspect of his financial life.
The Kingpin Defendants abused Mr. Ray’s trust, by, most egregiously, deceiving Mr. Ray about his exposure to criminal liability if he failed to personally, and immediately, infuse Jeunesse with cash to cover its payroll.
Relying on their representations, tens of millions of dollars were infused into Jeunesse.
In reality, this supposed need for payroll was a ploy by the Kingpin Defendants to launder the money through Jeunesse and then ultimately steal it for themselves and their co-conspirators.
For example, in 2022 alone, the Kingpin Defendants effectuated the transfer of at least $35,000,000 out of Mr. Ray’s accounts and into Jeunesse.
As further explained below, the Kingpin Defendants also targeted, and liquidated, Mr. Ray’s other personal assets in support of their scheme.
The alleged financial misconduct took place through a “spider web of companies” set up by Giguere and McKinney.
Ray alleges the Kingpin Defendants worked directly with Jeunesse executives as part of a conspiracy to defraud him.
The Kingpin Defendants recruited and conspired with key Jeunesse employees to alter corporate documents and records in order to allocate these funds directly out of Jeunesse and into the hands of the Network Defendants.
The money allegedly stolen from Ray is claimed to have primarily benefited the Kingpin Defendants.
In 2022 … Mrs. McKinney was added onto Mr. Ray’s PNC Bank accounts so she could handle all of Mr. Ray’s direct living expenses.
This gave Mrs. McKinney full ability to move and transfer money out of Mr. Ray’s bank accounts – an ability she abused over and over to move millions of dollars out of Mr. Ray’s accounts without his permission or under false pretenses.
This money eventually ended up laundered to the Kingpin Defendants, including Mrs. McKinney’s, her husband’s and her children’s, own pockets.
The third Kingpin Defendant, William Robert “Rob” Dawson, is alleged to have been in business with Ray since “at least 2005”.
Mr. Dawson is also a co-founder/partial owner of Jeunesse and served as Jeunesse’s Chief Legal Officer since its inception and until 2020.
In addition to serving as Jeunesse’s Chief Legal Officer, Mr. Dawson also oversaw Jeunesse’s finances (along with Jeunesse’s Chief Financial Officer Ryan Ogden) and would monitor cash flow, domestic/international bank accounts, operating accounts, depository accounts, and merchant processing.
Mr. Dawson is a licensed attorney in Nebraska who also owns a controlling interest in Pathway Bank, a community bank located in Cairo, Nebraska, that he used as part of his scheme.
In January 2023, Pathway Bank was incorporated in Florida, with its principal address located at Mr. Dawson’s personal residence in Longwood, Florida.
Ray accuses Dawson’s family members of profiting through bogus Jeunesse distributor positions.
Ray further accuses Dawson of “offering [him] a source of money … in exchange for heavily discounted value on investments”, and “sell[ing his] interest in commercial property … for a steep discount and under false pretenses”.
Mr. Dawson also misled Mr. Ray to purchase Mr. Dawson’s interest in Jeunesse for far below its actual [worth].
Family members of Ray’s are also implicated. Geri Dorman and Debbie Kurley are nieces of Wendy Williams, wife of Ray and a Jeunesse co-founder.
Along with Jennifer Luce, Dorman and Kurley are accused of “supervising and directing” Said Naciri, Taylor Norvell, Ashley Frost and Joseline Buscampbell (the Operational Defendants), to manipulate Jeunesse payouts (the “Point Scheme”).
The Kingpin Defendants implemented the Point Scheme by recruiting and directing members of the Operational Defendants to fraudulently add millions of unearned points onto sham accounts—the Network Defendants’ Jeunesse accounts.
This resulted in the Network Defendants being paid commissions that represented exorbitant multiples of the amount of “sales” they recorded.
For example, Network Defendant Youth Inside Out Inc., whose corporate identity was shielded by username “Moxie1720”, recorded total sales of approximately $10,000 in 2022 but received nearly $250,000 in commissions during the same period.
In reality, many of the Network Defendants had no actual sales at all.
Ray cites defendant Jennifer Luce is cited as an integral part of the alleged Point Scheme.
Jennifer Luce was Jeunesse’s Director of Human Resources and a long-time, trusted employee of Jeunesse.
Jennifer Luce also participated in the scheme by adding unearned points to the Network Defendants and was compensated by Kingpin Defendant Kevin Giguere directly for doing so.
Jennifer Luce also assisted the Kingpin Defendants’ efforts to avoid legal liability for their Point Scheme once the Kingpin Defendants believed the Point Scheme was uncovered by notarizing sham releases for improper payments to the Network Defendants.
One example of Ray’s alleged Jeunesse nepotism is Kevin Giguere’s daughter Bailey Giguere.
Between November 2019 and September 2022, Geri Dorman (identified as “geri” in Jeunesse’s system) added 56,000,000 total points to the Jeunesse username “ABKG.”
The payee of the ABKG account was Defendant Bailey Giguere – the daughter or Kevin Giguere, who was directly paid almost $2,000,000 to a Suncoast Bank account during the same time period.
Upon information and believe, Bailey Giguere never sold any Jeunesse products and was never a Jeunesse Independent Distributor.
To support receiving $2,000,000 in commission payments, she would have had to be responsible for tens of millions of dollars in Jeunesse product sales.
Specific to the Kingpin Defendants threatening Ray with imprisonment if he didn’t fund Jeunesse’s payroll;
On several occasions, the Kingpin Defendants alerted Mr. Ray of the immediate and pressing need for an infusion of cash into Jeunesse.
The Kingpin Defendants, Mr. Ray’s most trusted advisors, justified the need by explaining that Jeunesse did not have adequate funds to cover its payroll obligations.
Mr. Dawson, a trained and licensed attorney, went as far as telling Mr. Ray that if Jeunesse’s payroll was not covered, Mr. Ray would be arrested, criminally charged, and sent to prison.
Throughout their relationship, Mr. Dawson suggested several means by which Mr. Ray could protect himself, including purchasing a residence in, and obtaining citizenship in, the country of Cyprus – a country Mr. Dawson advised Mr. Ray had no extradition treaty with the United States.
Mr. Dawson told Mr. Ray he had purchased property in Cyprus for that same reason.
Mr. Giguere, on June 23, echoed the payroll imprisonment threat.
To Mr. Ray, an elderly Floridian, any potential imprisonment term meant he would likely spend the rest of his life behind bars, a situation the Kingpin Defendants knew would induce Mr. Ray to act upon their advice.
But like all “good” advisors, the Kingpin Defendants presented Mr. Ray with a “solution” that would cover Jeunesse’s payroll and relieve Mr. Ray from potential prison time.
The solution was simple: Mr. Ray would sell to the Kingpin Defendants his shares in several investment funds, that were no readily dispensable on the market, for cents on the dollar.
The Kingpin Defendants specifically targeted Mr. Ray’s illiquid investment funds, coupled with the Payroll Imprisonment Threat, to induce Mr. Ray to sell the funds well below market value.
In turn, the Kingpin Defendants would handle liquidating the shares and infusing Jeunesse with the ill-gotten proceeds.
Ray alleges
- $2.5 million was liquidated from seven partnership investment funds (Ray alleges his capital in the funds “exceeded $3.8 million)
- $2.5 million was liquidated from another five partnership investment funds (over $3 million in alleged capital)
Mr. Ray never saw a single cent of the money owed to him by Mr. Dawson under either transfer; rather, Mr. Dawson paid that money over to Jeunesse knowing the proceeds would be laundered through Jeunesse and paid out to the Kingpin Defendants and Network Defendants (including his own sham entity) through the Point Scheme.
- $700,000 was liquidated from a Charles Schwab margin account
- “at least $35 million” was transferred out of PNC Bank accounts
Ray alleges imprisonment threats were further used to coerce him into selling his private Challenger jet to “upgrade to a bigger model (the “G550 Jet”).”
The Kingpin Defendants convinced Mr. Ray that upgrading the Challenger Jet would allow for a greater chartering capacity and more income.
The Kingpin Defendants also informed Mr. Ray that the proceeds of the Jet sale could be used to cover the purchase price of the G550 Jet.
However, while Mr. Ray sought a buyer for the Challenger Jet, Mr. Dawson convinced Mr. Ray to purchase the replacement G550 Jet through a loan from his Nebraska-based bank, Pathway Bank.
To effectuate the approximately $21,000,000 purchase of the G550 Jet, Mr. Dawson caused multiple loans for millions of dollars to be issued by Pathway Bank.
Moreover, the three loans were collateralized by Mr. Ray’s real property.
In April 2022, the Challenger Jet was sold for approximately $23,000,000.
However, the proceeds of the Challenger Jet sale were not used to satisfy the three Pathway Bank loans.
Rather, upon information and belief, the proceeds of the Jet sale were diverted into Jeunesse by the Kingpin Defendants to continue funding their Point Scheme and launder the money and steal it for themselves.
Ray goes on to claim he was unable to afford maintenance on the purchased G550, and sold the jet less than a year later for a “$6 million loss from the purchase price”.
In this process, Mr. Ray was saddled with millions of dollars of fraudulently induced debt.
In another alleged scheme Dawson is accused of “capitalizing on the knowledge” Ray was paying millions to cover Jeunesse’s payroll, to convince him to sell his interest in the holding company that owned the land Jeunesse’s headquarters was built on.
Ray alleges his interest was sold for “substantially less” than it was valued at.
Dawson is alleged to have extracted another $60 million out of Ray by selling him his Jeunesse ownership shares in 2020. Ray claims the sale was negotiated on “misrepresentations”.
Mr. Dawson falsely represented to Mr. Ray that Mr. Dawson’s shares were worth approximately $60,000,000.00.
This was false, and Mr. Dawson knew, or should have known, it was false, as he was Jeunesse’s Chief Legal Officer and in charge of Jeunesse’ finances.
The Point Scheme devalued the company and sent Jeunesse on a downward spiral. Mr. Dawson failed to disclose the Point Scheme to Mr. Ray, and instead misrepresented the value of Jeunesse to induce Mr. Ray to enter into the transaction.
Ray claims all of the alleged conduct came to light after he appointed his grandson, Phillip Wallace, as Power of Attorney in 2022.
In the latter half of 2022, exhausted from the fraudulently induced multi-million dollar infusions, Mr. Ray decided to sell his interest in Jeunesse.
During this period, Mr. Wallace began discovering the suspicious addition of points on the Network Defendants’ Points Log.
As Mr. Wallace began asking questions, the Defendants became aware their Point Scheme was, or would soon be, uncovered.
In a matter of mere days, Mr. Giguere mobilized and secured for himself and his co-conspirators, what he believed, were legitimate and enforceable releases from Jeunesse – and do not purport to be releases by Mr. Ray – from their scheme to
steal money.
Strikingly, the releases also include many of the Network Defendants herein and serve as additional proof of the Kingpin Defendant’s and their co-conspirators’ involvement in the Point Scheme.
After securing his release, which for some reason Ray’s wife Wendy Lewis signed off on, Giguere sent Wallace an email.
Having allegedly misappropriated millions and obtained a release, Giguere told Wallace he wanted to “get this behind us before this blows up [into] something that nobody wants” (click to enlarge below).
In the email Giguere appears to implicate several additional names as being part of Ray’s alleged Points Scheme.
Start with a five dollar cycle that cost the company $8.9 million a year that 44 people are getting.
Once again you’re gonna tell me you don’t know anything about it or the 10 maxed out positions from Damien Eric worry Cliff Walker Teresa Gregory and 1000 other people and 6000 fake positions that Doug whitehead try to get you to terminate for two years.
I’m not 100% sure on who “Damien” is but I believe “Eric worry” refers to disgraced MLM coach Eric Worre.
Cliff Walker and Theresa Gregory are/were Jeunesse top earners. Gregory was sentenced to 31 months in prison for tax fraud in 2021.
Wallace continued to investigate and, working with Jeunesse’s compliance team, suspended identified Network Defendant “sham accounts” towards the end of 2022.
Retaliation from Giguere was swift.
Within hours of the suspension, Kingpin Defendant Mr. Giguere ordered the suspended accounts to be reinstated.
Then, that following Monday, Jeunesse’s entire compliance team was terminated.
While this was going on, Debbie Kurley and the other Operational Defendants are alleged to have been “deleting the points” they’d added to the sham accounts.
Internally, nothing more would come of the alleged misconduct.
Ray meanwhile went on to sell his interest in Jeunesse to LaCore Enterprises “for a loss”.
The sale to the Purchaser required Mr. Ray to infuse Jeunesse with a final payment of $5,000,000.00.
Ray alleges Jeunesse’s sale to LaCore Enterprises was “the final stage of his plan … to usurp Jeunesse”.
In less than a year after the sale, the new “owner” of Jeunesse has been removed from corporate records and replaced with Mr. Giguere, the mastermind of the scheme.
In fact, a December 15, 2023 amendment to Jeunesse’s public corporate records removed the Purchaser and added Kingpin Defendants Kevin Giguere and Pamela McKinney as Jeunesse Directors.
Neither LaCore Enterprises or owner Terry LaCore (right) are named defendants.
It is unclear whether LaCore had knowledge of the alleged misconduct.
Across 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 duty (Kingpin Defendants)
- conspiracy to commit breach of fiduciary duty (kingpin defendants)
- professional 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)
In the two months since Ray filed his Complaint, one hundred and thirty-four docket entries have been generated. Due to the sheer volume of defendants, most of the entries are administrative in nature.
- on November 15th the court clerk recorded Entries of Default against Dolan Ricketts, Brenda Ricketts and Ricketts Management LLC
- over a hundred pages of subpoenas to various non-parties have been filed by Ray
Stay tuned for updates as BehindMLM continues to track the case.
Damien = Danien Freier and Stefania Lo Gatto?