As part of an alleged conspiracy through which Kevin Giguere stole tens of millions of dollars from Ogale Ray (aka Randy Ray), Ray alleges Giguere “manipulated” Wendy Lewis.

Lewis is Ray’s wife and is alleged to have been suffering from onset dementia during the period in question.

Building on his original Complaint, filed in late 2024, Ray’s new allegations are detailed in an Amended Complaint filed on February 13th, 2026.

Ray alleges new facts surrounding Giguere’s money laundering scheme came to light through discovery.

Sadly, additional discovery has revealed that Mr. Giguere enlisted Mr. Ray’s wife and stepchildren into the scheme to steal from Mr. Ray.

Mr. Giguere preyed upon Mr. Ray’s dementia-stricken wife, Mrs. Lewis, to steal from Mr. Ray for years and years through hundreds of transactions.

If that wasn’t bad enough, Lewis’ own children were also in on Giguere’s alleged scheme.

Mr. Giguere manipulated Mrs. Lewis to participate in his conspiracy to financially benefit Mr. Giguere and Mrs. Lewis’s own family and children from her prior marriage.

Notably, Mrs. Lewis’ adult children, Kym Lewis and Scott Lewis, used Mrs. Lewis’ progressing dementia and Mr. Giguere’s influence over Mrs. Lewis as an opportunity to participate in the conspiracy and to encourage their mother to steal millions from Mr. Ray to directly benefit themselves and Mrs. Lewis’s estate, which Kym Lewis and Scott Lewis schemed to inherit.

Even now, Kym Lewis and Scott Lewis are locked in heated litigation about which one of them gets to take millions of
dollars that Mrs. Lewis wrongly absconded from Mr. Ray.

BehindMLM has previously covered the bones of Kevin Giguere’s alleged Jeunesse money laundering scheme as part of our reporting on Ray’s original complaint.

In a nutshell, through a sprawling empire of shell companies and “vast network” of accomplices, Giguere and Wendy Lewis, allegedly at the direction of Giguere, laundered tens of millions out of Jeunesse through “fraudulent 1099” tax filings.

Specifics alleged in Ray’s Amended Complaint that shed further light on an earlier “out of market” scheme Giguere is alleged to have headed up.

Mr. Giguere’s initial scheme, which was only uncovered after Mr. Ray filed his original Complaint, was to acquire Jeunesse products at vastly below ordinary costs (at times, for free) then sell the products in bulk for prices well below what ordinary Jeunesse distributors could sell it for.

Mr. Giguere typically moved these products through intermediaries based in Flushing, New York and Gainesville, Florida, and often made his bulk sale profits through associates in foreign countries.

This operation was initially authorized by Mrs. Lewis as a mechanism for finding additional online customers to support and help Jeunesse’s business, which it was successful in doing, but Mr. Giguere used the opportunity to enrich himself, Mrs. Lewis, and their co-conspirators.

The only person excluded from benefiting was Mr. Ray.

Once the profits rolled in from Mr. Giguere’s bulk product sales, that money did not benefit Mr. Ray as an owner of Jeunesse.

Instead, it was laundered through shell companies controlled by Mr. Giguere and then diverted to Mr. Giguere, Mrs. Lewis, Mr. Giguere’s conspiring associates, and to Mr. Giguere’s friends, family, and love interests.

Mr. Giguere often used his former girlfriend, Chantel Lowen, and business associate, Chris Munizzi, to help manage and effectuate the scheme.

Both received large payouts and used shell companies to effectuate the money movements; one such example is Victory International, LLC.

Mr. Giguere also wanted and needed Mrs. Lewis’s help to effectuate this operation, so he made sure she received financial benefits from this scheme.

Mrs. Lewis received direct proceeds from this scheme. These proceeds went to her individually and to companies she operated and controlled. An example of one such company is W L Enterprises LLC.

Mrs. Lewis’ adult children, Kym Lewis and Scott Lewis, also received direct proceeds from this scheme.

In the case of Kym Lewis, she never worked for Jeunesse and never had a role with Jeunesse. Despite this, and as just one example of the benefit to her from this scheme, Kym Lewis received over 5 million dollars into an account she owned with Mrs. Lewis as joint tenants with rights of survivorship.

Scott Lewis similarly received millions of dollars in ill-gotten gains from this scheme individually and through companies he owned and/or controlled. An example of one such company is S Lewis Enterprises LLC.

This operation, collectively, is referred to as the “Out of Market Scheme” as it was designed to sell Jeunesse products in bulk outside of the typical Jeunesse distributor “market.”

Mr. Ray was the only one not to benefit from the Out of Market Scheme.

Moreover, Mr. Ray’s injuries are special, in that he was harmed by being cut out of the proceeds from these sales while Mr. Giguere and Mrs. Lewis benefited, along with their associates.

Accordingly, Mr. Ray suffered a direct harm and is entitled to bring a direct action for the events relating to the Out of Market Scheme.

While Ray cites “tens of millions” in personal losses, Ray claims losses to Jeunesse as a company potentially run into the “hundreds of millions”.

Cited evidence of the actual cost of Giguere’s alleged money laundering scheme include communications between Giguere and a former Jeunesse promoter;

One former Jeunesse distributor, frustrated with Mr. Giguere, described the scope of what Mr. Giguere profited in a text to Mr. Giguere, saying: “that’s ok Kevin I know who actually fucked my China business over with your 55mm in earned from bulk sales.”

Ray claims Giguere’s “out of market” scheme slowed down towards the end of 2019 and into 2020, “due to difficulty in moving the out-of-market goods”.

We should note here that Chinese authorities seized $770 million in smuggled Jeunesse products between January and May 2020.

Chinese authorities claimed a “criminal group” was responsible and made three arrests, including Jeunesse President of Greater China, Robin Lee.

In any event, after Giguere’s “out of market” China smuggling scheme came to an end, Ray alleges he “devised a new scheme to continue stealing millions at Mr. Ray’s expense”.

This is the money laundering scheme details in Ray’s original late 2024 Complaint. In the original Complaint, Ray named thirty-nine defendants;

  1. Kevin Giguere
  2. Bailey Giguere
  3. Austin Giguere
  4. B&G Team Inc. (Florida)
  5. Big Country Acres LLC (Florida)
  6. VT3 LLC (Florida)
  7. Bet High LLC (Florida)
  8. KNC Enterprises INC. (Florida)
  9. KALB Enterprises International (Florida)
  10. Team Destiny LLC (Florida)
  11. Gato Grande LLC (Florida)
  12. Pamela McKinney and Pamela R. Mckinney CPA
  13. Brook McKinney
  14. Courtney Cook
  15. William Robert Dawson
  16. Carol Dawson
  17. CD Asset Holdings LLC (Florida)
  18. Barbara Dawson
  19. Geri Dorman
  20. Debbie Kurley
  21. Jennifer Luce
  22. Said Naciri
  23. Ashley Frost
  24. Taylor Norvell
  25. Joseline Buscampell
  26. United Strong LLC (Florida)
  27. Christopher Munizzi
  28. K2 Quest LLC (Florida)
  29. Canna Cope Wellness LLC (Florida)
  30. Covenant Home Security LLC (Florida)
  31. Hollie Mancini
  32. Youth Inside Out LLC (Florida)
  33. Ruth Northvell
  34. Ricketts Management LLC (Florida)
  35. Dolan Ricketts
  36. Brenda Ricketts
  37. Foubi Cleaning Services LLC (Florida)
  38. Myrna Nash and
  39. Allebas AES LLC (Florida)

Since filing, several defendants have been voluntarily dismissed from the case:

  • Jason Borne and his company Allebas AES LLC were dismissed in July 2025; and
  • William Robert Dawson, Carol Dawson and CD Asset Holdings LLC were dismissed in December 2025

As I’m writing this article with a slight delay, I’m also noting Pamela McKinney, William McKinney, Courtney Cook, Brooke McKinney, Wesley Shull, Cameron Cook and Summit Quest Inc. were dismissed in March 2026.

With the above dismissals taken into consideration, Ray’s Amended Complaint adds fifteen new defendants;

  1. Dakota Giguere – wife of Kevin Giguere’s son, Austin
  2. Dinosaur Marketing LLC
  3. Kevina Apartments LLC
  4. KVG Development LLC
  5. Chantel Lowen
  6. Nancy Fitzpatrick – appointed legal guardian of the property of Wendy Lewis (Lewis is legally incapacitated, Ray can’t sue Lewis directly due to a guardianship order);
  7. Kimberly Lewis (aka Kym Lewis) – daughter of Wendy Lewis
  8. Scott Lewis – son of Wendy Lewis
  9. S Lewis Enterprises LLC
  10. WL Lewis Enterprises LLC
  11. Wayne Dorman
  12. Jusbla Holdings LLC
  13. Frenzi LLC
  14. Victory International LLC
  15. Rentoor Spots LLC

As of April 23rd, 2026, the total number of defendants in Ray’s case stands at fifty-four.

Ray and Lewis sold Jeunesse to LaCore Enterprises in January 2023. Jeunesse remained operational with Giguere’s involvement as Chairman, before collapsing towards late 2024.

Velovita acquired what was left of Jeunesse in December 2024.

Stay tuned for updates as BehindMLM continues to track Randy Ray’s legal proceedings against Kevin Giguere.