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Raymond E. Butler II

Rico Case - Underlying Action

 

This First Amended Verified Complaint was originally filed in the U.S. District Court for the Western District of Michigan in Butler v. Eddi, et al., Case No. 2:24-cv-00134 (filed September 20, 2024; later transferred to the Northern District of Illinois as Case No. 1:25-cv-04443). The pleading asserts federal civil Racketeer Influenced and Corrupt Organizations Act (RICO) and RICO-conspiracy claims, along with a wide set of related state-law and equitable causes of action, arising from the alleged improper administration, concealment, and conversion of assets connected to the GPN Family Trust, the Doros Generation Trust, and related trusts/sub-trusts for which the plaintiff is a beneficiary. The complaint alleges that the trust structure was intentionally complicated through subsequent trusts, trustee changes, and the use of aliases/name changes to obscure asset trails, placing the value of the assets the plaintiff claims entitlement to at over $100 million (with some references to broader disputes exceeding $544 million). It frames the case as an “association-in-fact” enterprise that allegedly used a pattern of racketeering activity—including mail and wire fraud, money laundering, embezzlement, and other financial frauds—to withhold trust assets, enrich defendants, and conceal information from the plaintiff. A central factual issue is an alleged “fraudulent release” dated September 23, 2009, claimed to bear a forged signature and to have released trust interests in exchange for an incomplete disbursement. The complaint seeks damages (including treble damages under RICO), recovery of allegedly misappropriated assets, and a jury trial.


Latest filings through mid-October 2026 reflect continued intense procedural litigation focused on judicial impartiality, counsel status, transcript accuracy, appellate review, and sanctions. On March 13, 2026, Judge Georgia N. Alexakis granted the plaintiff’s motion for disqualification and recused herself (ECF 240) in light of a related 264-page RICO suit filed by the plaintiff against her two days earlier (Case No. 1:25-cv-10904), citing the appearance of impartiality under 28 U.S.C. § 455(a) despite describing the suit as baseless; the case was reassigned to Judge April M. Perry on March 19, 2026 (ECF 241). The plaintiff filed a motion to disqualify Judge Perry on March 30, 2026 (ECF 245), which was denied following the April 9, 2026 hearing. Plaintiff subsequently moved to correct the April 9 transcript (ECF 254, May 1, 2026) and for an evidentiary hearing to play the official audio (ECF 256, May 4, 2026); both were denied (ECF 255 and ECF 258). An Executive Commission Order 26D004 was issued and docketed on April 17, 2026 (ECF 251), suspending Katherine London from practicing law and representing Butler in the Northern District of Illinois (with a copy sent to the ARDC). Butler moved to appear pro se (ECF 252–253, April 29, 2026). Subsequent counsel Racine Miller and The Michigan Law Firm later were granted their 2025 request to withdraw, with the withdrawal granted in May 2026 (ECF 263–265).


In the related Seventh Circuit appeal (No. 25-2589), the Court on May 27, 2026 affirmed the denial of the motion to lift the stay, freeze trust assets, and appoint a neutral fiduciary; dismissed the appeal concerning the protective order for lack of jurisdiction; and denied the petition for writ of mandamus (and motion for leave to file a supplemental petition) as frivolous. Sanctions litigation continued through the summer and fall: on September 17, 2026 (ECF 287), Judge Perry denied the sanctions motions of defendants Rajchenbach and Shabat and non-party CIBC Bank USA but granted defendant Ilana Eddi’s motion in part, directing submission of an itemized fee proposal by October 1, 2026, with plaintiff’s objections due by October 15, 2026 (see ECF 288 and ECF 290). The underlying trust dispute remains pending before Judge April M. Perry amid these ongoing assignment, recusal, transcript, appellate, counsel, protective-order, and sanctions disputes. All major filings are posted below for public review.

Complaint - 9/20/24 (pdf)Download
ECF 101 - Motion to Lift Stay - 2/12/25 (pdf)Download
ECF 102 - Motion to Stay Enforcement of ECF 101 - 2/12/25 (pdf)Download
ECF 104 - Order Denying Emergency Motion to Stay ECF 102 - 2/13/25 (pdf)Download
ECF 105 - Plaintiff's Objection to ECF 101 - 2/26/25 (pdf)Download
ECF 107 - Defendants Response Brief in Opposition to Plaintiff’s Objection to ECF 101 - 3/11/25 (pdf)Download
ECF 113 - Opinion and Order - 4/4/25 (pdf)Download
ECF 179 - Non-Party CIBC Bank Motion to Enforce Protective Order & Memorandum in Support - 8/4/2025 (pdf)Download
ECF 186 - Plaintiff's Motion to Strike Non-Party CIBC Motion to Enforce Protective Order - 8/5/25 (pdf)Download
ECF 187 - Judge Alexakis Order - 8/5/25 (pdf)Download
ECF 188 - Emergency Motion to Vacate Stay Dismissal - 8/7/25 (pdf)Download
ECF 195 - Judge Alexakis Order - 8/8/25 (pdf)Download
ECF 199 - Chaim Rajenbach & Menachem Shabat Opposition to Plaintiff Motion to Vacate Stay - 8/14/25 (pdf)Download
ECF 203 - Plaintiff's Reply to Defendants Opposition - 8/20/25 (pdf)Download
ECF 206 - Judge Alexakis Order - 8/26/25 (pdf)Download
ECF 208 - Judge Alexakis: Denial of Plaintiff's Emergency Motion - 8/27/25 (pdf)Download
ECF 223 - Motion to Disqualify - Judge Alexakis - 9/10/25 (pdf)Download
ECF 227 - Judge Alexakis Order - 9/11/25 (pdf)Download
Doc 13 - Motion to Disqualify - Judge Maldonado - 9/24/25 (pdf)Download
Doc 19 - Denial of Motion to Disqualify Judge Maldonado - 10/3/25 (pdf)Download
Doc 28 - Show Cause Reply - 10/20/25 (pdf)Download
Doc 42 - Sanction Order for Requesting Judge Maldonado's Disqualification - 11/7/25 (pdf)Download
Doc 44 - Motion for En Banc - 11/16/25 (pdf)Download
Doc 50 - Motion for En Banc Denied - 11/19/25 (pdf)Download
Doc 52 - Appellee's Reply to Plaintiff's Appeal - 11/19/25 (pdf)Download
SCOTUS Emergency Application to Justice Amy Coney Barrett - 12/19/25 (pdf)Download
SCOTUS Denial by Justice Amy Coney Barrett - 1/5/26 (pdf)Download
Doc 68 - Appellants Reply to Appellee's Response - 1/12/26 (pdf)Download
SCOTUS Denial by Justice Clarence Thomas - 3/2/26 (pdf)Download
ECF 240 - Motion for Disqualification of Judge Alexakis Granted - 3/13/26 (pdf)Download
ECF 240-1 - Reassignment of Judge - 3/13/26 (pdf)Download
ECF 241 - Reassignment to Judge April M Perry - 3/19/26 (pdf)Download
ECF 241-2 - Reassignment by Judge Dirkin - 3/19/26 (jpg)Download
ECF 245 - Motion to Disqualify - Judge Perry - 3/30/26 (pdf)Download
Modified "Transcript" of Proceedings Before Judge Perry - 4/9/26 (pdf)Download
Executive Commission Order 26D004 London - 4/17/26 (pdf)Download
ECF 71 - Writ of Mandamus - 4/20/26 (pdf)Download
ECF 252 - Plaintiff Motion to Appear Pro Se - 4/29/26 (pdf)Download
ECF 253 - Pro Se Appearance Form - 4/29/26 (pdf)Download
ECF 254 - Plaintiff Motion to Correct Judge April Perry's Doctored Transcript - 5/1/26 (pdf)Download
ECF 255 - Denial By Judge April Perry to Correct Doctored Transcript - 5/1/26 (pdf)Download
ECF 256 - Motion For Evidentiary Hearing to Play Official Audio Per Doctored Transcript - 5/4/26 (pdf)Download
ECF 258 - Denial by Judge April Perry to Review Her Doctored Transcript - 5/5/26 (pdf)Download
ECF 259 - Status Report - 5/5/26 (pdf)Download
ECF 259-1 - Status Report Exhibit - 5/5/26 (pdf)Download
ECF 260 - Supplement to ECF 259 Status Report - 5/5/26 (pdf)Download
ECF 261 - Defendant Nachshon Draimon's Joinder to Status Report of Defendants - 5/5/26 (pdf)Download
ECF 72 - Motion for Leave to File Supplemental Petition for Writ of Mandamus - 5/6/26 (pdf)Download
ECF 73 - Supplemental Petition for Writ of Mandamus - 5/6/26 (pdf)Download
ECF 263 - Order by Judge April Perry re Racine Miller withdrawl - 5/13/26 (pdf)Download
ECF 264 - Stipulation Withdrawl of Racine Miller & The Michigan Law Firm - 5/15/26 (pdf)Download
ECF 265 - Attormey Racine Miller Motion to Withdraw Granted - 5/21/26 (pdf)Download
ECF 271 - Defendants Chaim Rajchenbach and Menachem Shabat Motion For Sanctions - 7/17/26 (pdf)Download
ECF 272 - Defendants Chaim Rajchenbach and Menachem Shabat Sanctions Memorandum - 7/17/26 (pdf)Download
ECF 272-2 - Affidavit of Shomshon Moskowitz - 7/17/26 (pdf)Download
ECF 274 - Plaintiff's Opposition to Defendant Ilana Eddi's Rule 11 Motion For Sanctions - 7/17/26 (pdf)Download
ECF 275 - Motion For Sanctions Acknowledgement - 7/20/26 (pdf)Download
ECF 276 - US Court of Appeals Notice of Issuance of Mandate - 7/22/26 (pdf)Download
ECF 277 - US Court of Appeals Petition For Rehearing Denial - 7/22/26 (pdf)Download
ECF 278 - US Court of Appeals denies Plaintiff’s motion to lift stay & freeze trust assets - 7/2/26 (pdf)Download
ECF 279 - US Court of Appeals Order affirming denial to lift stay, freeze trust assets - 7/22/26 (pdf)Download
ECF 280 - Defendant Illana Eddi Reply In Support of Rule 11 Sanctions Motion - 7/28/26 (pdf)Download
ECF 281 - Plaintiff's Opposition to Chaim Rajchenbach & Menachem Shabat Sanctions Motion - 8/10/26 (pdf)Download
ECF 282 - Former Counsel Racine Miller's Response in Opposition to Motion For Sanctions - 8/10/26 (pdf)Download
ECF 282-1 - Exhibit 1 - 8/10/26 (pdf)Download
ECF 282-2 - Exhibit 2 - 8/10/26 (pdf)Download
ECF 283 - Chaim Rajchenbach & Menachem Shabat's Reply in Support of Motion For Sanctions - 8/20/26 (pdf)Download
ECF 286 - Non-Party CIBC Bank's Renewed Motion For Sanctions & Fees - 9/15/26 (PDF)Download
ECF 287 - Judge April Perry Order (Warning) Denying CIBC & Defendants' Sanctions Motions - 9/17/26 (pdf)Download
ECF 288 - Defendant Illana Eddi's Statement in Support of Fee Award Against Plaintiff - 10/1/26 (pdf)Download
ECF 290 - Plaintiff's Objection to Defendant Ilana Eddi's Fee Award Statement - 10/15/26 (pdf)Download
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