The record · the Salem case · first amended complaint
BAM chose to tell its story as a racketeering suit, and to swear it: its chief executive and its recruiter signed the facts as true. On August 14, the people it took the store from filed the same accusation back, a racketeering-pattern count built out of BAM’s own oath, and named everyone: both senior officers personally, the operators BAM installed, and the companies in between.
An amended complaint is a set of allegations, not findings. What makes this one reportable is how much of it is checkable: it is built from documents the defendants themselves wrote. Every claim on this page is tagged with where it comes from:
And every claim wears its grade:
Where a claim already has its own entry on this site’s census of BAM’s self-contradictions, a small mark follows the sentence, like this: fact check It opens that exact entry, with its provenance, in a new tab.
As pleaded means: the amended complaint alleges it, and this page reports the allegation without adopting it. BAM has not yet responded to the amendment; its response will be reported the same way. Every person named here is presumed to have done nothing unlawful unless and until a court finds otherwise.
On March 27, 2026, Chrystal Law and Benjamin Gorman, the couple who ran the Bricks & Minifigs store in the Salem/Keizer area, sued BAM Franchising in Utah’s new business court. That original complaint told the story this site has documented from the records: a franchise terminated on November 14, 2024 with the locks changed the same evening, the inventory kept, no appraisal and no accounting. It named one defendant, the company. The amendment filed August 14 names the people. COURT RECORD Confirmed
The amendment itself: 168 paragraphs grown to 241, twelve causes of action grown to fifteen, one defendant grown to seven. Every number above is from BAM’s own sworn or filed documents.
The racketeering suit that armed the other side
To understand the amendment’s central device, start with what BAM filed first. Its suit against the reporter and the collector is itself a racketeering case, brought under Utah RICO, the state’s Pattern of Unlawful Activity Act. And a racketeering complaint has a cost of admission: you must plead the facts of the scheme, with particularity, and BAM chose to verify its version, meaning its chief executive and its recruiter signed the facts as true under penalty of law. The amendment’s answer is the same statute pointed the other way, a Utah RICO count against BAM, both officers, and the successor operators, and it is built, to a remarkable degree, out of the facts BAM’s own officers swore.
The mechanism in one line: the facts BAM swore to accuse others are the facts now pleaded against it. Confirmed as to what each filing says.
The oath has names. The verified complaint, filed in another Utah court against the reporter who covered this story and the man whose LEGO collection was in the store, was signed as true by Ammon McNeff and Josh Johnson themselves. The amendment quotes it, repeatedly, as the admissions of the people who swore to it:
That Best and Johnson’s successor company was formed on May 2, 2024, more than six months before the termination.
That on the night of the seizure, “Brandon was engaged as a contracted inventory inspector for BAM and was requested to inspect and inventory the Salem LLC store at the time of repossession.”
That BAM “exercised its priority rights to the collateral,” “repossessed the Salem LLC store,” assumed “any and all fixtures, inventory and other assets,” and “credited an estimated $38,000 paltry value thereof as an offset” to its claimed debt.
That in late 2025, the successor operators found “approximately 20” Star Wars sets in a lockable back-office cupboard, noticed “stickers not previously recognized” on them, and were directed that they not be sold.
BAM’s verified complaint, No. 260402353, as quoted in the amendment · Confirmed against the filed document
The last item is the one everything turns on.
The sworn fact the accusation cannot survive
For more than a year, BAM and its operators accused Chrystal Law of taking the consigned sets, in a nationwide press release, in online replies to customers, and in a complaint to the police that the amendment says was premised entirely on that story. Then, to plead its racketeering case, BAM swore its own timeline, and inside it is this: in late 2025, its operators found “approximately 20” Star Wars sets in a locked back-office cupboard of the store, wearing “stickers” they did not recognize, and were directed not to sell them. The amendment pleads what the stickers were: her consignment labels, the marks of the collector’s ownership. The sets she was accused of taking were, by the accusers’ own oath, in the accusers’ own cupboard.
Confirmed that BAM’s verified pleading says this · As pleaded that the stickers were the consignment labels. The accusation’s public half is on this site’s census; the police half is in the Keizer file.
To accuse others of racketeering, the company swore out the facts. The sworn facts are now the racketeering case against the company.
Who the amendment adds, and why it says so
The six new defendants, in the amendment’s own frame: Brandon Best and Josh Johnson, the pair who organized the successor company and took over the store, and whose roles this site documented in the Keizer file; their two entities, Baker Bricks, LLC (Utah) and Salem-Baker Bricks, Inc. (Oregon); and BAM’s two most senior officers, chief executive Ammon McNeff and chief operations officer Matthew McNeff, sued personally. As to Matthew, the amendment pleads that he personally made the claim that the franchise came with LEGO affiliation, in the era when BAM’s own disclosure document listed him as its Treasurer. As to Ammon, it pleads that he directed the takeover scheme and made the June 4 statements over his own name and title. And about the company itself, the amendment adds a registry fact: BAM’s registration to do business in Utah, the state it franchises from, was administratively dissolved on January 26, 2022 and never reinstated. COURT RECORD As pleaded on the conduct · Confirmed on the offices, which are BAM’s own Item 2 disclosures.
All seven defendants, in one view:
What the amendment pleads, and against whom
| Cause of action | Against | |
|---|---|---|
| 1 | Fraud in the inducement | BAM; Matthew McNeff personally, for the LEGO claim |
| 2 | Negligent misrepresentation | BAM |
| 3 | Breach of contract | BAM |
| 4 | Breach of the implied covenant of good faith | BAM |
| 5 | Conversion | BAM; and Baker Bricks, Best, and Johnson as direct converters |
| 6 | Aiding and abetting conversionnew | Baker Bricks, Best, Johnson |
| 7 | Utah UCC Article 9: commercially unreasonable disposition; elimination of the claimed deficiencynew | BAM |
| 8 | Tortious interference with economic relations | BAM |
| 9 | Defamation per senow also the officers | BAM; Ammon and Matthew McNeff personally, for June 4 |
| 10 | Injurious falsehood and trade libel | BAM and its agents |
| 11 | Civil conspiracy | BAM, both McNeffs, Baker Bricks, Best, Johnson |
| 12 | Oregon Unlawful Trade Practices Act | BAM |
| 13 | Utah RICO (Pattern of Unlawful Activity Act), with double damagesnew | BAM, both McNeffs, Baker Bricks, Best, Johnson |
| 14 | Unjust enrichment | BAM; Baker Bricks, for disgorgement |
| 15 | Declaratory judgment: the termination wrongful, the note discharged, the deficiency eliminated | All defendants (six of the seven added) |
Shaded rows are counts new in the amendment. Highlighted names are defendants the amendment ADDED to that count: the original complaint named BAM Franchising alone, so every other party, on every count, is new. COURT RECORD As pleaded
The chronology, from the registries
The amendment’s core argument about intent is not an adjective, it is a date sequence, and every date on it comes from a government registry or a filed document:
The successor’s paperwork vs. the termination
registry filings & filed documents, 2024–2026
The successor entity was organized six months before the termination it benefited from; the Oregon operating name was registered the day after the locks changed; the purchase agreement followed in March. BAM cannot dispute this line: the formation date, the next-day registration, and the purchase agreement are each admitted in its own sworn pleading, and the rest is government registries. COURT RECORD · registries · BAM’s own oath Confirmed on every date · As pleaded on what they mean.
“No honest termination process produces a successor whose paperwork precedes the default notice.”
One date on that line is this site’s addition, not the amendment’s: Best and Johnson’s Eugene corporation, the store where the Keizer file traced the consigned collection, was itself registered on August 21, 2024, three months before the seizure. OREGON REGISTRY Confirmed
The Director of Operations, quoted in the pleading
The original complaint described threats. The amendment does something more careful: it strikes the harshest remembered line and replaces it with what the recordings say. The pleaded quotes now attributed to BAM’s Director of Operations, Kai McAllister, from recorded calls on and around the night of the seizure, calls the franchisees have since published in full on their own channel:
On whether BAM’s take-it-or-leave-it demand was a kindness: “It sounds like a threat and I can […] acknowledge you feeling that because in a way it is.”
On the store’s lease, which BAM was contractually obligated to assign to the franchisees: “the lease is technically in our name still.”fact check The rent BAM blamed them for not paying was rent on a lease BAM itself still held.fact check
On what set the termination in motion, six days after Ms. Law called to ask about selling because her family needed to relocate: “Crystal did reach out to us and talk about you guys, uh, moving out of the country and wanted to know like what would need to happen before that? And so what we did is we sat down on our end and we looked at the […] relationship that we have with you guys and where all the outstanding balances and everything.” A sit-down, on the balances, triggered by her question. And when Mr. Gorman said out loud that her inquiry is what “got this whole ball rolling,” the answer: “Pretty sure that’s what you just said.”
On negotiation: “I don’t have the authority to make changes to that contract, and no one with authority to make changes to that contract would make changes to that contract.”
Recorded calls, as quoted in the amended complaint · As pleaded · and the recording is public: “Our Full Conversation With Ki McAllister” (15:57, the franchisees’ channel) · their account of the takeover · you can listen and check every quote yourself
And the amendment pleads the sequence of the papering itself: the formal termination notice was not emailed until that evening, after the seizure was already underway, and only after Ms. Law refused to hand over the keys without written documentation, saying on video, as the pleading quotes her, “And I still haven’t. You might want to let them know to send me that e-mail.” THE TAPES, AS FILED As pleaded
Three numbers for the same obligation
What did the franchisees owe? The amendment tracks BAM’s own answer as it moved:
Both numbers are BAM’s own: the claimed debt from its filings, the $38,000 “paltry” credit from its sworn pleading. Confirmed
Against that moving figure sits one fixed one: the $38,000 “paltry” value BAM’s sworn pleading says it assigned to everything it took, a store’s full inventory, fixtures, equipment and records, in a year when the same pleading valued the debt at $175,000. The amendment’s new commercial-code count says Utah law does not allow that arithmetic: a secured party that takes collateral must dispose of it in a commercially reasonable way, on notice, with an accounting, and when it instead transfers the collateral to a party related to itself, the law values the collateral at what an honest sale would have brought. The amendment asks the court to rule that under those rules the claimed debt is eliminated. COURT RECORD As pleaded · the letter’s figure and the sworn $38,000 are Confirmed from the filed documents.
June 4, and what it now costs
On June 4, 2026, BAM issued a nationwide press release announcing the Salem store’s closure. This site has read that release against the record before. The amendment attaches it as Exhibit J and pleads its statements about Ms. Law, that there were “three sets of books,” a “hidden personal bookkeeping version” of the consignment records, an “unauthorized consignment agreement,” a debt of “close to $200,000 at time of planned abandonment”, as defamation per se, false statements imputing dishonesty in her trade. And because the release went out over the names and titles of BAM’s two most senior officers, the defamation count now runs against Ammon McNeff and Matthew McNeff personally, not the company alone. Read the release whole and notice who it blames: the franchisees it took the store from, and then, in the same breath, the successor operators BAM itself installed, cited for “gross negligence” and “operational gaps.” Everyone who ever ran the store, except the company that took it twice. The amendment’s summary of the release is its own sentence: “harvest the store, discard the successors, and rewrite the history.” BAM’S OWN PAPERS · Ex. J Confirmed the release says these things · As pleaded that they are false. And the release’s “unauthorized consignment agreement” line has already been read against BAM’s own contract:fact check the franchise agreement’s own text lists consignment sales among what a franchisee “may also offer.”fact check
The same release opened by calling BAM “an authorized LEGO® reseller.” The amendment sets that beside a letter from LEGO itself, filed as Exhibit A: “Bricks and Minifigs isn’t affiliated with the LEGO Group in any ways.” The affiliation claim, the amendment pleads, is the same one that induced the purchase in the first place.fact check BAM’S OWN PAPERS Confirmed on both documents’ words.
The count that changes the stakes
The amendment’s thirteenth cause of action is brought under Utah RICO, formally the Pattern of Unlawful Activity Act, the state’s civil racketeering statute, against the company, both McNeffs, Best, Johnson, and Baker Bricks. It pleads four episodes: Salem, this case; Canby, where another Oregon franchisee, a woman over 65 who invested her life savings, sued after BAM took possession of her store’s assets in October 2023 and, per her complaint, refused any inventory or valuation, a case still pending in Clackamas County (her complaint); and the Keizer and Springfield reports the consignor put in writing to LEGO’s chief executive. Utah’s statute allows a plaintiff who proves a pattern to recover twice their damages, plus costs and attorney fees. The amendment reserves the right to add episodes as discovery opens BAM’s franchise files. And the symmetry should be said plainly: both sides now stand accused under Utah RICO, but only one side’s accusation is built from the other’s sworn signature. COURT RECORD As pleaded throughout; the Canby case’s existence and filings are Confirmed public record.
Where this site grades the amendment itself
This page grades the plaintiffs’ pleading by the same standard it grades BAM’s papers, and one paragraph needs it. The amendment says BAM’s disclosure tables for fiscal 2024 report “no Oregon termination and no Oregon reacquisition at all.” That is half right, and the full truth is stranger than the pleading’s version. Corroborated in direction, overstated in one clause; here is the record itself:
One store-year, five ways, in BAM’s own filings
the November 2024 Salem termination, as BAM’s disclosure documents booked it
The 2025 edition’s departed-franchisee exhibit lists the exit, under “Termination,” naming “Chrystal Law and Ben Goreman [sic]”, the surname misspelled, the third misspelled name in these filings. The same edition’s Item 20 franchise table reports zero Oregon terminations that year,fact check in a row whose own arithmetic is impossible: it starts with 6 outlets against the prior year’s ending 5, books one reacquisition, and still ends at 6. Its company-store table reports nothing arriving at all, and silently drops the Canby store from its opening count. Then the 2026 edition restates the same historical year: the reacquisition becomes zero, the exit appears in no column, and two “opened” outlets absorb the swap. And the 2026 edition’s own fiscal-2025 Oregon row is impossible in the same way: seven outlets, minus one reacquired, equals seven.
BAM’S OWN PAPERS · 2025 & 2026 disclosure documents Confirmed, every cell quoted is in the filed editions. The five-edition reading of these documents lives at the disclosure file.
So the amendment understates its own best point. The problem is not that the seizure was left out of one table; it is that across two editions and five different places, BAM’s filings could not tell the same story about the same store twice, and the one time a number appears, the row it sits in cannot add. Confirmedfact check
And while its tables misbook the seizure, the same current edition’s litigation item, the section that exists to tell a prospective buyer about cases like this one, says “no litigation is required to be disclosed.” Three lawsuits about this conduct were pending when it issued. BAM’S OWN PAPERS Confirmedfact check
The other side, reported the same way
BAM has not yet answered the amendment, but its positions are on the record and belong here. It has a motion pending, filed in May, to move this dispute out of court and into arbitration under the franchise agreement’s dispute clause; the amendment devotes twenty paragraphs to why that clause should not apply, and the court has not ruled. In its own verified complaint, BAM pleads the other story: that Ms. Law told it she intended to close and abandon the store, that the payment defaults were real and mounting, that the repossession was pre-scheduled with her, and that the franchisees’ later settlement demand was itself extortionate. A court granted BAM a temporary restraining order in that case against other parties on June 2, 2026, finding its claims there likely enough to restrain conduct while the case proceeds. Every one of those positions is an allegation too, and the same presumptions apply to everyone. COURT RECORD As pleaded, by BAM
The records the amendment names
Like every real dispute, this one is waiting on paper that exists. The amendment names it: the store’s point-of-sale data, which BAM seized with the store and which would show what the inventory was worth and what the consignment sold for; the price the successor operators actually paid, which would test the $38,000 against a real number; the appraisal the termination letter promised and the amendment says never came; and the recording of the November 14 morning meeting. The case is not waiting on speculation. It is waiting on production. As pleaded
The documents
Nothing here asks for your trust. The amendment is public, the original complaint is public, and the sworn pleading it quotes is public.
The court’s redline comparison: every deletion struck through, every addition underlined, all 43 pages. Also: the original complaint · BAM’s verified complaint · the 2026 disclosure document · the franchise agreement · the termination letter · the Canby complaint · the LEGO letter
What this page holds back, on purpose
Intent, throughout: the chronology is confirmed, what it means is for the court. The identities of store employees named in the filings are not repeated here. The recordings quoted in the pleading are quoted only as the pleading quotes them. The criminal matters touching this story are unadjudicated and every defendant in them is presumed innocent. And where the amendment overstates, the overstatement is graded on this page, by the same razor used on everything else.
The amendment: First Amended Complaint, BAMF Salem 1, LLC, et al. v. BAM Franchising, Inc., et al., No. 260200029 (Utah Business & Chancery Court, filed Aug. 14, 2026), hosted above as the court’s redline against the March 27, 2026 original.
BAM’s sworn account: its verified complaint, No. 260402353 (4th District, Utah County), verified by Ammon McNeff and Josh Johnson; its Order and temporary restraining order are likewise public record.
The recordings: the franchisees published the McAllister call in full, “Our Full Conversation With Ki McAllister”; the quotes above are as the amendment pleads them, checkable against the published audio.
The registries: Utah and Oregon Secretary of State records for Baker Bricks, LLC (formed May 2, 2024), Eugene Baker Bricks Inc. (August 21, 2024), and Salem-Baker Bricks (November 15, 2024).
BAM’s own papers: the 2023, 2025 and 2026 franchise disclosure documents, including Item 2 (the officers), Item 19 (the revenue figures), Item 20 and the departed-franchisee exhibits (the tables above), and the audited statements; the June 4, 2026 press release (Exhibit J to the amendment).
The Canby case: Plastic Palette LLC and Christina Maria Cooper v. BAM Franchising, Inc., No. 24CV06902 (Circuit Court of Oregon, Clackamas County), cited in the amendment with its filings attached.
The census: the fact-check marks open individual entries on Every time Bricks & Minifigs contradicted itself, so far, this site’s registry of 685 graded self-contradictions, each with its provenance.
Prior reporting on this site: the Keizer file, second edition · who bought the store · the disclosure documents, read against themselves · BAM’s public statements.
Presumption of innocence throughout, in every direction. An amended complaint is a set of allegations. What this page confirms, it confirms from filed documents and government registries; what it cannot confirm, it labels; and the one place it found the amendment overstating, it says so.