The shells and the resurrection

#The trademarks move

Further down, the same playbook turns up where the family actually lives: four of its own houses deeded into asset-protection shells, swept to a spouse days before the sons sued, then quietly re-recorded with a cured notarization once the suit had passed (the four deeds, side by side).

Start with the brand, because the brand was the last thing worth anything. The Bricks & Minifigs franchise system runs on a name, and the federal registration for the standard-character mark BAM is owned by BAM Franchising, Inc., the operating company at the center of the litigation. USPTO TSDR, BAM (SN 98706031) In Utah’s corporate registry, that operating entity now reads “Inactive.” Utah business registry, entity No. 11984597 (BAM Franchising)

On July 16, 2025, while the franchisee lawsuits and the trademark fight were live, a new company was organized in Utah: BAM IP Holdings, LLC, filed active, its managers listed as Ammon McNeff and Matthew McNeff, the two sons running the franchise day to day. Utah business registry, entity No. 14333873 (BAM IP Holdings) Filing History BAM IP Holdings LLC, Reg. No. 14333873 The entity is named for intellectual property, formed by the operators of a franchise whose remaining value depends heavily on its brand.

What the public record does not yet show is a recorded assignment moving the BAM marks out of the operating company and into the new holding company. The USPTO Assignment Center shows no recorded assignment of the BAM or Bricks & Minifigs marks to BAM IP Holdings; the registered BAM mark still names BAM Franchising as owner. USPTO TSDR, BAM (SN 98706031) The Delaware redomestication did not move them either: the surviving Delaware corporation was supposed to inherit the Oregon company’s property by operation of law, yet the marks still name the old Oregon entity, leaving the title clouded across three boxes, the inactive Oregon shell that still holds the registrations, the Delaware survivor that supposedly absorbed it, and the Utah holding company built to receive it. Delaware Certificate of Merger - BAM Franchising (Oregon) into Delaware - File 2482543, Reg. No. 2482543 So the transfer, if it happened, has not surfaced on paper, and that distinction matters. But the shape is the relevant record fact: a negative-equity operating company, a new entity owned by insiders, and the valuable asset positioned one entity away from old creditors while the operating business keeps using the name. BAM IP Holdings’ own Utah registration carries no intellectual-property assignment recorded into it, so the marks remain, on the record, where they started. USPTO TSDR, BAM (SN 98706031) Utah business registry, entity No. 14333873 (BAM IP Holdings) Whether a court will ever call it a fraudulent conveyance is undecided; the structure is on the registry. Utah business registry, entity No. 14333873 (BAM IP Holdings)

#The husk and the resurrection

The second move is cleaner, and it is documented to the day. The company that had been sued for twenty years, Legally Mine, LLC, the original Utah entity formed back in January 2009, did not die. It was renamed. On May 21, 2026, an amendment to its certificate of organization ran through Utah’s Business Entity Search. Filing History LM OLDCO LLC, Reg. No. 7228976 The thing once called Legally Mine became “LM OLDCO, LLC”, a conventional old-company name for a shell left after a business line has moved. It did not happen only once: that same afternoon, by an identical amendment, the family’s tax-and-accounting arm, Legally Mine Tax and Accounting, LLC, was renamed to “LMTA OLDCO, LLC.” LMTA OLDCO, LLC - Amendment to Certificate of Organization (UT 2026-05-21) Two companies turned into two husks in a single sitting. The tax-and-accounting work also runs through an entity called SHIELLD LLC, which Utah lists doing business as ‘Legally Mine Tax & Accounting’ and as ‘SHIELLD Tax & Accounting.’ SHIELLD LLC

Eight days later, the good part reappeared. On May 29, 2026, a separate company registered the assumed name “LEGALLY MINE LLC” as a brand-new doing-business-as, and a companion DBA, “LEGALLY MINE TAX AND ACCOUNTING LLC.” Filing History Legally Mine 2026 Entity, Reg. No. 14441858 Filing History Legally Mine Tax and Accounting 2026 Entity, Reg. No. 14441864 The certificate of assumed name for the revived “Legally Mine” brand is its own filing. Assumed Name (DBA) Legally Mine 2026 Entity, Reg. No. 6069703 The owner of these freshly minted Legally Mine names is not the litigated entity. It is Centra Wealth Solutions, LLC. Centra Wealth Solutions LLC, Reg. No. 6061489

The sequence matters. The defendant in the lawsuits is renamed “LM OLDCO”. Certificate of Organization LM OLDCO LLC, Utah business registry, entity No. 7228976 The operating brand then reappears as an assumed name owned by a different company with no litigation history attached to it. Assumed Name (DBA) Legally Mine 2026 Entity, Reg. No. 6069703 Centra Wealth Solutions LLC, Reg. No. 6061489 Same product, same market, new shell. It leaves creditors and regulators chasing the old name while the customer-facing name continues elsewhere.

#Who is Centra

Centra Wealth Solutions, LLC was organized in Utah, with a certificate of organization on file and a registered agent, BTJD Corporate Services, LLC, that also serves the new Legally Mine DBAs. Certificate of Organization Centra Wealth Solutions LLC, Reg. No. 5892820 Filing History Centra Wealth Solutions LLC, Utah business registry, entity No. 14681035 Its managers, per the Utah registry, are two men: David Johnston and Mark Comer. Centra Wealth Solutions LLC, Reg. No. 6061489

The name Mark Comer carries weight because FTC v. iMall is not a rumor and not just a vague “sanction.” In 1999, over the Internet commerce venture iMall, the Federal Trade Commission obtained a stipulated final judgment and order for permanent injunction against iMall, Craig R. Pickering, and a Mark R. Comer, resolving charges that they made false earnings claims for Internet-based business opportunities and violated the FTC Franchise Rule. FTC v. iMall, Inc., No. 2:99-CV-03650 (C.D. Cal. Apr. 12, 1999)^✓ The order matters in four distinct ways:

• Money: $4 million in total consumer redress, with iMall paying $750,000 and Pickering and Comer paying a total of $3.25 million. FTC v. iMall, Inc., No. 2:99-CV-03650 (C.D. Cal. Apr. 12, 1999)^✓
• Business-opportunity restraints: Pickering and Comer were permanently barred from selling Internet-related or pay-per-call business opportunities, barred for ten years from selling franchises, and required to post a $500,000 performance bond before selling business opportunities. FTC v. iMall, Inc., No. 2:99-CV-03650 (C.D. Cal. Apr. 12, 1999)^✓
• Conduct restraints: the order barred future Franchise Rule violations and material misrepresentations in business-opportunity marketing. FTC v. iMall, Inc., No. 2:99-CV-03650 (C.D. Cal. Apr. 12, 1999)^✓
• Publication caveat: the stipulated judgment resolved the FTC case for settlement purposes and was not an admission of a law violation; it proves the court-entered order and its terms, not a trial finding. FTC v. iMall, Inc., No. 2:99-CV-03650 (C.D. Cal. Apr. 12, 1999)^✓

Whether the Mark Comer now steering the revived “Legally Mine” brand is that same man is confirmed, and not on the shared name alone. Across independent records the match holds on several axes: the same middle-initial-R name (the voter file gives it in full, Mark Richard Comer); the age iMall’s own SEC filing gives for Comer (31, in early 1998), which places his birth in late 1966 and fits the present-day Comer; the same Brigham Young University attendance window, 1984 to 1985, recited in both the iMall filing and the present-day record; the same Utah County base; and the same seminar-marketed line of business. What converts that to outright confirmation is the continuous public record: iMall’s 1999 SEC proxy carries Comer’s own home in Orem, and the Utah County Assessor shows a single, unbroken “Comer, Mark R” ownership chain running from that Orem home to his present Highland and Alpine residences, with no competing second Mark R. Comer in the county. In his own 2016 Synergy profile he describes founding “an online mall” during the Internet boom, the iMall venture, recounted without its name or its FTC outcome. The scope of the iMall paper travels with the claim: the held court record confirms the caption and a 1999 order to show cause, the judgment terms ($4M in redress, a $500,000 bond) come from the FTC’s own press release, and the lifetime ban reached Internet and pay-per-call business opportunities while the franchise-sales bar ran ten years and expired around 2009. The company now holding the Legally Mine name is run by the same Mark Comer the FTC named in 1999, out of a Highland address the old operating entity never used. Centra Wealth Solutions LLC, Reg. No. 6061489

That an asset-protection brand under a UPL injunction from the Supreme Court of Ohio (Ohio State Bar Association v. Legally Mine, LLC, No. 2025-0037) Final Order, Ohio Bar v. Legally Mine should re-emerge under new managers, in a new entity, weeks after the litigated company was renamed to “OLDCO,” is one more instance of the same structure.

#The houses

The brand, the operating shell, and the receivables are three of the asset classes the family ran its own product on. The fourth is the most concrete, because it is where they live. Start with where the family actually lives. Rivendell Estates, LLC, one of a row of whimsically named McNeff entities, is owned, per its own 2016 certificate of organization, by “The Daniel J. and Evelyn F. McNeff Living Trust.” Rivendell Estates, LLC - Certificate of Organization (UT 2016-05-26) That same certificate carries, verbatim, the charging-order mechanic the seminars sell: a “Distribution Authority” article empowering the members to “distribute the profits and/or capital of the LLC business pro-rata or non-pro-rata as they deem advisable.” The clause was filed in May 2016, years before this family’s litigation began. It is the marketed design, found operating inside the family’s own governing document, on the family’s own roof. The county recorder shows that same LLC held the family home at the McNeff family's residential address (Orem) in Orem: Daniel and Evelyn deeded it in, Rivendell held title, and in 2021 it was deeded back out. Utah County Recorder, the McNeff family's residential address (Orem) (Rivendell, parcel 55-602-0002) A living trust on top, an asset-protection LLC beneath it, a house at the bottom, the nesting-doll arrangement the curriculum prescribes.

Then watch the timing. On January 12, 2021, about ten days before Daniel’s own sons sued him in federal court, four of these asset-protection LLCs deeded four family houses to Evelyn McNeff, Daniel’s wife, in four consecutive recorder entries, 5830 through 5833: Bear-Elf Manor, Legal Bear, Legal Bricks, and Rivendell Estates, each to Evelyn, one after another. Utah County Recorder, 2021-01-12 batch transfers to Evelyn McNeff (entries 5830-5833) Two years later, on February 26, 2023, the move reversed: Evelyn deeded three of the houses back out to three brand-new entities, Bagend Burrow, Green Dragon Lair, and Phoenix Keep, again in consecutive entries, 11822 through 11824. Utah County Recorder, 2023-02-26 batch transfers from Evelyn McNeff (entries 11822-11824) Consecutive entry numbers are the signature of a single coordinated batch recording, not four families independently selling houses on the same day. It is the same fingerprint as the husk-shed up the page: two Legally Mine entities renamed in the same minute in 2026. Filing History LM OLDCO LLC, Reg. No. 7228976

The January 2021 batch carries a second tell, in the notarizing. As first recorded, all four of those deeds were defective on their face: the notarial jurat named no signer and stated no capacity, the kind of acknowledgment that under Utah law is not even entitled to record (Utah Code section 57-3-101). Seven months later, in August 2021, after the sons’ federal suit had come and gone, the same four deeds were re-executed and re-recorded in a second consecutive batch, entries 141977 through 141980 (the four deeds, side by side), this time cured: Daniel McNeff added as the named signer, the execution date moved to August 10, 2021. The same in-house notary, commission number 702080, signs both the defective originals and the cures. The originals were recorded within a minute of one another that January; the cures were re-recorded within a minute of one another that August. The defective window spanned the divorce-decree finalization and the sons’ lawsuit, and the cure followed the suit’s dismissal.

The reading is bounded but pointed. That an identical defect appeared on all four deeds and was cured identically in a single later batch is documented on the recorder’s own face, and it is hard to square with an innocent clerical error, which would not replicate across a coordinated four-property batch and then resolve in a coordinated four-property fix. A defective acknowledgment is not itself a crime, the timing is circumstantial, and no court has found the re-recording to be anything but a correction. What the record shows is a coordinated misperfection and later perfection of the family’s own home transfers, executed by the family’s own notary, timed to the litigation calendar.

The names read like a fantasy index, Bagend Burrow, Green Dragon Lair, Phoenix Keep, Doriath Domain, Rivendell Estates, Bear-Elf Manor, alongside the Daniel Jay and Evelyn Freeman McNeff Family Limited Partnership. The pattern beneath them is uniform: a McNeff individual or the family partnership conveys to an asset-protection LLC or land trust, the 2021 batch moves the house to Evelyn, the 2023 batch moves it on to a fresh shell. Utah County Recorder, the McNeff family's residential address (Orem) (Corner Cottage, parcel 55-017-0001) Utah County Recorder, the McNeff family's residential address (Orem) (Legal Bricks / Phoenix Keep, parcels 41-311-0017 and 41-311-0018) These are the same charging-order LLCs and land trusts the company teaches, run on the family’s own homes rather than a client’s.

None of this is, by itself, unlawful. Charging-order LLCs and living trusts are ordinary estate-planning tools; deeding property to a spouse is common; and the 2016 clause and the 2016 deed-in long predate any of this family’s litigation, which cuts against reading the structure as a reaction to a creditor. No court has found that any of these transfers was a fraudulent conveyance, and whether one ever will is undecided. What the record shows is the structure, and that the structure is the one the company sold.

One more parcel rounds out the picture, with a caution attached. In Provo, the home of Ammon McNeff at Ammon McNeff's residential address (Provo) carries a $300,000 deed of trust to Mountain America, signed February 19, 2026 and recorded February 25, in the same window the litigation was peaking. Utah County Recorder, Ammon McNeff's residential address (Provo) (Ammon home, parcel 55-333-0014) + 2026 refinance docs When a related lien was reconveyed weeks later, the release retired only a 2017 deed of trust for $46,000; an older 2012 deed of trust to Goldenwest, recorded for $250,800, shows no reconveyance anywhere in the recorder’s index. On the face of the record, then, the 2026 refinance added new secured borrowing over a large prior lien it did not retire, rather than paying that lien off. Two honest limits travel with that reading. The size of the net draw depends on whether the 2012 Goldenwest lien was in fact still open, which the absence of a recorded release strongly suggests but does not conclusively prove. And the reading stops at the lien stack: a homeowner may refinance for any reason, the recorder does not show the purpose of the draw, and no court has connected this deed of trust to any creditor claim.

#They run it on themselves

The clearest sign that this is a method and not a one-off is that the people who sell it hold their own homes inside it, in the same county recorder. Scott Soelberg, an asset-protection lawyer in the same Jay Mitton lineage, deeded his own Orem home into an entity named The Legal Edge, LLC for ten dollars, and the operative deed (recorder entry 48147) was prepared by his own law firm, Scott L. Soelberg, P.C.; the home later passed to his son as trustee, again for ten dollars. Lee and Sharon Francis, who own the captive title agency the McNeff rotation ran through, cycled their own Provo home through their family trust for ten dollars, with that same agency, United West Title, in the chain. Karen Weeks, the agency’s president and its in-house notary, runs her own parcel through the agency she controls.

Two honest limits travel with this. These are separate operators, not one company: Soelberg’s rotation runs through his own firm and his own notary, not the McNeff notary, so the tie is a shared method and a shared title vendor, not common ownership. And, as with the McNeffs, charging-order LLCs and family trusts are lawful tools, and no court has found any of these transfers improper. What the record shows is that the practitioners who teach the structure keep their own houses inside it, which is hard to reconcile with a public posture that it is ordinary estate planning rather than creditor-defeating design.

The captive arm has a title-company side, and its closer is no more disinterested than the notary. Karen Weeks holds Utah notary commission 732152, and she is also President of United West Title, a member and manager of its in-house 1031 accommodator United West Exchange, and a member of Francis Family LLC, the holding company over the whole stack. The closer co-owns the stack she closes through, and on the record United West Title conveys title directly into its own captive accommodator, one Francis-owned office to the same Francis-owned office at a single Orem address. A title company and a tax-deferred-exchange accommodator that share a door and an owner, passing title between themselves on a recorded conveyance, are one back office wearing two names.

And the lawyer is the seam. The Articles of Organization that formed United West Exchange were drafted and filed by Anderson Fife & Marshall, the firm whose fax header sits on the 2009 formation certificate. That is the same firm captioned, in plain words, as “Attorneys for Legally Mine LLC and Daniel McNeff” in Daniel McNeff’s own Provo litigation, McNeff (Legally Mine) representation, Provo 4th Dist. No. 220400565 (Apr. 14, 2022)^⌖ and a named defendant in the sons’ federal complaint. One firm drafted the title family’s swap vehicle and represents the asset-protection operator whose shells that title family closes for.