BAM has given three different accounts of why it took, kept, and let its successors resell a LEGO collection it did not own. Each one is below, quoted from BAM’s own filings, letters, recordings, and texts, with the law walked at every step. They cannot all be true. Pick one and follow it.
CONFIRMEDEvery account in this tree is BAM’s, quoted from its own verified complaint, its own termination letter, recordings pleaded in the public court record, and the police file its own operators spoke into. Every quote carries its provenance where it appears. CONFIRMEDEach route ends at a statement BAM already made somewhere else, in writing or on tape, or at a rule of law that was on the books before the locks changed.
On the night of November 14, 2024, BAM Franchising terminated its Salem/Keizer, Oregon franchise by letter and seized the store, with a third party’s consigned LEGO collection inside: the retired Star Wars collection Bryan Mansell and his father spent about fifteen years building, consigned to the store under a written agreement dated November 22, 2023. That agreement is not this site’s document. It is BAM’s own Exhibit A, attached to BAM’s own complaint, hosted here, and its title clause reads: “Consigned merchandise shall remain the property of Mansell until sold.”
Ever since, BAM has needed an answer to one question: on what basis did it take, keep, and let its successors resell another family’s property? It has given three. Each answer, followed honestly, forces a second question, and BAM’s record has already answered those too.
On what basis did BAM take, keep, and let its successors resell another family’s property? BAM has given three answers. Choose the one you believe, and follow it.
Where they said it: BAM’s verified complaint asks the court to declare that BAM and its successor are “neither parties to, nor have any contractual duty or obligation regarding, the alleged 11/22/23 Consignment Agreement.” Twelfth cause of action, ¶212(b), BAM Franchising, Inc. v. Schneider, No. 2:26-cv-00593 (D. Utah), removed from Utah’s Fourth District, No. 260402353.
Follow this story to where it goes. If BAM is a stranger to the consignment, BAM holds nothing under it: no right to sell the goods, no share of the proceeds, nothing to inherit or assign. This door also closes a favorite deflection: the same paragraph calls the consignment “the private legal dispute between Chrystal and Bryan,” meaning the franchisee, Chrystal Law, and the consignor, Bryan Mansell. It cannot be that either, because behind this door BAM swears it holds no duty under the agreement at all, and a stranger’s possession of another family’s property is not a contract question.
Which leaves the collection itself. A stranger with no rights under the agreement still has to say what happened to the goods when the locks changed. BAM’s record gives three accounts. Choose again.
Where they said it: the seizure-night call at 7:10 PM, BAM corporate’s Ki McAllister on speakerphone, addressing the franchisee, Chrystal Law, as preserved in the detective’s synopsis of the recordings in the Keizer police file.
“So, Crystal, ultimately that is a business thing and not necessarily yours. Brandon is taking on the business and takes on all that consignment.”
The speaker is Ki McAllister, BAM corporate. “Brandon” is Brandon Best, the incoming operator, the one being handed the store. The thing Best “takes on” is Bryan Mansell’s consignment, and the voice doing the handing, that night, is corporate’s, administering the agreement it swears it never joined. An agreement moves through someone bound by it. You cannot hand off a contract you were never part of.
Where they said it: BAM’s Verified Complaint ¶29, sworn: “Less than $5,000 worth of Star Wars LEGO product could be located and identified” in the store at the takeover.
Start with who counted. By the complaint’s own words, the count was “an informal and video inventory” conducted by “BAM’s representative, Brandon”: Brandon Best, the same incoming operator who was handed “all that consignment” on the 7:10 PM call that night. The published police file then answers the count from inside the company. The successor operator, Josh Johnson, in writing, to Bryan Mansell:
“We have been holding on to what had stickers on them. We put them in the back. Let me know if you want it. Otherwise leave us alone.”
And witnesses told police that the identifying marks came off the consigned sets immediately after the takeover. Sets with the stickers removed count differently. A company holding the tagged goods in its successor’s back room, setting terms for their return, is not describing an empty store. It is describing possession, and behind this door possession is the one thing a stranger cannot explain.
Where they said it: the successor operator, Josh Johnson, to police, in Officer Starns’ contemporaneous report of their call, May 2025, Keizer file, Supplement 1.
“He added that he also doesn’t feel he needs to, since the store’s inventory became his once he took it over.”
Title does not move because a store changes hands. BAM’s own Exhibit A says what stayed put: “Consigned merchandise shall remain the property of Mansell until sold,” and its first section opens with the words “Mansell owns.” For a year, the store’s monthly consignment checks agreed. And behind this door BAM was never inside the agreement, so nothing it took over could turn Bryan Mansell’s property into anyone else’s.
Where they said it: the termination letter BAM’s law firm emailed the franchisees the night of the seizure, Exhibit D to No. 260200029.
“BAM will be exercising all of its post-termination rights under Section 15 of the Franchise Agreement, including Appraisal Notice to determine Fair Market Value of the Assets, purchasing the assets of the Franchise, and taking over operations under the Marks at the Accepted Location.”
Follow this story to where it goes. Rights come with their process, and this letter names it: an appraisal notice, fair market value, a purchase. The steps run in order, each one presupposes the step before it, and underneath them all sits the legal claim doing the work: the security interest in the store’s assets.
So choose the ground that carries the takeover: one of the letter’s own steps, or the lien underneath them.
Where it was promised: the termination letter itself, naming the Appraisal Notice. The franchise agreement gives the appraisal ten days.
As pleaded by the franchisees in No. 260200029: no appraisal, ever. Not late. Never. The letter that elected the process is the letter that promised this step first, and the record of BAM performing that promise does not exist.
Where it was promised: the same sentence of the letter, “purchasing the assets of the Franchise” at Fair Market Value.
Fair market value is the number the appraisal was supposed to produce, and the appraisal never happened, so no purchase at that number could have either. What the pleaded record shows instead: resale underway within days, through operators connected to BAM’s Eugene store, while the seized store’s own website redirected shoppers to Eugene.
Where it attaches: the commercial code’s terms for disposing of collateral: notice, a commercially reasonable sale, an accounting of proceeds.
As pleaded, more than a year after the takeover there was still none. Electing the rights while skipping every duty attached to them is not exercising a contract. It is keeping the goods.
Where it rests: the legal skeleton under the letter, the franchisor’s lien on the store’s assets, exercised as self-help. This is the strongest version of BAM’s case, so it gets the most careful walk.
A security interest attaches to the debtor’s rights in collateral. The debtor was the franchisee. BAM’s own Exhibit A opens with “Mansell owns” and keeps title with him “until sold,” so the franchisee’s rights in the collection were a bailee’s: hold, sell for the owner, remit. A lien on the store’s inventory reached what the store owned. It did not reach what the store merely held.
Article 9 does have a rule that looks like it helps, and it deserves to be named precisely, because it is this door’s best hope. ORS 79.0319 deems a consignee to hold the consignor’s title, but only “for purposes of determining the rights of creditors of, and purchasers for value of goods from” the consignee. It is a priority rule. It protects third parties who claim through the store, which is why the sets sold at the register to retail customers are gone. It does not make the taker the owner as against the consignor, and it has never been a license to keep another family’s property: under Oregon law, selling or refusing to return goods one does not own is conversion, and good faith is not a defense.
And this door has a prior question to survive: whether Article 9’s consignment machinery covers this store at all. The statute excludes deliveries to a merchant “generally known by its creditors to be substantially engaged in selling the goods of others.” A used-LEGO resale store, a business whose model is selling what other people bring in, is close to the paradigm. If the exclusion applies, the deal was never an Article 9 consignment, the priority machinery never engages, and the title clause controls exactly as written.
One more paper problem, from the certified record: the blanket financing statement BAM’s own bank filed against BAM covers all of BAM’s inventory, present and after-acquired, with no carve-out for consigned goods. Whatever entered BAM’s estate as inventory sat under its lender’s lien. That is not a defense to keeping the goods. It is the mechanism by which the goods became unrecoverable, which is what a conversion claim prices.
Where they said it: BAM’s verified complaint, ¶43: BAM acquired the store’s assets “as a bona fide purchaser for value, without actual or constructive notice of any actual third-party right, claim or lien.” The complaint is verified by Ammon McNeff, BAM’s chief executive and owner, as true and correct. No. 2:26-cv-00593.
Follow this story to where it goes. “Without actual or constructive notice” is a sworn factual claim about one night, and a sentence sworn once means one thing.
Whose ignorance does it describe? Choose the reading to defend.
Where they said it: the successor operator, Josh Johnson, to police, on body camera: “we don’t know about any consignment.”
The night of the takeover, BAM corporate’s Ki McAllister, on speakerphone, handed the consignment to the incoming operator by name: “Brandon is taking on the business and takes on all that consignment.” A year earlier, the store had publicly promoted a “Retired Star Wars™ Collection reveal,” a launch event with press and a line out the door, run under BAM’s brand. And BAM’s chief executive, Ammon McNeff, on police body camera released under Utah’s public records act, discussed the collection as someone else’s: “his stuff,” that “allegedly she didn’t pay him,” and “we will figure out how to make you whole.” Total ignorance has too many recordings against it.
Where they said it: the same sworn sentence, ¶43, which continues past the no-notice clause to name “the undisclosed private consignment arrangement without notice to or the consent of BAM.” The next paragraph, ¶44, repeats it: the arrangement was “never disclosed to or approved by BAM.”
Read the sworn sentence whole. It swears BAM took the assets “without actual or constructive notice of any actual third-party right, claim or lien”, and then, in the same breath, names the right it had no notice of: “the undisclosed private consignment arrangement.” A sentence cannot describe the thing it swears it never heard of. “Undisclosed” is not the vocabulary of ignorance; it is the vocabulary of a company that knows exactly which arrangement it is characterizing, and is characterizing it away. The seizure-night tape and the brand’s own advertising then supply how the knowing happened: the consignment was administered by corporate’s own voice that night, and had been advertised to the public under BAM’s brand a year before.
Where it rests: the new operators, Brandon Best and Josh Johnson, cast as buyers who took the inventory free of claims.
Brandon Best was told, on the seizure-night recording, that he “takes on all that consignment.” Months later, Josh Johnson texted Bryan Mansell that the store had “been holding on to what had stickers on them.” An overnight seizure of an entire store is the opposite of an ordinary-course purchase. A customer buying one set at the register is a bona fide purchaser. The company that changed the locks is not.
Ten routes in, ten dead ends, each closed by BAM in its own words or by a rule of law that was on the books before the locks changed: a sworn complaint, a termination letter, a speakerphone call, a text message, an exhibit, a statute. The tree has no eleventh branch, and the game had only one rule: at every moment, the collection had exactly one owner. BAM’s own exhibit names him. “Consigned merchandise shall remain the property of Mansell until sold.”
In court filings, yes. Rule 8(d) of the Federal Rules of Civil Procedure lets a party plead inconsistent positions in the alternative, and that is normal and proper. If that were all this was, there would be no story here.
But alternative pleading protects positions taken inside a lawsuit. It does not un-say statements made outside one. The “takes on all that consignment” line is on tape, in a police file. The “we will figure out how to make you whole” line is on police video. The “stickers” line is in writing, in the same police file. The reveal event was marketing to the public. Statements of a party come into evidence against it whichever story it finally elects at trial, under Federal Rule of Evidence 801(d)(2). And BAM’s complaint is verified: its allegations are sworn by its chief executive, Ammon McNeff, not hypothetical.
Sooner or later a factfinder asks which single story is true. Whichever route BAM picks through this tree, it has already testified against itself on the others.
CONFIRMEDThe statutes below are Oregon’s enacted commercial code, linked to a public compilation; the cases are published Oregon Supreme Court decisions, cited by reporter. Each rule also appears above, at the step it governs. ANALYSISThe application of that law to the pleaded record is this site’s analysis. No court has ruled on it.
The consignment agreement chooses Oregon law (§XVI), and the goods sat in Oregon, so Oregon’s commercial code governs the property questions. The agreement itself is a textbook retained-title consignment: “Mansell owns” (§I), “Consigned merchandise shall remain the property of Mansell until sold” (§IV), 65 percent of gross to the consignor with a monthly accounting (§II). Every door in the tree is an attempt to get around that clause. Here is the law each one runs into, assembled.
If BAM is a stranger to the consignment, property law takes over, and its rule is conversion: an intentional exercise of dominion over another’s chattel serious enough that the actor must pay its full value. Oregon adopted the Restatement’s definition in Mustola v. Toddy, 253 Or. 658 (1969). A bailee who sells for its own account converts. A stranger who takes and keeps converts. A purchaser in good faith who buys converted goods still converts, because no one passes title they do not have. The tort does not care which door was chosen; every door is an exercise of dominion, and the only thing each door changes is the explanation.
A security interest attaches only to rights the debtor holds in the collateral, ORS 79.0203, and enforcing one carries duties: commercially reasonable disposition, ORS 79.0610, and application and accounting of proceeds, ORS 79.0615. The pleaded record shows the duties unperformed: no appraisal, no accounting, resale within days.
The lien argument itself then has two walls of its own. First, Article 9’s consignment machinery only applies if the deal meets every element of ORS 79.0102(20), and one element excludes deliveries to a merchant “generally known by its creditors to be substantially engaged in selling the goods of others.” A secondhand-LEGO franchise sits close to the paradigm of that exclusion, and Oregon’s controlling gloss, Belmont International, Inc. v. American International Shoe Co., 313 Or. 112 (1992), set a forgiving standard for the showing. If the exclusion applies, the deal was never an Article 9 consignment: it is a common-law bailment, the title clause controls as written, and every bulk taker downstream took nothing. Second, even inside Article 9, the deemed-title rule, ORS 79.0319, runs only to creditors of, and purchasers for value from, the consignee. A search of Oregon’s lien registry in this record found no financing statement filed by anyone against the store entity, so as against a perfected lender and the register customers, an unfiled consignor’s goods, once sold through, are gone; that is why the consignor’s remaining claim is a money claim. But priority decides who keeps the goods. It has never decided who owed whom their value, and it has never made the taker the owner as against the consignor.
Two separate laundering rules could move title through a merchant’s hands, and both stop at the same wall. Entrustment, ORS 72.4030(3), passes the owner’s rights only to a buyer in ordinary course of business. That buyer takes free, ORS 79.0320. And the definition, ORS 71.2010(2)(i), expressly excludes transfers in bulk. A customer at the register is inside the definition. A franchisor seizing a store overnight, and a successor acquiring the store’s assets whole, are outside it, twice over: outside the definition, and, on this record, outside “without knowledge.” The record on knowledge is the tape, the texts, the advertising, and the sworn no-notice sentence that names “the undisclosed private consignment arrangement” inside itself, each quoted at its step above, each a party’s own statement admissible against it under Federal Rule of Evidence 801(d)(2).
Within Article 9, an individual creditor’s actual knowledge does not, by itself, change perfection-based priority; that is a real feature of the code and BAM is entitled to it. It is also beside the point of this page. The notice record answers a sworn factual sentence (“without notice of any third-party claims”), the good-faith element of the purchaser defenses, and the conversion claim. It is quoted here for those purposes, not as a priority argument.
At every moment since the day it was consigned, that collection has had exactly one owner. BAM’s own exhibit names him: “Consigned merchandise shall remain the property of Mansell until sold.” For a year, the store’s monthly consignment checks agreed. No route through the tree changes that. Each one just adds another statement to the record.
The other side. Every door above is BAM’s own account, presented at its strongest and followed to its end; that walk, not this box, is where BAM’s positions get their hearing. What remains on BAM’s side of the ledger: a prosecutor twice reviewed the Keizer police file and twice declined to bring a criminal case, and BAM is entitled to cite that; the copy of the consignment agreement in the court record is unsigned; and no court has yet ruled on any claim here, in any direction. Every allegation, from every party, is unadjudicated.
Sources. BAM Franchising, Inc. v. Schneider et al., No. 2:26-cv-00593 (D. Utah), removed from Utah 4th Dist. No. 260402353: Verified Complaint, verified by Ammon McNeff, CEO (¶29; ¶¶43–44; twelfth cause of action, ¶212), Exhibit A (Consignment Agreement, Nov. 22, 2023, §§I, II, IV, XVI; hosted), Exhibit B (sales ledger; hosted). Law/Gorman v. BAM Franchising, Inc., Utah Bus. & Chancery No. 260200029: Complaint (filed Mar. 27, 2026; seizure-night recordings as pleaded; no-appraisal and no-accounting allegations; Eugene resale and website redirect as pleaded), Exhibit D (Notice of Immediate Termination, Nov. 14, 2024). Oregon action No. 24CV06902 ¶14. Keizer Police Department file KZP24020132, released under Oregon public records law, published in full with a hosted redacted copy; witness statements on the removed marks reported here. Police body camera: The Keizer Store (Version 2); Orem, Utah footage (March 11, 2026), released under GRAMA, bodycam archive. The store’s public event promotion, November 2023. Utah UCC-1 No. 2023970648-7 (June 26, 2023); certified UCC-11 search No. 2606021254563-0. Oregon Revised Statutes 71.2010(2)(i), 72.4030, 79.0102(20), 79.0203, 79.0319, 79.0320, 79.0610, 79.0615 (linked inline). Belmont International, Inc. v. American International Shoe Co., 313 Or. 112 (1992); Mustola v. Toddy, 253 Or. 658 (1969); Restatement (Second) of Torts §222A. Fed. R. Civ. P. 8(d); Fed. R. Evid. 801(d)(2). Prior reporting: the store and the collection.
The BAM Map is independent reporting on matters of public concern. Nothing here is a finding of any person’s guilt; the claims described are allegations in pending civil litigation, no court has ruled on them, and every party is presumed innocent. The legal analysis above is the site’s reading of public law applied to a pleaded record, not legal advice and not a prediction. Sources are linked so readers can check the record. · Home · Map · The law · Bodycam