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Update · August 15, 2026

Racketeering now runs both ways: the franchisees’ Utah RICO count, fact-checked episode by episode.

First BAM pleaded racketeering against its critic, and swore it. On August 14 the Salem franchisees pleaded the same statute back: Utah RICO, the Pattern of Unlawful Activity Act, against BAM Franchising, chief executive Ammon McNeff, chief operations officer Matthew McNeff, takeover operators Brandon Best and Joshua Johnson, and their companies. The statute requires at least three related episodes. The complaint pleads four. Each one is presented below as pleaded and graded against the record, and every fact checkconfirmed mark opens the matching entry of the living census in a new tab.

AS PLEADED The count is a set of civil allegations. BAM has denied wrongdoing throughout, its response to the amended complaint is pending, and nothing here is adjudicated.Source: First Amended Complaint ¶¶ 225–231, BAMF Salem 1, LLC, Law & Gorman v. BAM Franchising, Inc. et al., No. 260200029, hosted as filed; the full report on the amendment is here.

CONFIRMED The checkable skeleton beneath the episodes: registry dates, recorded calls, court files, police records, and BAM’s own disclosure tables, each behind a fact-check mark, graded in the living census.Source: linked throughout; the census began as update 100, preserved as published.

What was filed

The count pleads its pattern element in the statute’s own terms, quoting it: “at least three episodes of unlawful activity” that are not isolated but share purposes, results, victims, and methods. It asks for the statute’s double damages. And it names the operation, pleading in the alternative that the defendants are an enterprise associated in fact:

“Defendants BAM, Baker Bricks, LLC, Salem-Baker Bricks, Inc., Ammon McNeff, Matthew McNeff, Brandon Best, and Joshua Johnson constitute a group of individuals and entities associated in fact—the recapture-and-resale operation.”

First Amended Complaint ¶ 225AS PLEADED

The four episodes, graded

They differ in how much of each sits in checkable record, and the grades say so. The standard is the one applied to BAM all over this site: the pleading gets graded, not presumed.

Episode one · ¶ 227AS PLEADED

Salem, Oregon · 2022 to 2025

The eight-step sequence walked, with its fact-checks, in the companion report on “the Fraud Scheme”: induced by the Item 19 figures, executed through withheld transfers and manufactured defaults, finished with the seizure and the resale. Pleaded with communications-fraud and theft-statute predicates. The documentary record here is the densest on this site: the registry dates, the recorded calls, BAM’s own verified pleading, the resale trail.

Episode two · ¶ 228AS PLEADED

Canby, Oregon · 2017 to 2023

Pleaded from the Canby franchisee’s own suit: the representation that the store “had generated $200,000 of profits per year during the previous three years,”fact checkasserted the October 30, 2023 taking of roughly $200,000 in assets with, she pleads, no inventory or valuation ever provided, and BAM’s 2026 FDD corroborating the affiliate history in its own words.

The Canby paper trail already holds a census entry of its own: one franchise agreement carrying three different dates across BAM’s filings.fact checkconfirmed Full report: the Canby matter; her complaint is hosted here.

Episodes three and four, as labeled · ¶ 229AS PLEADED

“Keizer” and “Springfield”

Both enter the pleading through one sentence of the consignor’s written report to LEGO’s chief executive: “a pattern up here in Oregon of seizing stores to steal assets (Keizer and Canby locations) as well as a recent event involving over $200k of Lego product being stolen and resold in Springfield Oregon.”fact checkasserted The complaint uses that letter twice: at ¶ 84 as evidence of scienter and motive, and at ¶ 229 promoted to episodes three and four.

Read against the record, the labels thin out. The store the letter calls “Keizer” is the store the first episode already describes: the complaint itself calls it “the Salem/Keizer franchise,” the police file on the seizure is Keizer PD’s,fact checkconfirmed and this site’s Keizer coverage is that same takeover. What the letter adds is not a second store; it is the second victim of the same night, the consignor whose collection was in the building. And “Springfield”: BAM’s own store roster lists no Springfield, Oregon outlet at all. The nearest is the Eugene store, one town over, the “independent” store through whose website the seized goods were later offered.fact checkconfirmed In the record this site holds, the Springfield event rests on the letter’s sentence, and its census entry grades it exactly that way.

The pleading’s own continuity clause points the same direction: the five-year spacing the statute requires is measured, in the complaint’s words, between Salem and Canby.

The count, the pleading, and BAM’s own paper

3
Related episodes the statute requires
As the complaint quotes it
4
Episodes the complaint labels
Salem · Canby · “Keizer” · “Springfield”
8
Takeovers booked in BAM’s own Item 20 tables
Fiscal 2020 through 2025
0
Lawsuits disclosed under Item 3, three editions running
While the Canby and Salem suits were live

What the record books beyond the four

Eight takeovers in six years, in BAM’s own tables. Item 20 Table 4, editions 2021 through 2026, books eight reacquisitions from franchisees, against a development chief recounted on camera calling corporate takeovers “the absolute last resort” that “we never do.”fact checkasserted The roster, with locations and years, is in the takeover count.

Three consecutive editions of “no litigation.” BAM’s 2024, 2025, and 2026 FDDs each certify that no litigation is required to be disclosed.fact checkconfirmed A prospective buyer reading BAM’s current disclosure would learn of none of these episodes.fact checkconfirmed

And the machinery that keeps episodes invisible. The Canby case itself was compelled into confidential arbitration in April 2024 and left the public record; the interview behind the takeover count could get three of thirty-five former owners to answer at all. That is what a public census is for. Whether any of this ever becomes a pleaded episode is the parties’ business; what BAM’s own documents book is already on the record.

The fair reading, and its limit. A racketeering count is a label the law lets a plaintiff plead and then makes the plaintiff prove, in Utah by clear and convincing evidence. BAM denies wrongdoing, its answer to the amended complaint has not yet been filed, and when it is, it will be reported here the same way this filing is. The four labeled episodes are not equally situated, and this page says so plainly: Salem sits on the densest record this site holds, Canby on a sworn complaint and BAM’s own corroborating disclosure, and the “Keizer” and “Springfield” labels, read against the record, describe the second victim and the resale side of the seizure the first episode pleads. Both sides have now pleaded the same statute at each other, which is itself a fact about this dispute worth holding onto. Nothing here is a finding of law.
Sources. First Amended Complaint, No. 260200029 (Utah Bus. & Chancery Ct., Aug. 14, 2026), hosted as filed, and the full report on the amendment · The living census, whose entries every fact-check mark opens (begun as update 100, preserved as published) · The companion report: “the Fraud Scheme,” eight steps with their fact-checks · The Canby matter and the hosted Cooper complaint · The Keizer takeover and the reopened police file · The takeover count. · Update: the Mansell settlement, and the apology that dates to the McNeffs’ exposure.
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The BAM Map is independent reporting on matters of public concern. Nothing here is a finding of any person’s guilt; the civil allegations described are unadjudicated, and every defendant is presumed innocent. Sources are linked so readers can check the record.  ·  Home · Map · The law · Bodycam