Josh Johnson verified BAM’s RICO complaint, which calls it a lie that Ammon McNeff “took the LEGOs.” Over the phone, he said Ammon “didn’t want to give Bryan his Legos back.”

Johnson is one of the six plaintiffs suing Reckless Ben and one of the complaint’s two verifiers, with Ammon McNeff. On a recorded call published this week, he contradicted it on who kept the Lego, when the cupboard sets turned up, what he owed the consignor, who the buyers were, and what they paid. Those are the facts the rest of the complaint stands on. By October 16, BAM must answer a motion that asks the judge to weigh the plaintiffs’ own admissions.

PRIMARY SOURCEThe verified complaint in BAM Franchising, Inc. v. Schneider, filed May 27, 2026 in Utah’s Fourth District, No. 260402353, and removed to federal court, D. Utah No. 2:26-cv-00593: the complaint, and its caption and verification pages. Johnson’s verification: “I, Josh Johnson, individually and in my capacity as a Manager of Baker Bricks, LLC dba Salem-Baker Bricks Inc., hereby state that I have read the foregoing Verified Complaint and verify that the foregoing allegations are true and correct to the best of my knowledge, information and belief.”

PRIMARY SOURCEThe call: Matty AppleSeed’s 65-minute version on Patreon and his 25-minute cut on YouTube, quoted with times, as in the update on the call. Every one of the complaint’s thirteen claims is brought by all the plaintiffs: BAM, Ammon and Matthew McNeff, Brandon Best, Baker Bricks and Johnson.

The complaint’s words on the left, Johnson’s on the right. REFUTED: the record disproves the line. CONTRADICTED: the man who verified it says otherwise.

“Took the LEGOs”

The complaint’s first claim is racketeering. Among the “predicate acts” it charges Reckless Ben with is communications fraud, and among the lies it says make up that fraud:

Matty AppleSeed put it to Johnson that he had wanted to return the collection until Best got on the phone to say it was not going to happen. Johnson:

Seventeen minutes later Matty AppleSeed asked again.

The complaint calls it a lie that Ammon McNeff took the Lego. The man who verified the complaint says Ammon would not give it back, and names Matt McNeff with him. Both are his co-plaintiffs. So is Best, the man he says never said no.

CONFIRMEDThe complaint’s words and Johnson’s, as filed and as recorded.CORROBORATEDThat the refusal came from the top. Johnson’s account moves the blame off himself, so it needs a second source, and the Keizer police file has two: the detective’s summary of Matt McNeff’s February 2026 interview, “even if there were items sitting in that store, they don’t belong to Mansell anymore,” and the December terms, a document “from our legal team.”

Two men verified the complaint. One of them says the other would not give the Lego back.

“In late 2025”

The complaint’s account of the seizure is that nobody on BAM’s side knew the collection was there. Best took the inventory:

The consignment it describes was of “the Star Wars Legos” (¶ 33). So by its own account Best found Star Wars Lego in the store and identified none of it as consigned. He looked again, it says, and “concluded none existed” (¶ 51). Within two days of the termination, the complaint says, Mansell came to the store with his paperwork; Johnson looked it over, and the two men invited Mansell “to review the limited number of LEGO sets on display” (¶¶ 48, 49). That evening he came back with officers, and the complaint says the two men told the police the same thing:

And the Lego in the back office, it says, surfaced a year after the takeover:

Johnson, on the call:

The police got there first, a year before the complaint was filed. In the Keizer police file, Officer Starns’s May 2025 supplement notes that some items matched Mansell’s descriptions and had been set aside, and its photos show stickered sets in the store the night of the takeover. She recorded Johnson’s position in the same supplement: he “does not want to give these items to Mr. Mansell. He added that he also doesn’t feel he needs to, since the store’s inventory became his once he took it over.”

REFUTEDThat Best found no consigned product, and that the cupboard sets were first located in late 2025. Johnson says Best knew and showed him the sets in the cupboard when they took over; the police file has them set aside and refused to Mansell in May 2025.

“Nor have any contractual duty or obligation”

The complaint asks the court for a declaration:

He draws his own line: not the contract, not what Chrystal Law sold, only the sets left in the store. The complaint he verified draws it at nothing. It describes his December 2025 offer of those sets as made “Purely as an accommodation (and without any legal obligation to do so),” and states its terms: “Josh indicated a written apology and other concessions would need to be made and the harassment must stop” (¶ 83).

“Bona fide third-party purchasers”

In the complaint, Johnson asked BAM for the store after its inspector finished the count. In his own telling, the company came to him. To an American Fork police officer on March 8, 2026, on this site’s bodycam page:

And to Matty AppleSeed:

Put the complaint’s own sentences in order. In November 2024 Salem was “BAM’s corporate owned store at that time” (¶ 49). It was counted by “BAM’s representative, Brandon,” who put it under $38,000 (¶ 29). In 2025, it says, Best and Johnson bought it as “bona fide third-party purchasers” (¶ 47). Johnson told the police the price was “whatever you recover it for,” and told Matty AppleSeed it was free; his explanation is that the $80,000 he put into the store “goes towards the purchase of the business” (41:19 on Patreon). The complaint credits the seized store against the Gormans’ $175,000 debt at “an estimated $38,000 paltry value” (¶ 27).

The complaint’s account of the sale, beside BAM’s own record:

REFUTED: BAM’s own record disproves the line. CONTRADICTED: its own books say otherwise.

BAM’s 2025 disclosure document, filed with state regulators, reports no company-owned Oregon store reacquired in 2024 (fact check).

CONFIRMEDThe complaint’s words; Johnson’s, to the officer and on the call; BAM’s balance sheets and its disclosure document’s Item 20; the Keizer police file as published.REFUTEDThat it was an arm’s-length sale to independent buyers without notice. By the complaint’s own paragraphs the store was BAM’s, counted by BAM’s representative, and sold to him and a BAM employee who had already looked over the consignor’s paperwork. In Johnson’s own word it was free. Fourteen months after the sale, BAM’s books still carried its “Corporate Store Costs.”

“BAM’s corporate owned store,” in November. “Bona fide third-party purchasers,” by March. “Free,” on the phone.

“His videos are awesome”

Every plaintiff also sues Reckless Ben for “Intentional Infliction of Emotional Distress” and for “Unjust Enrichment, Accounting and Disgorgement of Profits,” the claim that reaches the money his videos make. Johnson:

He also described being afraid in March, the days the State has charged: “I don’t trust these guys. … What the hell are we going to do? Because he tried coming in the door yesterday. What do I do?” (18:49 on Patreon) That account belongs to the complaint’s civil stalking claim, which Reckless Ben’s motion does not target, and to the criminal case, where the preliminary hearing is Wednesday.

On the extortion the racketeering count charges, his words cut both ways. He cast Mansell’s demand as a threat: “I’m going to get a YouTuber to ruin your life.” (13:43 on Patreon; 6:44 on YouTube) He also said he was glad “we were able to give him all his Legos back and pay him, you know, what he wanted.” (4:25 on Patreon; 3:20 on YouTube) BAM had already apologized to Mansell and agreed to pay.

What falls with it

The complaint is a chain, and his words break its first links. Nearly everything in it rests on three propositions: BAM took the store with no notice of the collection, sold it at arm’s length to independent buyers, and kept none of the Mansells’ Lego. Follow the chain forward.

• Falsity. The complaint’s own authority says statements that are defamation per se have to be false (¶ 146, citing Jacob v. Bezzant). The defamation, false-light and injurious-falsehood claims, and the racketeering count’s defamation and communications-fraud predicates, all need “took the LEGOs” to be false. The man who verified the complaint says Ammon McNeff would not give the Lego back.
• The pattern. Utah’s racketeering statute requires “at least three episodes of unlawful activity.” If the speech episodes fail on truth, the pattern has to stand on what is left: the extortion charge and the raffle-ticket, gift-certificate, impersonation and obstruction allegations, which the call does not touch.
• The extortion charge. Johnson frames Mansell’s demand the way BAM does, “I’m going to get a YouTuber to ruin your life,” and that helps BAM. He also calls paying Mansell “what he wanted” a good outcome, and BAM has since apologized to Mansell, paid him, and asked the court to erase its claims against him.
• The declarations. BAM asked the court to declare that it and Salem Baker acquired the store’s assets “lawfully and in accordance with governing contracts and applicable laws” (¶ 212(a)). Under the commercial code, that is BAM’s to prove, on its own account of a free transfer (below). It asked for a declaration of no duty over the consignment (¶ 212(b)); its verifier says he was “personally responsible” for the sets.
• The independence wall. The complaint says Salem’s buyers “began operating as an independent authorized franchisee of BAM” (¶ 47). By Johnson’s account, the refusal to give the consigned sets back came from the franchisor’s own officers: “Matt and Ammon.” Ammon McNeff told Orem police it “was a corporate store for a period of time.”
• The order. As soon as it sued, BAM sought a temporary restraining order. The motion says it was sought “based on assertions of fact in a Verified Complaint” and that Reckless Ben “had no opportunity to object to the TRO.” The order has since been “amended by stipulation.” One of the complaint’s two verifiers is now on tape against those assertions.
• Damages. Johnson lays his losses on the stores and on the McNeffs, not on Reckless Ben: “90% of them are underfunded,” “I lost like 160 grand on Salem,” “I got done dirty by my boy.”
• The claims BAM bought. In the Mansell settlement, BAM took an assignment of Mansell’s consignment claims and said it “may elect to pursue these claims against those responsible” (Choose Your Claim). Its September amendment says it acquired them “against the former franchisee.” Its own plaintiff has now named who kept the collection: Ammon, “Matt and Ammon,” and himself, “personally responsible” for what was left.
• Racketeering, the other way. The Gormans’ count charges BAM with a pattern of seizing stores and passing them on (the count, graded). Johnson’s account supplies another documented episode: Wesley Chapel, where the plan was “instead of terminating a franchise agreement, let’s find a way for Josh and Brandon to revitalize that store,” and the company he and Best formed was incorporated on the date of the termination letter (the Florida corporation).
• The plaintiffs. One plaintiff now contradicts the complaint, and says a second, Best, “got screwed on the deal too, big time.” A plaintiff who contradicts the pleading is a witness the other side can call.

CONFIRMEDThe complaint’s paragraphs and cited authority; Utah Code 76-17-401; the motion’s account of the restraining order; BAM’s settlement statement and September amendment; the Florida registry.UNRESOLVEDHow a court weighs his words against the complaint he verified.

October 16

Reckless Ben’s motion was filed a week before the call went public. It asks the judge to throw out the racketeering claim and the claims around it:

It does not ask the judge to stop at the complaint. On truth, the motion argues that “the Court can consider undisputed evidence on a UPEPA motion,” citing the statute’s grant of “any evidence that could be considered in ruling on a motion for summary judgment,” and that “the Court can consider Plaintiffs’ own admissions and apologies to the Mansell family in publicly available materials.” It says “BAM’s executives have repeatedly admitted that they still had LEGOs to return to the Mansells.” It attacks the “bona fide purchaser theory” with a recorded call in which a BAM representative says Best “takes on all that consignment.” Johnson’s call is the same kind of material, from a plaintiff who verified the complaint, on the same two points.

Which evidence counts depends on which rules govern, a question for Judge Barlow. Under Utah’s statute the court “shall consider” that evidence (Utah Code 78B-25-106), and once the statute applies it must dismiss a claim on which BAM “fails to establish a prima facie case as to each essential element” (78B-25-107(1)). Under the federal rules, matters outside the complaint either stay out or turn the motion into one for summary judgment, and then “All parties must be given a reasonable opportunity to present all the material that is pertinent to the motion” (Rule 12(d)). On either road, once the judge takes in evidence, BAM has to answer it with evidence.

The complaint itself may not be that evidence. An affidavit or declaration used on summary judgment “must be made on personal knowledge” (Rule 56(c)(4)). The complaint’s two verifications vouch for its allegations “to the best of my knowledge, information and belief.” Neither carries a notary’s jurat, and neither uses the words the law prescribes for a statement not made under oath: “under penalty of perjury” in federal court (28 U.S.C. § 1746), “under criminal penalty under the law of Utah” in the state court where it was filed (Utah Code 78B-18a-106). Whatever BAM files will sit beside a recording of one of the two men who verified the complaint.

The gap runs one way. Against BAM, the complaint is BAM’s own statement, and the rule for a party’s own statements asks for no oath (Federal Rule of Evidence 801(d)(2)(A)). For BAM, it has to meet the rules for testimony.

BAM’s response comes first. Under the court’s rule for motions to dismiss, “A response to a motion must be filed within 28 days after service of the motion,” which makes it due October 16. What its lawyers can say in it is governed by Rule 11: presenting a paper, “whether by signing, filing, submitting, or later advocating it,” certifies that “the factual contentions have evidentiary support,” after “an inquiry reasonable under the circumstances.” The complaint was filed in state court. Defending it in federal court is advocating it, and the circumstances now include a published recording of one of its verifiers.

Dropping the claims would not end the question of who pays. Utah’s anti-SLAPP statute says a voluntary dismissal without prejudice “does not affect a moving party’s right to obtain a ruling on the motion and seek costs, attorney fees, and expenses,” and that a dismissal with prejudice “establishes … that the moving party prevailed on the motion.” A prevailing movant’s fees are not optional: the court “shall award” them. Whether that rule applies in federal court is part of the same question.

CONFIRMEDThe motion’s words; the verification page; Federal Rules of Civil Procedure 11(b), 12(d) and 56(c)(4); 28 U.S.C. § 1746; the court’s local rule, DUCivR 7-1(a)(4)(A); Utah Code 78B-25-106, 78B-25-107, 78B-25-110 and 78B-18a-106.UNRESOLVEDWhether the Utah statute’s procedure applies in federal court, whether the judge takes in evidence beyond the complaint, what weight the verifications carry, and whether the fee rule applies.

What his words are worth in court

Three rules decide how far the call travels.

• Against Johnson himself, nothing more is needed. A party’s own statement comes in against him when it “was made by the party in an individual or representative capacity” (Federal Rule of Evidence 801(d)(2)(A); Utah’s rule reads the same). He is a plaintiff in the federal case and a defendant in the Gormans’.
• Against BAM, the question is whether he is its agent. The rule reaches a statement “made by the party’s agent or employee on a matter within the scope of that relationship and while it existed” (801(d)(2)(D)). BAM’s disclosure document, filed this month, lists him as one of its franchise sellers. If he is BAM’s seller, the rule can reach what he says about the business he sells for it. If he is not, BAM’s own filing lists a seller who says he has “nothing to do with those people.”
• If he is unavailable as a witness, the rule for statements against interest takes over. It admits a statement that when made was “so contrary to the declarant’s proprietary or pecuniary interest or had so great a tendency to invalidate the declarant’s claim against someone else or to expose the declarant to civil or criminal liability” that a reasonable person would have said it only if it were true (Rule 804(b)(3)). The Supreme Court holds it to the sentences that cut against the speaker: it “does not allow admission of non-self-inculpatory statements, even if they are made within a broader narrative that is generally self-inculpatory” (Williamson v. United States, 1994).

Sorted by that rule, the call splits in two. Against him: Best showed him the Lego in the cupboard when they took over; the sets left in the store were his responsibility; the store came free; and, against his own claims in the lawsuit, “I actually do like Ben” and “Ben can go after Bricks and Minifigs all he wants.” Not against him: the lines that move the blame, “Ammon didn’t want to give Bryan his Legos back,” “Matt and Ammon,” “They convinced me.” Those stand only with a second source, and for the refusal the police file supplies it.

That does not make the rest dead weight. The rules leave the lines that move the blame other doors:

• Against Johnson and his company, every line counts. The party rule has no against-interest test, and it covers statements made “in an individual or representative capacity.” He verified the complaint as a Manager of Baker Bricks, one of the plaintiffs, so the same rules reach the company he manages.
• Against BAM, through its own seller list. “90% of them are underfunded” is a franchise seller, named in BAM’s September filing, talking about the stores he sells. That is the agent rule’s cleanest case.
• A residual door for corroborated statements. A statement no exception covers can still come in if it is “supported by sufficient guarantees of trustworthiness,” judged on the circumstances and on “evidence, if any, corroborating the statement,” with notice to the other side (Rule 807). For the refusal, the corroboration is the police file. For his agreement with The Last Relic’s account of the McNeffs, a court can weigh that he asked for exactly that line to be kept private: “don’t make this public, my opinion.”
• As impeachment, truth does not matter. An inconsistent statement is used to test the witness, and the rule’s preconditions fall away for a party’s own words: they do “not apply to an opposing party’s statement” (Rule 613(b)). Every place the call contradicts the complaint he verified is a question he can be asked on the stand.
• His false denials count against him. “We didn’t sell anything,” against his own December text, “There were a couple of sets she had on layaway we sold.” “There’s no Cloud City,” against BAM’s own ledger of two. Each denial is his statement, and each is contradicted by a document.
• A map for subpoenas. The call names what discovery can ask for: the raw recording, the texts he says he sent Mansell, the Wesley Chapel payroll he says he paid himself, the purchase agreement and the count BAM has never produced, and Best’s side of “Brandon got screwed on the deal too, big time.”

CONFIRMEDThe rules’ text, Federal and Utah Rules of Evidence 801(d)(2), 804(b)(3), 807 and 613(b); Williamson v. United States, 512 U.S. 594 (1994).UNRESOLVEDWhether a court treats Johnson as BAM’s agent, and whether he remains available to testify.

The other courtroom, and a question the statute answers

In the Gormans’ own case against BAM, in Utah’s Business and Chancery Court, Johnson is a defendant, named with Best and both McNeffs in the amended complaint, and the amended complaint puts BAM’s handling of the seized store in issue. Utah’s commercial code answers the question that raises:

• “Every aspect of a disposition of collateral, including the method, manner, time, place, and other terms, must be commercially reasonable.” (Utah Code 70A-9a-610(2))
• Once the debtor puts compliance in issue, “the secured party has the burden of establishing” that the disposition complied. (70A-9a-626(1)(b))
• If it cannot, the store is presumed to have brought “the sum of the secured obligation, expenses, and attorney’s fees unless the secured party proves that the amount is less than that sum.” (70A-9a-626(1)(d))
• The statute’s safe harbors are a sale “in the usual manner on any recognized market,” “at the price current in any recognized market,” “in conformity with reasonable commercial practices among dealers,” or one approved by a court or by creditors. (70A-9a-627)

Set BAM’s own account against that. A private transfer of “BAM’s corporate owned store” to its employee and to the inspector who counted it, priced at “whatever you recover it for,” which Johnson calls free. The only other buyer Johnson mentions is the Canby store, which he thinks was offered it first and said no. The buyers’ Oregon business name was registered on 11/15/24, the day after BAM’s notice of termination (¶¶ 6, 27). No recognized market, no market price, no court or creditor approval. BAM’s evidence of value is its buyer’s count, “less than $38,000,” against a $175,000 debt (¶¶ 27, 29), and the count does not hold still: Best told the Keizer detective he reported about $17,000 to corporate that night, and estimated about $32,000 in the same interview. Matt McNeff told the Keizer detective, in the detective’s summary, that “if the assets of the store were in excess of what was owed, they would be required to pay that money back.” Under the statute the burden sits with BAM: it must prove every aspect of that sale was commercially reasonable, or the law presumes the store covered the whole debt.

The complaint’s description of the credit raises a second question the statute answers. BAM, it says, repossessed the store and “credited an estimated $38,000 paltry value thereof as an offset to the unpaid $175,000 debt” (¶ 27). If that credit was BAM keeping the collateral against part of the debt, the code allows it only if the debtor “agrees to the terms of the acceptance in a record signed after default” (70A-9a-620(1), (3)(a)), and otherwise “A purported or apparent acceptance of collateral under this section is ineffective” (70A-9a-620(2)). The complaint pleads a repossession “pre-scheduled” with Chrystal Law. It pleads no signed agreement to a $38,000 credit. If instead the sale to Johnson and Best was the disposition, the burden above applies to it. On either reading, the statute puts the proof on BAM.

CONFIRMEDThe statute’s text, Utah Code 70A-9a-610(2), 620, 626(1) and 627; BAM’s own paragraphs and Johnson’s words; the detective’s summary as published in the Keizer file.

“I have nothing to do with those people”

In June, BAM told the wire that “Bricks & Minifigs Parts Ways with… Brandon Best and Joshua Johnson” (the June statement). In September it filed a disclosure document listing nine franchise sellers at its Provo headquarters, the McNeffs first and Johnson sixth (the amendment). On the call, asked why he is in business with Ammon McNeff: “I’m not. I have nothing to do with those people.” (54:34 on Patreon; 22:28 on YouTube) And: “I don’t have anything to do with Matt and Ammon.” (58:02 on Patreon; 23:15 on YouTube) He is still their co-plaintiff.

Sources. BAM Franchising, Inc. v. Schneider, verified complaint filed May 27, 2026, Utah Fourth District No. 260402353, removed to D. Utah No. 2:26-cv-00593, ¶¶ 6, 22, 27, 28, 29, 33, 41, 43, 45, 46, 47, 48, 49, 51, 52, 82, 83, 135(e), 146 and 212, and its verification pages. Reckless Ben’s Special Motion for Expedited Relief and for Partial Dismissal, ECF 37, filed September 18, 2026. Federal Rules of Civil Procedure 11(b), 12(d) and 56(c)(4); 28 U.S.C. § 1746; Local Rules of Civil Practice, District of Utah, DUCivR 7-1(a)(4). Federal Rules of Evidence 613(b), 801(d)(2), 804(b)(3) and 807; Williamson v. United States, 512 U.S. 594 (1994). Utah Code 78B-25-106, 78B-25-107, 78B-25-110, 78B-18a-102, 78B-18a-104, 78B-18a-106, 76-17-401 and 70A-9a-610, 620, 626 and 627. BAM Franchising, Inc., 2025 franchise disclosure document, Item 20 Table No. 4 and balance sheet as of March 31, 2025; September 2026 amendment, Item 3 and balance sheet as of May 31, 2026. Matty AppleSeed, “1 hour Call with Josh Johnson,” Patreon, September 25, 2026, and “Josh Johnson Told Me His Side | BRICKS & MINIFIGS,” YouTube, September 26, 2026. American Fork Police Department body camera, March 8, 2026. Orem Police Department body camera, March 11, 2026. Keizer Police Department case file KZP24020132. BAMF Salem 1, LLC v. BAM Franchising, Inc., Utah Business and Chancery Court No. 260200029, first amended complaint. BAM’s June statement and its August settlement statement. Everyone named here is presumed to have acted lawfully.

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