It is the core pleading for Utah Case No. 260402353 and frames the allegations in the Bricks & Minifigs civil case.
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Wm. Kelly Nash (4888)
[email redacted]
Justin T. Rich (18519)
[email redacted]
Mina S. Ghobrial (20214)
[email redacted]
DENTONS DURHAM JONES PINEGAR, P.C.
1557 W. Innovation Way, Ste. 400
Lehi, Utah 84043
Telephone [phone redacted]
Attorneys for Plaintiffs
IN THE FOURTH JUDICIAL DISTRICT COURT IN AND FOR
UTAH COUNTY, STATE OF UTAH
Bricks & Minifigs FRANCHISING, INC., a Delaware VERIFIED COMPLAINT
corporation; AMMON MCNEFF, an
individual; MATTHEW MCNEFF, an (Tier 3)
individual; JOSH JOHNSON, an individual;
BRANDON BEST, an individual; BAKER
BRICKS, LLC, a Utah limited liability
company, and dba SALEM-BAKER BRICKS Case No.:
INC., an Oregon corporation,
Judge:
Plaintiffs,
vs.
BENJAMIN PAUL SCHNEIDER, an
individual, dba and aka “RECKLESS BEN”;
RECKLESS BEN LLC, a California limited
liability company; BRYAN MANSELL, an
individual; VICTOR NGUYEN, an individual;
and DOES 1-15,
Defendants.
Plaintiffs Bricks & Minifigs, Inc. (“Bricks & Minifigs”), Ammon McNeff (“Ammon”), Matthew
McNeff (“Matthew”), Josh Johnson (“Josh”), Brandon Best (“Brandon”), Baker Bricks, LLC
UC_8981990.4
(“Baker”) dba Salem-Baker Bricks, Inc. (“Salem Baker”) (collectively, “Plaintiffs”), through
counsel, file this Complaint against Defendants Benjamin Schneider, dba and aka “Reckless
Ben” (“Schneider”), Reckless Ben LLC (“Reckless Ben”), Bryan Mansell (“Bryan”), Victor
Nguyen (“Victor”) and DOES 1-15 (collectively, “co-Defendants”) and for causes of action
assert and allege as follows:
Parties, Jurisdiction, and Venue
1. Bricks & Minifigs is a corporation organized and existing under the laws of the State of
Delaware, doing business throughout the United States, including its principal place of business
in Utah County, State of Utah.
2. Ammon is a Utah resident, currently residing in Utah County, Utah and an owner
and executive officer of Bricks & Minifigs.
3. Matthew is a Utah resident, currently residing in Utah County, Utah and an owner
and executive officer of Bricks & Minifigs. Ammon and Matthew are referred to collectively, as “McNeffs”.
4. Josh is a Utah resident, currently residing in Utah County, Utah and an owner and
executive officer of Baker.
5. Brandon is a Utah resident, currently residing in Salt Lake County, Utah and an
owner and executive officer of Baker.
6. Baker is a Utah limited liability company (organized on 5/2/24) dba Salem Baker
in Oregon (registered on 11/15/24), and an authorized franchisee of Bricks & Minifigs engaged in business in
the State of Oregon, and also doing business in Utah County, Utah.
7. Upon information and belief, Schneider is an individual, who resides in or around
Los Angeles, California (at 5013 ½ Marathon Street, Los Angeles, CA 90027) and who operates
under the dba, aka and online persona of “Reckless Ben” as an online paid streaming content
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creator and publisher (i.e., through YouTuber, Patreon, etc.), who does business throughout the
United States and in Utah County, Utah.
8. Upon information and belief, Reckless Ben LLC is a limited liability company
organized and existing under the laws of the State of California, with a principal place of
business at 1407 N Edgemont St., Los Angeles, California 90027, and doing business in Utah
County, Utah, which is owned, controlled and/or operated by Schneider and Schneider Group
(i.e., defined below).
9. Schneider and Reckless Ben LLC and their affiliated entities, employees,
contractors, associates, representatives, assistants and legally cognizable agents, including Victor
Nguyen (and as yet unknown DOE 1-15 defendants), along with the Schneider Group’s affiliated
entities and participants in the Enterprise (the “Schneider Group”), conspired together and with
co-Defendants and Chrystal Law (“Chrystal”) and Benjamin Gorman (“Benjamin”) (also
potential DOE 1-15 defendants) and aided and abetted to create, participate in and effectuated a
scheme and enterprise of unlawful activities over a substantial time period through multiple
distinct episodes in order to defraud, manipulate, threaten, trespass, extort, injure and damage
Plaintiffs, including based on a sustained pattern of unlawful activities, including the
racketeering and profiteering and other misconduct described herein, thereby injuring and
damaging Plaintiffs in Utah County, Utah and other locations throughout the United States
(“Enterprise”).
10. Co-Defendants conspired with Chrystal and Benjamin to participate in support
and aid/abet the Enterprise and misconduct described herein in or affecting Plaintiffs in Utah
County, Utah and other locations throughout the United States.
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