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Vol II

2025-02-10
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Day Overview

Volume II covers the full first day of jury trial proceedings in trial2 (February 10, 2025). The day began with pre-jury housekeeping disputes, including defense counsel Udoibok raising Ms. Bock's lack of electronic device access and complaints about the government's alphabetical exhibit naming convention, both of which the court denied. Preliminary jury instructions were then given, followed by all three opening statements. The government's opening (Bobier) was powerful and detailed, framing the case as the largest COVID fraud in U.S. history — $250 million stolen through fraudulent meal claims — with Bock as architect and Said as the biggest individual operator. Bock's defense (Udoibok) countered that MDE failed in its oversight duties, that site operators lied to Bock, and that the evidence will show she is a convenient scapegoat. Said's defense (Montez) was brief, urging the jury to consider the extraordinary COVID context and pay close attention to who specifically did what. The government then called Postal Inspector Matthew Hoffman, who described the January 20, 2022 search of the Feeding Our Future office (approx. 270 boxes of documents and 60+ electronic devices) and authenticated a large volume of records now in evidence. Finally, MDE Director Emily Honer began direct examination, covering her background, the structure of the child nutrition programs (CACFP, SFSP, National School Lunch Program), how COVID waivers expanded participation, and MDE's growing alarm at Feeding Our Future's explosion of for-profit restaurant sites and astronomical claim volumes starting in spring 2020. Her direct examination was not completed and continues into Volume III. Defense counsel should pay close attention to Honer's testimony about MDE's own decision-making, the restraining order that Feeding Our Future obtained forcing MDE to lift its stop-pay, and the significant concessions the defense can draw from MDE's regulatory failures.

Government Strategy

The government used Volume II to lay the complete factual architecture of its case. Through opening statement, AUSA Bobier painted a vivid narrative of a brazen $250 million fraud on the Federal Child Nutrition Program, positioning Aimee Bock as the all-controlling gatekeeper and Salim Said as the single largest site operator. The government then called its first witness, Postal Inspector Hoffman, to authenticate and admit the massive documentary haul from the January 20, 2022 search of the Feeding Our Future office — establishing the evidentiary foundation for the entire paper trail. The second witness, MDE Director Emily Honer, began detailed testimony about how the programs worked pre-COVID, how COVID waivers changed the rules, and how MDE grew alarmed at Feeding Our Future's explosive and implausible site growth and claim volume starting in spring 2020. The government is building toward showing that MDE raised red flags early, Bock evaded and deflected every concern, and ultimately MDE had to refer the matter to the FBI.

Strategic Notes for Defense Counsel

- MDE IS THE DEFENSE'S BEST WEAPON: Emily Honer's cross-examination is the highest-priority opportunity in this volume. MDE paid hundreds of millions of dollars in claims without ever seeing underlying documentation, accepted Bock's October 2020 explanation that FOF was staffing for-profit sites (allowing them to continue), lost a TRO fight when it tried to implement a stop-pay, and (per defense opening) told Bock it would 'take no position on fraud' when she reported sites. Defense counsel should cross Honer with the specific email from MDE refusing to investigate reported fraud — if that document exists, it is case-defining. - EIDLEH IS THE KEY THIRD-PARTY CULPRIT: Udoibok's opening consistently pointed to Abdelahi Eidleh (FOF's community-facing employee who spoke Somali) as the person who actually recruited sites, took bribes himself, and manipulated Bock. If your client had any contact with Eidleh rather than Bock directly, this is a major defense theme. Watch for Eidleh's cooperation deal and prior statements carefully. - THE TRO IS UNDEREXPLOITED: Feeding Our Future went to court, filed a lawsuit alleging discrimination, and obtained a temporary restraining order stopping MDE's stop-pay. A federal judge found enough merit to issue emergency relief. This is not the behavior pattern of a fraud defendant — it is the behavior of an organization fighting what it believed were unjust regulatory actions. Defense counsel should make this a centerpiece. - AUTHENTICATE-EVERYTHING STRATEGY IS UNCONTESTED: The defense made no objection to the mass authentication of hundreds of exhibits through Hoffman. If any of these documents relate to defense counsel's client, he should investigate whether any specific exhibits have chain-of-custody vulnerabilities given the 270-box mass seizure and Hoffman's admitted lack of direct oversight during the search. - COOPERATORS WILL BE THE REAL THREAT: The government's opening prominently promised cooperating witnesses who will testify about pay-to-play kickbacks, fake rosters, and fake invoices. Defense counsel must obtain all cooperation agreements and prior statements immediately. The defense theory (people lied to Bock) depends on impeaching cooperators with their prior inconsistent statements and the financial incentives of their deals.

Witnesses
Matthew Hoffman
U.S. Postal Inspector with over 20 years of experience; assisted in executing the January 20, 2022 search warrant at the Feeding Our Future office in St. Anthony, Minnesota.
Other Government Government
Direct Examination

Hoffman described executing the search warrant at the Feeding Our Future third-floor office with a team of approximately 25-30 agents from USPS, FBI, and IRS Criminal Investigations. The search lasted approximately seven hours and produced roughly 270 banker's boxes of documents and over 60 electronic devices. He then authenticated and sponsored the admission of a massive volume of records (B, C, E, G, H, I, J, K, L, M, P, Q, S, A, AA series exhibits) tied to Safari Restaurant, ASA Limited, Olive Management, Stigma-Free sites (Willmar, Mankato, Waite Park, St. Cloud, St. Paul), Horseed, Brava Restaurant, Bet on Better Future/Gaur, Feeding Our Future Arcad/Sir Boxes, Southcross, Southside Youth, Action for East African People, Shafii Tutoring, Sambusa King, Future Leaders, Alif Halal, Xogmaal Media, Nawal Restaurant, Somali America Faribault Education, and additional records.

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Approximately 270 banker-style boxes of documents and over 60 digital devices were seized from the Feeding Our Future office on January 20, 2022. The office had 22 individual offices across two floors. — Establishes chain of custody for all documentary evidence; the volume underscores the scale of the alleged fraud and the scope of the government's investigation. [p. 308]
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Exhibit B50: A file folder labeled 'Safari Restaurant, 310 Fourth Avenue South, Minneapolis, Minnesota 55408' found at the Feeding Our Future office, containing a CACFP vended meal contract signed by Aimee Bock (as sponsor) and Salim Said (as owner/vendor). — Directly links both defendants through their signed contract, underpinning the conspiracy and bribery counts. [p. 315-316]
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The site team leader for the search was Uri Rosenwald of the FBI. Hoffman personally spoke to only two employees: Qeys Mohamed (IT support) and Coley Flynn. — Hoffman had limited direct knowledge of the office and its operations; his testimony is purely foundational for evidence authentication. [p. 331]
Cross-Examination

Udoibok's cross was limited and largely ineffective. He established that Hoffman did not know who pre-assembled the boxes found in the office, could not identify which boxes came from which specific rooms, and personally spoke to only two employees. He also highlighted an 'Obstruction Permit' document (p. 8 of B50) found in the Safari file that Hoffman could not explain — though the court sustained a relevance/foundation objection before that line could be developed. Colich declined to cross-examine.

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Hoffman could not identify which specific office the pre-existing boxes were found in, stating: 'I can't tell you today which office these specific boxes were seized out of.' — Opens a limited chain-of-custody argument — though the broader admissibility is not seriously threatened since agents labeled rooms and documented locations. [p. 335-336]
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An 'Obstruction Permit' document appeared on page 8 of Exhibit B50 (Safari Restaurant file). Hoffman did not know why it was there or what it was. The court sustained a relevance/foundation objection before Udoibok could develop it. — The defense was cut off before developing this point. A more aggressive cross could potentially question document integrity within that file, or suggest the files were not pristine. Worth revisiting if B50 is challenged. [p. 336]
Vulnerabilities Hoffman's knowledge is entirely foundational — he was not a case agent, did not investigate the fraud substantively, and can only authenticate what was seized and where. He admitted he was conducting interviews during the search and was not personally watching the search teams. He does not know who assembled the pre-existing boxes in the office or their specific contents. He cannot testify about what the documents mean, whether they are fraudulent, or what happened at any of the sites. His cross-examination was largely untouched.
For Defense Counsel If defense counsel's client's files were among those seized, challenge the provenance of specific documents within the mixed file folders — Hoffman admitted he cannot tie specific items to specific rooms. Also press on the chain of custody from seizure to FBI storage to trial exhibit: Who scanned the documents? Who ensured they were not mixed? The 270-box haul and 60+ devices create real opportunities to question the integrity of any specific exhibit extracted from that mass.
Emily Honer
Director of Nutrition Program Services at the Minnesota Department of Education; oversaw the CACFP and SFSP programs and was a primary MDE official who raised concerns about Feeding Our Future's site growth and claims from 2019 onward.
MDE Government
Direct Examination

Honer's direct examination (which continues into the next volume) covered three main areas. First, she gave a detailed tutorial on how the child nutrition programs work: the three-layer structure (USDA → MDE → sponsor → site), how sponsors submit claims on behalf of sites, how MDE pays reimbursements based on sponsor submissions without independently verifying documentation, and how sponsors are supposed to monitor sites. Second, she described the impact of COVID-19 waivers, including the switch from school lunch to summer food, the relaxation of congregate requirements, and the expansion of area eligibility. Third, and most critically for the case, she described MDE's growing alarm at Feeding Our Future's explosive growth beginning in spring 2020: brand-new sites appearing during a pandemic, for-profit restaurants being enrolled, astronomical claim volumes (Safari claiming 5,000-6,000 meals/day by July-October 2020), and Bock's pattern of deflection and regulatory loophole-finding. She admitted key emails in evidence (F2, F3, F5, F6, F7) showing the back-and-forth in which she told Bock for-profit sites were not eligible and Bock responded by claiming Feeding Our Future was staffing them. She also admitted extensive CLiCS data (V1-V25, V28, V29, V32-V43) showing the actual claim submissions.

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In July 2020, Safari Restaurant claimed 154,810 total meals (lunch and morning snack) over 31 days — approximately 5,000 kids per day. By October 2020, it had grown to 185,849 total meals (breakfast and lunch) in 31 days — approximately 6,000 kids per day. — These specific numbers, drawn directly from the government's CLiCS system, are the core quantitative proof of inflated claims. Honer's reaction ('absolutely' concerning) gives the numbers official credibility. [p. 402-403]
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MDE does not collect documentation when processing a claim: 'We do not ask for them when we get the claim, no. We rely on the sponsor.' The sponsor keeps the records for three years. — This is a two-edged sword. For the government it shows the system relied on sponsor honesty. For the defense, it shows MDE processed and paid these claims without ever seeing the underlying records — undermining any claim that MDE was deceived in real-time. [p. 357-358]
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On October 20, 2020, Bock sent Honer (Exhibit F7) claiming Feeding Our Future was staffing all the for-profit restaurant sites — including Safari, ASA Limited, Brava, Olive Management, Lido, S&S Catering — with its own nonprofit volunteers. Honer testified: 'I found it difficult to believe that an organization could switch gears that quickly.' — This email is central to the government's false statement theory. The defense will argue Bock's explanation was legally sufficient, and that MDE accepted it. Honer's credibility on this point is a key battleground. [p. 418-420]
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MDE issued a serious deficiency notice to Feeding Our Future in January 2021 for loss of IRS nonprofit status and failure to submit a required federal single audit. MDE then implemented a 'stop pay' on claims. Feeding Our Future obtained a temporary restraining order and MDE ultimately lifted the stop pay. — The TRO and MDE's capitulation is a major defense argument: Bock used the legal system legitimately to challenge MDE's action, which is not the behavior of someone hiding fraud. It also shows MDE's regulatory response was weak and inconsistent. [p. 427-434]
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In December 2020, Feeding Our Future's pending applications exceeded 50,000 children per day — the federal regulatory limit above which MDE cannot approve without special authority. MDE began denying applications; Feeding Our Future appealed. — Shows the scale of the alleged fraud dwarfed anything MDE had seen. Also shows MDE found regulatory mechanisms to push back, which Bock contested — relevant to intent. [p. 425-426]
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Honer testified that MDE made a referral to the FBI (specifically to SA Jared Kary) in spring 2021 after the stop-pay was lifted, based on concerns about site types, claim amounts, and money going out. — Establishes the investigation trigger and the FBI nexus, and shows MDE's escalation to criminal referral only after its own administrative remedies were exhausted. [p. 435]
Cross-Examination

Cross-examination of Honer was deferred to Volume III — she remained on the stand at the end of Volume II. No cross has yet occurred.

Vulnerabilities Honer is the government's most important lay witness so far, but she has substantial vulnerabilities. (1) MDE paid all claims without seeing underlying documentation — she acknowledged this explicitly. MDE processed and approved massive claims month after month and cannot disclaim responsibility for the payments. (2) The Feeding Our Future lawsuit resulted in a TRO that MDE lost — a court found at least temporary merit in Bock's challenge of MDE's stop-pay. (3) Honer admitted she found Bock's October 2020 'Feeding Our Future is staffing these sites' explanation 'difficult to believe' but could not stop the sites — meaning MDE acquiesced. (4) Udoibok's opening specifically referenced an email showing MDE told Bock they 'would take no position in fraud' when she reported a site. If this email exists, it is devastating to Honer's narrative. (5) Honer has an obvious institutional interest in minimizing MDE's own failures. (6) Her 2019 observation that Feeding Our Future lacked financial staff — yet MDE continued to pay claims for years — shows MDE's oversight was hollow. (7) MDE reauthorized organizations that Bock had terminated for suspected fraud (per defense opening) — if Honer knew this, her credibility on MDE's diligence is compromised.
For Defense Counsel Defense counsel should cross Honer aggressively on: (1) MDE's own failures — it paid hundreds of millions in claims without ever requesting documentation; (2) The TRO victory — a court found Bock had a colorable legal claim against MDE's stop-pay; (3) Specific emails where MDE told Bock they would not investigate fraud she reported; (4) MDE re-enrolling sites Bock had terminated; (5) The USDA finding that MDE had made improper reimbursements (referenced in Udoibok's opening — letter from Daron Korte in October 2020); (6) The fact that MDE approved all these applications — the applications had to go through MDE, not just Bock. The defense theme is: MDE had independent oversight obligations, failed them, and is now shifting blame.
Key Evidence
Type Exhibit Description Page Challenge Opportunity
Document Gov. Ex. AA1 Photographs taken by law enforcement during the January 20, 2022 search of the Feeding Our Future office at 3055 Old Highway 8, Suites 312 and 229, St. Anthony, Minnesota. Shows hallways, lobby, filing cabinets, offices including the Claims Department (Room G) and Aimee Bock's office (Room M). [p. 309] Photos taken after entry by law enforcement; the state of the office at the time of search reflects a moment in time after investigators had already begun moving through it. The location of specific boxes cannot be mapped to specific rooms by Hoffman.
Document Gov. Ex. B50 62-page file folder labeled 'Safari Restaurant, 310 Fourth Avenue South, Minneapolis, Minnesota 55408,' found at the Feeding Our Future office. Contains a CACFP Contract for Vended Meals signed by Aimee Bock (as FOF authorized representative) and Salim Said (as owner/vendor of Safari), dated June 1, 2020 through June 1, 2021. [p. 314-316] An unexplained 'Obstruction Permit' document appeared at page 8 of this exhibit; Hoffman could not explain it. Defense can argue file integrity is not guaranteed when 270 boxes of documents were co-mingled during a mass seizure.
Document Gov. Ex. B51-B76 Additional file records from the Feeding Our Future office all relating to Safari Restaurant. [p. 318] Same chain-of-custody concerns as B50; authentication rests entirely on Hoffman's general representation that these were 'seized that day.'
Document Gov. Ex. C35-C53 Records related to ASA Limited seized from Feeding Our Future. [p. 319-320] Records found at Feeding Our Future, not at ASA Limited's premises; authenticity of each specific document within the batch could be contested.
Document Gov. Ex. E40-E57 Records related to Olive Management (St. Cloud site) seized from Feeding Our Future. [p. 320] No specific document content described at this point in testimony; authentication is purely through Hoffman's broad sweep.
Document Gov. Ex. G40-G53, H40-H57, I20-I29, J30-J35, K10-K18 Records related to Stigma-Free International sites (Willmar, Mankato, Waite Park, St. Cloud, St. Paul) and Horseed, all seized from Feeding Our Future. [p. 320-323] Same chain-of-custody and document integrity issues as all records from the mass seizure.
Document Gov. Ex. B4 April 13, 2020 email from Aimee Bock to MDE (Kendra Pace and mde.fns@state.mn.us) with subject 'Site application Safari,' attaching: an MDE Submission Verification signed by Aimee Bock; and a CACFP Program Agreement between Feeding Our Future and Safari (signed by both Salim Said as owner and Aimee Bock as founder/executive director on April 10, 2020). [p. 382-389] The agreement was lawful on its face. Defense argues that signing the contract does not prove knowledge of subsequent fraud by site operators.
Data/Summary Gov. Ex. V1-V25, V28-V29, V32-V43 CLiCS system data showing Feeding Our Future's site applications and monthly claim submissions for Safari Restaurant and associated sites from April 2020 through the program's end. Includes claims showing: April 2020 — 1,179 avg daily attendance, 15,322 meals; May 2020 — 2,928 avg daily attendance, 90,725 total meals; July 2020 — 154,810 total meals (approx. 5,000/day); October 2020 — 185,849 total meals (approx. 6,000/day). Also includes the Safari site application and vended meal contract (V1), signed by Bock and Said. [p. 379-403] CLiCS shows what was submitted by FOF, not whether meals were actually served. Defense can argue the data only proves what was claimed, not fraudulent intent. The CLiCS data must be paired with evidence that meals were not served, which the government will presumably provide through surveillance, cooperator testimony, and community witnesses.
Document Gov. Ex. F2, F3, F5, F6, F7 Email chain from September-October 2020 between MDE (Honer) and Aimee Bock regarding for-profit restaurant sites. F2 (Sept. 25) — Honer notifies Bock that for-profit CACFP at-risk sites are not allowed. F3 (Oct. 2) — Honer seeks clarification on specific sites. F5 (Oct. 7) — Bock responds with a letter of request for SFSP restaurants. F6 (Oct. 14) — Honer tells Bock for-profit distribution sites cannot participate in either CACFP or SFSP and will be closed by Oct. 31. F7 (Oct. 20) — Bock emails Honer claiming Feeding Our Future is staffing all the for-profit restaurant sites (including Safari, ASA, Brava, Olive Management, Lido, S&S Catering) with its own nonprofit volunteers. [p. 409-420] Bock's October 20 response may have been legally accurate or at least a good-faith interpretation of program regulations. MDE accepted the explanation — no action was taken to close the sites. Honer testified she 'found it difficult to believe' but could not articulate a regulatory basis to reject it. The defense can argue this shows Bock navigated ambiguous rules in good faith and that MDE's acquiescence shows the explanation was legally sufficient.
Legal Rulings & Objections
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Court denied Udoibok's request to modify the electronic device prohibition for Aimee Bock, allowing her only to use defense counsel's computer to assist with trial preparation. — Bock, who the defense described as 'very skillful' with computers and for whom the case is primarily electronic, is severely hampered in her ability to assist counsel during trial. This is a structural disadvantage that may affect the quality of cross-examination. [p. 227-228]
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Court denied Udoibok's request to require the government to change its alphabetical exhibit naming convention, finding the issue should have been raised at the pretrial conference. — Defense is stuck navigating a multi-series exhibit system (A through AA+) with hundreds of exhibits. This logistical burden disadvantages a resource-constrained defense team. [p. 227]
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Court denied Colich's implicit request for a discovery cutoff, declining to impose a deadline on the government's ongoing witness interview reports and discovery production during trial. — Defense will continue to receive new discovery during trial and must review it in real time. Colich flagged this as a serious concern, noting 67,000+ documents had already been produced. [p. 226-227]
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Relevance and foundation objection sustained by the court when Udoibok asked Hoffman about an 'Obstruction Permit' document found in the Safari file (B50, page 8), before Udoibok could establish what the document was. — Defense was cut off from developing a potentially useful chain-of-custody or document-integrity argument. Defense counsel should consider whether the 'Obstruction Permit' can be independently developed with a proper foundation. [p. 336]
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Objection by Colich overruled when Honer testified that opening a new child nutrition program site during a pandemic 'didn't seem like the right time' — Colich objected as argumentative. — Court allowed Honer to express opinion-colored testimony about the implausibility of Feeding Our Future's expansion, suggesting the court will permit MDE witnesses to offer lay opinions about program reasonableness. [p. 376]
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Objection by Udoibok sustained — leading question — when AUSA Thompson asked a leading question about the area eligibility requirement for the Summer Food Service Program. — Court is enforcing the no-leading rule on direct, which is standard. No strategic significance. [p. 370]
Prior Defense Performance

Overall, defense performance on Day 1 was mixed but showed some strategic awareness. Udoibok's opening was the strongest defense moment of the day — he effectively planted seeds about MDE's failures, Eidleh's manipulation of Bock, Bock's limited contact with sites, and the Monday.com/CenterPilot/CLiCS multi-step claims process that allegedly insulated Bock from direct knowledge of fraud. The specific examples of sites Bock terminated for fraud (many of whom pled guilty) was a clever move to flip the government's narrative. However, Udoibok's opening was organizationally chaotic — jumping between PowerPoint slides and named individuals without a clear through-line — which may have lost jurors. Montez's opening for Said was extremely brief and essentially conceded that evidence of a crime exists, relying entirely on 'who did it.' Cross-examination of Hoffman was weak: Udoibok failed to develop the chain-of-custody issue on the 'Obstruction Permit,' wasted time on boxes he could not identify, and got no meaningful concessions. Cross-examination of Honer is pending. The defense's most glaring omission is the lack of any objection to the avalanche of exhibits authenticated by Hoffman — no objection was made to any of the B, C, E, G, H, I, J, K, L, M, P, Q, or S series exhibits. This wholesale admission is a significant missed opportunity, particularly where Hoffman acknowledged he was not personally watching the search teams when exhibits were collected.