Vol IV
On February 12, 2025, the government presented the entirety of FBI Special Agent Jared Kary's direct examination and a substantial portion of the cross-examination by defense counsel Udoibok (Bock's attorney), with Montez's cross for defendant Said deferred to the next day. Kary is a case agent with 17 years at the FBI assigned to the complex financial crimes squad and served as the organizing witness who tied together all prior evidence into a coherent fraud narrative. The most significant moments included: (1) Kary's testimony that pole cameras placed at Safari Restaurant (Dec. 8–Jan. 20, 2022) averaged only 40 visitors per day while the site claimed up to 6,000 meals daily; (2) the introduction of emails showing Abdihakim Ahmed — Said's ASA partner — using an Excel formula to auto-generate fake children's names with random ages between 7 and 17 for required attendance rosters; (3) Kary testifying that Safari Restaurant received over $12.1 million through Feeding Our Future, the single highest-paid site; and (4) the court mid-cross issuing a supplemental wire fraud instruction after Udoibok's questioning created juror confusion about whether the wires themselves needed to be false. Defense counsel should pay close attention to Udoibok's cross-examination, which surfaced genuine weaknesses: the pole camera only covered the front of Safari (not a side/back entrance), surveillance ran for only about one month, Kary admitted he did not know FOF's number of staff or volunteers, and Kary could not cite a law or regulation that would have required Bock to refuse submitting invoices consistent with approved site applications.
Volume IV was dominated by the government's comprehensive direct examination of FBI Special Agent Jared Kary, one of the lead case agents. The government used Kary to synthesize the entire arc of the investigation — from its spring 2021 origins through the January 20, 2022, overt search and seizure operation — and to introduce a sweeping array of bank records, emails, surveillance footage, and summary charts. The core narrative the government built was that Safari Restaurant (Salim Said) and ASA Limited (Said plus partners) submitted fraudulently inflated meal counts claiming to feed thousands of children per day, that Aimee Bock as FOF executive director personally signed checks transmitting millions in federal funds to Said's entities, and that pole camera surveillance flatly contradicted the claimed meal volumes at both sites. The government also introduced the specific wire fraud counts (Counts 2, 4, 5, 8, and 12) tied to particular emails. A secondary goal was establishing Said's interconnected web of entities (Safari, Cosmopolitan, ASA, Salim Limited, 3017 LLC) and showing money flowed from federal funds into luxury real estate and vehicles rather than food purchases.
- The auto-generated fake children roster evidence (Exhibits C20-C26) is the government's most devastating piece of evidence, but it was entirely between Ahmed and Said — never sent to Bock. Defense counsel must exploit this knife-edge distinction aggressively: Said's knowledge of fabrication cannot be imputed to Bock without more evidence, and the government has not yet shown that bridge. - Kary admitted critical ignorance about the regulatory framework: he does not know what inspections FOF was required to conduct, whether pandemic waivers relaxed those requirements, or what law obligated a sponsor to refuse invoices consistent with approved applications. Defense counsel should retain a federal child nutrition program regulatory expert to testify about the actual SFSP/CACFP sponsor obligations — if Bock operated within (or close to) those requirements, the fraud theory depends entirely on what she actually knew. - The pole camera gap (no coverage of side/back entrance at Safari, only ~one month of footage) is a real evidentiary hole. For Salim Said's cross, Defense counsel should consider whether a site inspection, architectural diagram, or testimony about distribution patterns at Safari (e.g., community organizations, Ramadan-related bulk pickup) could create reasonable doubt about the surveillance conclusions. - The court's supplemental wire fraud instruction mid-trial is a warning flag: the jury has now been told twice that the wire need not itself be false — only in furtherance of the scheme. defense counsel's defense for Bock on the wire counts must therefore focus on whether she had the requisite fraudulent intent and knowledge of the scheme, not whether individual emails were truthful. - Eidleh's flight to Somalia is a double-edged sword. The government will use his absence as evidence of guilt-by-association with the scheme. Defense counsel should instead frame Eidleh as the operational mastermind — he ran the claims process, brought in sites, prepared meal count documentation, and vanished the moment law enforcement appeared. A defense theory that Bock was misled by her own program manager is available and has documentary support in the emails where Eidleh presents information to Bock for approval rather than Bock directing Eidleh.
Kary provided a sweeping chronological overview of the investigation from spring 2021 through trial, introduced the MDE CLiCS summary data showing Safari Restaurant as the highest-paid site at $12.1 million for 3.9 million claimed meals, introduced over 260 bank records for 3,000+ financial accounts, presented pole camera surveillance footage showing only roughly 40 people per day at Safari versus claimed 6,000 meals, and walked the jury through emails showing auto-generated fake children rosters and the specific wire fraud count emails. He testified about the January 20, 2022, search and seizure operation at 27 locations yielding $50+ million in seized assets.
Udoibok's cross was lengthy (pages 839–921) and had some effective moments but overall left the most damaging evidence unrebutted. The strongest defense points were: (1) the pole camera only covered the front of Safari, not the side/back entrance, so deliveries by vehicle from another angle could not be ruled out; (2) Kary conceded he did not know FOF's number of employees or volunteers, nor the regulatory frequency of site inspections; (3) many of the most incriminating emails (ASA fake roster generation) were never sent to Bock; (4) Kary could not cite any law that would have obligated Bock to refuse submitting invoices consistent with approved applications; and (5) Kary admitted that the search warrant at FOF yielded 4.4 million pages and no evidence of document destruction, suggesting the organization was not hiding anything. Cross was partially blunted by the court's mid-cross wire fraud instruction and by Kary's disciplined refusal to concede any benign interpretation of the overall pattern.
| Type | Exhibit | Description | Page | Challenge Opportunity |
|---|---|---|---|---|
| Data/Summary | Gov. Ex. X1 | FBI-created summary chart of MDE CLiCS data showing Feeding Our Future claims by site — both dollar amounts and meal counts — for 2018–2021. Total claims: $246 million; total meals: 91 million. Safari Restaurant is #1 at $12.1M and 3.9M meals. | [p. 697-700] | The chart is a government-created summary derived from MDE data (Exhibit V43). Defense could challenge whether the underlying CLiCS data accurately captured actual approved payments versus submitted claims, and whether the chart fairly represents all sites or cherry-picks comparisons. Foundation objection was overruled at admission. |
| Surveillance | Gov. Ex. B48, B48a-B48i | One-minute video clip and nine still images from FBI pole camera at Safari Restaurant (Fourth Avenue South, Minneapolis) from December 10–31, 2021. Shows a street-level view of the front/side of the restaurant with minimal foot traffic on days when Safari claimed 3,495–3,498 meals served. | [p. 772-780] | Camera covered only the front/side of the building; side entrance was not monitored. Footage runs only approximately five to six weeks in late 2021 — not representative of the entire 2020–2021 fraud period. Drive-through or back-door delivery by truck cannot be excluded. The one-minute clip shown to the jury was a tiny excerpt of hours of footage — defense did not explore whether other footage showed more activity. |
| Surveillance | Gov. Ex. C60, C60a-C60h | Video clip and still images from FBI pole camera at ASA Limited site (Gurey Deli, 281 McKnight Road, St. Paul) from December 2021. Shows near-empty storefront between a Smoke Shop and dry cleaner. Average of 23 individuals per day versus claimed ~1,791–1,795 meals. | [p. 825-830] | Same limitations as Safari camera — one angle, limited time period, cannot account for all distribution methods. |
| Document | Gov. Ex. C20-C26, C28 | Emails from Abdihakim Ahmed (ASA co-owner) to a contact at 'Faaris Studio' and then to Salim Said, containing Excel spreadsheets with an embedded formula '=RANDBETWEEN(7,17)' to auto-assign ages to fake children's names pulled from surnames.com hyperlinks, used to generate fraudulent attendance rosters. | [p. 809-819] | These emails were NOT sent to Aimee Bock (Kary confirmed on cross). Defense can use them to distinguish Said's conduct from Bock's. The government will need to bridge this gap through other evidence or a conspiracy theory. |
| Financial Record | Gov. Ex. W1-W2, W4-W10, W11-W260 | Bank records from BBVA, Bank of America, Bridgewater Bank, Wells Fargo, and approximately 3,000 other financial accounts obtained via grand jury subpoena. Show Aimee Bock as sole signatory on FOF's Bank of America account, Salim Said and Abdulkadir Salah as signatories on Safari/Cosmopolitan accounts, and a pattern of millions in federal funds flowing through these accounts. | [p. 701-712] | The sheer volume (260+ exhibits) may overwhelm jurors but also creates appellate issues if each exhibit was not individually authenticated. Defense could seek to limit or challenge chain of custody for specific accounts if a particular check or transfer is disputed. |
| Document | Gov. Ex. B16 | February 4, 2021 email chain: Eidleh sends Bock CLiCS screenshot of $854,522 in Safari claims asking 'Please take a look if it's right'; Eidleh also sends Bock Safari's 2020 1099-NEC showing $4.8M in compensation from FOF to Cosmopolitan/Safari; Bock responds 'Looks good to me.' | [p. 720-724] | The response 'Looks good to me' was to the 1099 tax document, not necessarily to the underlying meal counts. Defense can argue Bock was merely confirming the accuracy of the accounting document as prepared by Eidleh, not independently verifying the legitimacy of the meal counts. |
| Document | Gov. Ex. Z1 | Google letter dated August 12, 2022, with certificate of authenticity, stating that no Gmail servers exist in Minnesota during January 2020 through July 2022. | [p. 714-716] | Boilerplate authentication document — largely unassailable unless defense can show the specific emails charged were routed differently. |
| Document | Gov. Ex. Z2, Z5, Z8, Z12 | Four emails corresponding to specific wire fraud counts in the indictment. Z2: Sept. 8, 2020 Bock email to MDE submitting ASA site application (Count 2). Z5: Oct. 20, 2020 Bock email to MDE with 'clarification' about FOF staffing for-profit restaurants (Count 5). Z8: March 1, 2021 Safari Restaurant gmail to Eidleh with meal count forms claiming ~6,000 meals/day (Count 8, Salim Said). Z12: Said partner Ahmed email to FOF/Bock with invoices, clicker count, and attendance (Count 12). | [p. 832-838] | Z5 (the clarification email) was the subject of extended cross — Bock's defense is that it was a legitimate operational clarification to MDE, not a fraudulent representation. The court's supplemental instruction ultimately undermined this defense angle by clarifying the wire need not itself be false. For Z8, Kary admitted Bock was not even a recipient. Defense should examine whether each charged wire was truly 'in furtherance of' the scheme versus routine business communication. |
| Document | Gov. Ex. B3 | Email attaching Safari Restaurant tax returns for 2017 ($339,092 total income, $624K gross receipts) and 2018 ($304,174 total income, $569K gross receipts), both signed by Salim Said. | [p. 735-740] | Defense could argue pandemic conditions and the relaxed federal child nutrition program rules — not fraud — account for the dramatic revenue increase, and that Safari's capacity expanded with federal support. |
| Document | Gov. Ex. C17, C18 | C17: August 2021 email chain showing Said's ASA asking Bock for a 'catering contract' — Bock sends a signed FY22 SFSP Contract for Vended Meals naming Safari Restaurant as the vendor for ASA Limited, signed by both Bock (for FOF) and Said (for Safari) on May 1, 2021. C18: Invoice from Safari to ASA for August 2021, billing $440,820 for 2,000 meals/day at $7.11/meal. | [p. 803-808] | Kary acknowledged the billing rate of $7.11/meal was the approved federal reimbursement rate, not an inflated fabrication. Defense can argue the contract structure was disclosed to FOF and followed regulatory templates. |
Udoibok's cross of Kary was the longest cross-examination of the volume and showed genuine strategic intelligence in places, but it had serious structural problems. On the positive side, Udoibok effectively established: (1) the pole camera's coverage limitations; (2) Kary's ignorance of FOF's regulatory obligations; (3) that many of the most damaging emails never reached Bock; (4) that Bock did not personally enrich herself with luxury purchases; and (5) that the organization's records looked normal and were not destroyed. However, there were significant failures. The most damaging was the wire fraud instruction episode — Udoibok's questioning suggested the wire itself had to be false, which the government correctly pointed out is not an element of wire fraud. By forcing the court to re-instruct the jury mid-cross, Udoibok inadvertently strengthened the government's legal theory. Udoibok also failed to: land a clean blow on Kary's speculation about deliveries from the back of Safari; pin down the exact number of FOF employees to quantify Bock's supervisory limitations; effectively use the pandemic context (his questions on this were scattered and easily parried); develop the Eidleh-as-mastermind narrative (Eidleh's flight to Somalia and non-return was barely touched); or meaningfully challenge the $12.1 million figure or the surveillance methodology. The cross ended without cross-examining Kary on the auto-generated roster emails at all from Bock's perspective — a missed opportunity to argue she had no visibility into what Said's group was doing internally.