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Trial II · 22cr223

Vol VI

2025-02-18
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Day Overview

Volume VI, tried on February 18, 2025, was one of the most document-intensive days of the trial. The day opened with brief testimony from FBI Special Agent Jessica Klepadia, who authenticated documents and computers seized from Total Financial Solutions at 2722 Park Avenue, Minneapolis — including an invoice purporting to show nearly 47 tons of milk purchased for Horseed/Stigma-Free sites, and a collection of meal count sheets for Safari, ASA, Stigma-Free, Olive Management, and other sites found in the TFS offices. The bulk of the day, however, was consumed by Postal Inspector John Western's direct examination, which traced the entire lifecycle of the Stigma-Free International fraud: from MDE's October 2020 nonprofit-only rule change, through Jamal Osman's same-day transfer of the dormant nonprofit to the Safari/Said group, to the opening of fake sites in Willmar and Mankato with immediate claims of feeding 3,000 children daily, to the flow of over $1.5 million in Feeding Our Future checks into the previously dormant Stigma-Free bank account and out to Tunyar Trading and Horseed Management as 'vendor' payments. The day ended dramatically: two co-defendants (the Abshir brothers) arrived noisily after lunch and one allegedly approached the government's next cooperating witness in the hallway, prompting the court to admonish both defendants against all communications with witnesses or codefendants and to threaten seizure of Said's phone. Defense counsel must pay close attention to Western's foundational testimony about the 500-meal site capacity versus 3,000-per-day claims, the dormant bank account evidence, and the government's contract-law redirect establishing Bock's authority and obligation to reject fraudulent claims.

Government Strategy

The government used Volume VI to establish two interlocking strands of its fraud narrative. First, it introduced SA Klepadia to authenticate documents seized from Total Financial Solutions (TFS) — a bookkeeping firm tied to the scheme — showing inflated meal count sheets for multiple Feeding Our Future-sponsored sites, directly linking those records to the defendants' network. Second, and predominantly, the government called Postal Inspector John Western to methodically walk the jury through the acquisition of the shell nonprofit Stigma-Free International, its immediate enrollment of fraudulent sites in Willmar and Mankato, and the resulting $5.3 million and $5.2 million in fraudulent federal reimbursements at those sites respectively. The government's theory is that Salim Said, working through Safari Restaurant partners and codefendants, seized control of a dormant nonprofit, opened fake food sites almost overnight, submitted 3,000-meal-per-day counts that were physically impossible for the small storefronts involved, and routed the payments through shell vendors (Tunyar Trading and Horseed Management) back to Said and his associates. Bock's role is framed as indispensable gatekeeper: she signed the site contracts, submitted claims to MDE in CLiCS under penalty of prosecution, earned a 10-15% administrative fee, and had explicit contractual authority to reject claims she had reason to believe were invalid.

Strategic Notes for Defense Counsel

- The Stigma-Free bank account (W11) is devastating: zero activity for 14 months, then $1.56 million in FOF checks signed by Bock arrives and exits to shell vendors within 12 days, triggering U.S. Bank to close the account as suspicious. Any defense of Bock must address why she signed checks totaling over $1.5 million to a nonprofit she had just enrolled whose bank account had never had a single transaction. - The roster evidence (fewer than 33-50 names out of 2,000 matching the entire 4,000-student Willmar school district) is likely the single most persuasive factual proof of fabrication in the volume. A future defense must either challenge the methodology of the name-matching (a forensic expert may be able to argue different demographic naming patterns for Somali-American children versus school district records) or front this issue with a witness who can explain it. - The government has established a strong implied knowledge framework for Bock: she received a 10-15% administrative fee on a $200 million portfolio in 2021, personally signed over $1.5 million in checks to a nonprofit with no prior banking activity, and personally signed the site contracts and CLiCS certifications. The defense must develop evidence that she had a genuine, functioning compliance infrastructure and relied on it in good faith. - Said's most vulnerable exposure comes from the consulting agreement (T4 — Tunyar Trading to Salim Limited, 10% of profits) and the November 3, 2021 emails where he personally submitted meal counts to FOF. The defense needs to establish either that the consulting agreement was never executed/paid, or that Said was transmitting documents he had no reason to believe were false. - The witness tampering issue (Abshir brothers in court, alleged approach to cooperating witness Jama) has poisoned the atmosphere and may be creating juror hostility toward Said specifically. Defense counsel must be aware that the jury has likely registered these incidents even if admonished to disregard them, and this makes a clean, credible alternative narrative essential.

Witnesses
Jessica Klepadia
FBI Special Agent assigned to a financial crimes squad (C2); served as team lead for the January 20, 2022 search of Total Financial Solutions at 2722 Park Avenue, Minneapolis.
FBI Government
Direct Examination

Klepadia established the chain of custody for documents and computers seized from TFS Suite 100. She walked the jury through photographs of the search site and authenticated numerous meal count sheets for Feeding Our Future-sponsored sites (Safari, ASA Limited, Stigma-Free Mankato/Willmar/Waite Park/St. Cloud, Olive Management, Brava, Southcross, Gaur, etc.) as well as a striking invoice for nearly 47 tons of milk addressed to Horseed Management/Stigma-Free. Feeding Our Future was listed as the sponsor on every meal count sheet found at TFS.

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An invoice found at TFS purported to show 2,760 gallons of milk x 4 = approximately 11,000 gallons (about 47 tons) purchased from 'Premuim Fresh Produce LLC' for Mankato Restaurant/Horseed Management/Stigma-Free. — Illustrates the absurdity of the quantities claimed; the government used this to signal that fabricated documents were being created at the TFS bookkeeping office, suggesting TFS was a central document-manufacturing hub. [p. 1069]
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Meal count sheets for at least eight different Feeding Our Future sites were found inside TFS offices, all naming Feeding Our Future as the sponsor. — Corroborates the government's hub-and-spoke theory — that TFS served as the back-office processor for fraudulent claims across multiple sites, all flowing through Bock's organization. [p. 1081]
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On redirect, Klepadia confirmed that Salim Said is one of the owners of Safari Restaurant and that Feeding Our Future was the sponsor on every meal count sheet reviewed — with Aimee Bock as its executive director. — The government used redirect to repair any impression from cross that the meal count sheets couldn't be tied to Bock or Said; it re-anchored both defendants to the documents. [p. 1090]
Cross-Examination

Udoibok (Bock's counsel) effectively established that Klepadia could not identify whose signatures appeared on any of the meal count sheets, did not know who owned the various sites, and conceded the TFS building was not a Feeding Our Future building. Colich (Said's counsel) highlighted that each meal count sheet bore initials of a certifying person at the site level — not Bock — and that the certifying initials were different at each site (AS, AA, NA).

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Klepadia admitted she did not know whose signatures appeared on the meal count sheets and said they did not appear to be Bock's. — Supports an argument that Bock did not personally certify these site-level counts; the site operators were the ones attesting to accuracy. [p. 1082-1084]
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Colich elicited that each meal count sheet has a line, 'Initials of person taking daily meal count certifying that the information is true and accurate,' and the initials were those of unknown individuals at the sites — not Bock. — This is a key defense theme: the certification responsibility at the meal-count level rests with site personnel, not Bock. Future cross of MDE witnesses should develop this further. [p. 1086-1089]
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Klepadia conceded she had no knowledge of whether Bock or Feeding Our Future owned or controlled any of the sites whose documents were found at TFS. — Limits the evidentiary value of Klepadia's testimony to authentication only; she could not speak to mens rea or Bock's knowledge of the fraud. [p. 1083-1084]
Vulnerabilities Klepadia's value to the government was entirely foundational — she authenticated exhibits and established the search. She had no independent knowledge of ownership, fraud, or intent. Defense successfully established she could not link any document to Bock personally. A major unexploited angle: the defense did not ask why the TFS bookkeeping firm had meal count sheets for sites it was not supposed to be running, which could have opened the door to argue that the fraud was being driven by third parties (the bookkeepers) and not by Bock or Said.
For Defense Counsel If this witness appears in defense counsel's trial, establish clearly that (1) Klepadia was not the case agent and had no investigative knowledge; (2) she cannot authenticate who created or submitted these documents; (3) the meal counts found at TFS were for sites not owned by your client; and (4) the presence of documents at a third-party bookkeeper's office is equally consistent with routine accounting services as with fraud. Consider whether TFS's role as the document hub can be used to argue an independent third-party actor drove the paperwork fraud.
John Western
United States Postal Inspector assigned to the mail/wire fraud group; one of the lead investigators in the Feeding Our Future case, working alongside the FBI and IRS.
Other Government Government
Direct Examination

Western delivered the government's core narrative for the day in an extended direct lasting most of the trial day. He traced how the MDE nonprofit rule change in September 2020 triggered the rapid acquisition of Stigma-Free International (a dormant shell nonprofit with a $100 bank balance and no operations), its immediate conversion into a vehicle for opening fake food sites in Willmar and Mankato, and the submission of wildly inflated meal counts — 3,000 per day — for over 14 months. He documented the flow of over $1.56 million in FOF checks into the Stigma-Free account in January 2021, and the almost immediate disbursement of $741,344 to Tunyar Trading (Mohamud's shell) and $740,682 to Horseed Management (Abshir's shell), both created days after the nonprofit rule change. He concluded that total reimbursements at Stigma-Free Willmar reached $5.3 million and at Stigma-Free Mankato $5.2 million for a combined 3.2 million claimed meals.

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Stigma-Free International had no employees, no office, no operations, and only a $5/month bank fee from November 2019 until October 2020 — Western called it a 'shell company.' Within days of the Safari group acquiring it, it was enrolled to run food sites. — Directly supports the government's theory that the nonprofit status was fraudulently acquired and weaponized. The speed — enrollment application submitted October 19, 2020, same day as contracts signed — is highly probative of premeditation. [p. 1102, 1111, 1140-1141]
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All four resignation letters from the original Stigma-Free board (Osman, his wife, Wardere, Hassan) were sent within a ten-minute window on October 7, 2020, used identical language, bore e-signatures, and were facilitated by Abdi Salah — senior policy adviser to Mayor Frey and brother of Safari Restaurant co-owner Abdulkadir Salah. — Shows coordination and speed suggesting the transfer was planned, not organic. Abdi Salah's role as a mayoral aide gives the conspiracy a political dimension that may resonate with jurors. [p. 1122-1127]
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The Stigma-Free Willmar site claimed to serve 3,000 children per day in a town of 21,000 people with 4,000 school-age children total, from a 'small storefront' smaller than a quarter of the courtroom. The numbers never fell below 2,990 per day, through COVID, snowstorms, and holidays. — The most viscerally persuasive evidence in the volume — the absurdity of the counts argues itself. Western's personal commentary ('jaw dropping,' 'unbelievable') echoes what the jury is likely feeling. [p. 1154-1159, 1167-1168]
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Investigators compared the roster of 2,000 names purportedly served at Stigma-Free Willmar to the entire Willmar Public School District enrollment of 4,000 children and found fewer than 33-50 names matching. — This is among the strongest corroborating evidence of fabrication. The defense had no effective answer to this. [p. 1174]
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Salim Said personally forwarded meal counts for Stigma-Free Willmar to Feeding Our Future (Exhibit G29, G30) on November 3, 2021, and Tunyar Trading (Mohamud's company) sent meal documents directly to Said's personal Gmail on that same date (Exhibit G28). — Directly ties Said to the submission of fraudulent claims — not just ownership of Safari Restaurant, but active participation in the claim-filing process for Stigma-Free sites. [p. 1183-1186]
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Safari Restaurant billed Feeding Our Future $14,220/day — identical amounts for both the Stigma-Free Willmar and Stigma-Free Mankato sites in August 2021, totaling $440,820 per site or more than $880,000 combined in a single month. — The identical, round-number invoices from Said's own restaurant to Feeding Our Future for services at Stigma-Free sites he helped set up creates a direct financial nexus between Said and the fraud. [p. 1226-1227]
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Feeding Our Future's sponsorship agreement (G3) expressly provided at paragraph 13: 'Feeding Our Future may withhold any program payments for claims that Feeding Our Future has reason to believe are invalid due to false or erroneous meal counts or are not supported by program records.' — The government used this to rebut Udoibok's 'no choice but to submit' defense. This is damaging for Bock because it eliminates the argument that she was a mere pass-through with no discretion. [p. 1308]
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In 2021, sites under Feeding Our Future's sponsorship received $200 million in federal reimbursements. Bock's company received an administrative fee of 10-15% — potentially $20-30 million — creating an enormous personal financial incentive to approve and submit any claim submitted to her. — Establishes financial motive for Bock to turn a blind eye or actively facilitate fraud; the fee structure means the higher the fraudulent claim, the higher her personal compensation. [p. 1323]
Cross-Examination

Udoibok's cross was wide-ranging and sometimes unfocused, but scored meaningful points on the following: (1) Western did not personally participate in the Feeding Our Future search and learned of documents only after the fact; (2) he could not confirm whether MDE pre-approved the specific meal count volumes for these sites; (3) emails containing meal counts went to the Feeding Our Future claims department and to Eidleh, not directly to Bock's personal email; and (4) Bock did not participate in creating the Stigma-Free nonprofit. Colich's cross was shorter and more disciplined, effectively establishing that the 'Safari group' designation used by the government conflated many separate actors, and that Said's direct connection to the Stigma-Free sites was limited primarily to two emails shown during direct.

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Western conceded he does not know whether MDE pre-approved specific meal count volumes for the Stigma-Free sites, and that his opinion that the counts were 'outrageous' was based on his own investigative assessment, not MDE regulatory rules. — Opens a potential gap for the defense: if MDE never communicated a cap to Feeding Our Future, it becomes harder to prove Bock knew the counts were fraudulent simply because they were high. An MDE witness will need to close this gap for the government. [p. 1261-1263, 1330-1332]
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Western admitted the meal count emails went to claims@feedingourfuturemn.org and to employee Eidleh — not to Bock's personal email address — and he did not know how many people worked in Feeding Our Future's claims department. — Supports an argument that Bock was not personally reviewing individual meal count submissions; there were intermediaries. This is critical for establishing a lack of actual knowledge defense. [p. 1285-1287]
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Western acknowledged Bock sent a clarification letter to MDE in October 2020 explaining that Feeding Our Future (a nonprofit) would staff the for-profit sites, and he agreed this was 'allowable' if they actually staffed the sites — he simply did not know whether they did. — Leaves open a factual question about whether Bock's actions were consistent with legitimate compliance behavior. Defense should develop evidence that FOF did provide some staffing. [p. 1293]
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Colich elicited that Said's name came up directly in Western's testimony only in connection with two emails involving Stigma-Free Willmar meal documents, and that for the Stigma-Free Mankato site Said's name did not appear at all in Western's testimony. — Useful for Said's defense to compartmentalize his alleged involvement; he was not the primary operator of either Stigma-Free site. However, the consulting agreement (T4) between Tunyar Trading and Said's Salim Limited (10% of net profit) was not effectively neutralized. [p. 1303]
Vulnerabilities Western is a highly credible and well-prepared witness, but has significant limitations Defense counsel can exploit: (1) He joined the case in fall 2021 and was not present at key early events; (2) He is not the case agent for Bock's activities — the forensic accountants will testify to the money flow, and MDE witnesses will testify to the regulatory framework; (3) He admitted he never investigated MDE's rules about maximum allowable meal counts per site, and the site application listed only 500 capacity but Western acknowledged the agreement did not contain an explicit cap on claims; (4) His characterization of Stigma-Free as a 'shell company' is contested — it was a legitimate 501(c)(3) with IRS approval; (5) He has no direct knowledge of whether Bock ever reviewed individual meal count sheets versus relying on her staff; (6) The 'Safari group' label unfairly aggregates multiple defendants with different roles and levels of involvement.
For Defense Counsel If Western appears in defense counsel's trial: (1) Press hard on the MDE approval/oversight gap — MDE processed and paid these claims for 14+ months; the regulatory failure is shared. (2) Develop the Eidleh/claims department structure to show Bock was not personally reviewing each submission. (3) Challenge the 'shell company' label for Stigma-Free — it was a legitimate IRS-recognized nonprofit. (4) Focus on the 500-capacity figure: the site application said 500, but nothing in the contract between FOF and MDE prohibited serving more children if demand existed. (5) If this is a Bock-focused defense, emphasize that she had no control over what the sites actually did once contracted, and the fraud was executed by Artan, Mohamud, Abshir and others. (6) The consulting agreement between Tunyar Trading and Salim Limited is the most damaging piece for a Said-focused defense and should be carefully re-examined — the agreement was unsigned and undated.
Key Evidence
Type Exhibit Description Page Challenge Opportunity
Document Gov. Ex. FF1, FF2 Photographs of the Total Financial Solutions search site at 2722 Park Avenue, Minneapolis (FF1), and a file folder labeled '19' containing documents seized from TFS (FF2). [p. 1064, 1070] The presence of documents at TFS is equally consistent with legitimate bookkeeping services. Defense did not challenge why TFS would have these records or attempt to introduce evidence that TFS created documents without Bock's knowledge.
Document Gov. Ex. FF5, FF6, FF16, FF22, FF24, FF27, FF30, FF35, FF36, FF38 Meal count sheets found at TFS for multiple FOF-sponsored sites (Safari, ASA Limited, Stigma-Free Mankato/Willmar/Waite Park/St. Cloud, Olive Management, Gaur, Brava, Southcross), claiming 2,000-3,000 meals per day, each naming Feeding Our Future as sponsor. [p. 1073-1081] Each sheet was certified by site-level personnel, not Bock. The signatures/initials are unidentified. The defense can argue these were forged or fabricated by site operators without Bock's knowledge.
Document Gov. Ex. F20 Minnesota Secretary of State certificate of incorporation and articles of incorporation for Stigma-Free International, filed August 15, 2019, by Jamal Osman (later elected to Minneapolis City Council). [p. 1102] A legitimate IRS-recognized nonprofit is not inherently a fraud vehicle. The characterization as a 'shell company' is disputed — it had valid nonprofit status.
Document Gov. Ex. F21, F22, F24-F27 Email chain showing Jamal Osman's corporate documents forwarded by city aide Abdi Salah on October 7, 2020, to an attorney and to Abdikadir Mohamud for transfer of Stigma-Free International; resignation letters from the original board members (Osman, Amba, Wardere, Hassan) all sent within 10 minutes using identical language and e-signatures. [p. 1111-1127] F21 was admitted over hearsay objection as a co-conspirator statement — conditionally. The identical language on resignation letters could be argued as a standard template, not evidence of fabrication.
Financial Record Gov. Ex. W11 Bank account records for Stigma-Free International at U.S. Bank, showing: (1) the account was dormant from opening in November 2019 through October 2020; (2) four Feeding Our Future checks totaling $1,560,028.72 deposited in January 2021, all signed by Aimee Bock; (3) checks of $741,344.43 to Tunyar Trading and $740,682.85 to Horseed Management written by Ahmed Artan on January 27, 2021; (4) account closed by U.S. Bank in February 2021 as suspicious. [p. 1107-1140, 1312-1314] The defense could argue Bock wrote checks to Stigma-Free (a legitimate nonprofit contractor) without knowing what the nonprofit did with the money. Chain of custody from Stigma-Free to the vendors was handled by Artan, not Bock. The bank's closure is concerning but is not conclusive evidence of fraud.
Document Gov. Ex. G3 Site application for Stigma-Free International Willmar, submitted by Aimee Bock to MDE on October 19, 2020 — the same day Mohamud submitted meal counts — listing estimated capacity of 500 meals. Contract signed by both Artan and Bock dated October 9-10, 2020. [p. 1142-1144] The application listed 500 as an estimate, not a regulatory cap. Udoibok's cross raised the possibility that MDE could have approved a higher number — Western admitted he did not know. Defense should subpoena the actual MDE approval records.
Document Gov. Ex. G1 Certificate of organization for Tunyar Trading LLC, filed by Abdikadir Mohamud on September 28, 2020 — three days after MDE announced the nonprofit-only rule change — listing Mohamud's residence as the business address. [p. 1149-1151] The timing of formation alone is not proof of fraud; many legitimate businesses respond to regulatory changes by forming new entities. The company had no warehouse or employees, but that does not definitively establish fraudulent intent at formation.
Document Gov. Ex. G28, G29, G30 Emails showing Abdikadir Mohamud sent Stigma-Free Willmar September 2021 meal documents (invoice, roster, meal counts) to Salim Said's personal Gmail on November 3, 2021; Said then forwarded meal count documents to Feeding Our Future claims the same day. [p. 1181-1186] Said forwarding documents to FOF claims could be argued as a ministerial act consistent with innocent involvement — he may have been acting as a conduit without knowing the counts were fraudulent. The defense should develop whether Said had any independent ability to verify the accuracy of Mohamud's counts.
Document Gov. Ex. T4 Email from Mohamud to Said (May 4, 2021) with an unsigned, undated consulting agreement between Tunyar Trading and Said's company Salim Limited, providing Said's company with 10% of Tunyar Trading's net profit in exchange for vague 'consulting services.' [p. 1188-1190] The agreement was unsigned and undated; there is no evidence it was ever executed or that payments were actually made. Defense should subpoena Salim Limited's bank records to show whether any 10% payments were received, and if none, argue the agreement was never operative.
Data/Summary Multiple Gov. Ex. G40-G53, H42-H56 Folders recovered from the Feeding Our Future search, organized by month and site, containing meal count sheets for Stigma-Free Willmar (Oct 2020 - Dec 2021) and Stigma-Free Mankato (Oct 2020 - Dec 2021), each claiming 3,000 (later 2,000) meals per day, with near-zero variance. [p. 1160-1176] The defense has argued these counts were consistent with MDE-approved levels and that the sponsor cannot reject claims that comply on their face. The roster comparison to school district enrollment is a stronger argument than the count consistency alone, and will need to be addressed by a more specialized witness.
Legal Rulings & Objections
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Gov. Ex. F21 (email from Osman to Abdi Salah): Udoibok objected on hearsay grounds; overruled. Admitted as co-conspirator statement (conditionally). — The court is broadly admitting co-conspirator communications conditionally. Defense counsel should monitor whether the conspiracy is ultimately proved sufficiently to sustain these admissions. [p. 1111]
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Gov. Ex. F24-F27 (Abdi Salah forwarding Stigma-Free documents): Udoibok objected on hearsay; conditionally admitted as co-conspirator statements. Government also argued non-hearsay (not for truth of the matter asserted). — The dual basis for admission (co-conspirator plus non-hearsay) makes these exhibits nearly unassailable on appeal. [p. 1120]
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Colich's objection on foundation to Klepadia's answer about whether meal count signatories certified accuracy across all forms: overruled. — The court is giving the government latitude on foundation for authentication-level witnesses. The defense will need to challenge document authenticity through substantive witnesses, not authentication witnesses. [p. 1088]
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Multiple objections by Thompson to Udoibok's hypothetical questions about Bock's contractual obligations sustained as confusing and not based on evidence. — The court will not permit defense counsel to use hypotheticals to rehabilitate Bock's role through this witness. That argument must be made through MDE witnesses or Bock herself. [p. 1272, 1294, 1327-1329]
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Post-testimony: Court admonished both defendants not to communicate with any witnesses or codefendants for the duration of trial after the Abshir brothers appeared in court and one allegedly approached cooperating witness Jama in the hallway. — The court is now actively monitoring witness tampering concerns. Defense counsel should be aware that the court has a heightened sensitivity to this issue, and any defense contacts with potential witnesses will be scrutinized. [p. 1277-1279, 1334-1339]
Prior Defense Performance

Udoibok's cross of Klepadia was appropriately brief and focused on limiting her testimony to authentication, which was correct. His cross of Western was more problematic: he spent enormous time on hypothetical contract-law questions that were repeatedly sustained as confusing, alienating the court and potentially confusing the jury. His best moments were establishing (1) that meal counts went to claims department and Eidleh, not Bock personally; (2) that Bock was not involved in creating the Stigma-Free nonprofit; and (3) that Western admitted he did not know MDE's rules about meal count caps — but these points were buried in hours of less effective questioning. He missed an important opportunity to directly confront the $200 million / 10-15% fee testimony, which he should have challenged more aggressively by establishing what portion of FOF's administrative fee came specifically from the Stigma-Free sites versus the broader portfolio. Colich's cross was shorter and more surgical — he successfully isolated Said's direct involvement to two emails and drew a cleaner distinction between Said's role and that of Artan, Mohamud, and Abshir. However, neither defense counsel effectively challenged the roster-versus-school-district-enrollment evidence, which is among the most persuasive proof of fabrication in the volume. Neither counsel moved to strike Western's lay characterization of the meal counts as 'fake,' 'inflated,' and 'unbelievable,' which amounted to lay opinion testimony that arguably invaded the province of the jury.