Trial II · 22cr223

Vol IX

2025-02-24
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Day Overview

Volume IX covers the continuation and conclusion of FBI Agent Jared Kary's cross-examination, redirect, and recross; a brief appearance by Google records custodian Gabrielle Raines; the full direct and cross of cooperating witness Abdulkadir Awale (a guilty-plea restaurant owner); and the direct and cross of Bridgewater Bank compliance officer Beth Shipman. The most significant moment was Awale's testimony that Eidleh of Feeding Our Future coached him to inflate meal counts and that Aimee Bock personally appeared at a December 2021 meeting to solicit donations — with checks directed to 'School Age Consultant,' an account owned solely by Bock. Shipman's testimony about Salim Said's account network ($24.5 million in under a year, cash structuring, vendors with no physical locations) powerfully supported the government's money-laundering narrative against Said. Defense cross of Kary succeeded in highlighting that Kary conducted no surveillance at the Taylor Street address and could not conclusively place Bock as the creator of the fraudulent rosters. Defense counsel should note that the December 2021 donation meeting with Bock is critical new evidence, and Awale's admission that it was Eidleh — not Bock — who showed him how to inflate counts is a significant opening.

Government Strategy

The government used this day to cement the wire/mail fraud jurisdictional hooks (interstate commerce via Google servers and Bridgewater Bank out-of-state systems), while simultaneously delivering one of its most powerful cooperating-witness moments. Through Abdulkadir Awale, the government put a human face on the fraud: a restaurant owner who admitted inflating meal counts at Feeding Our Future's direction, paying kickbacks to Abdikerm Eidleh, and attending a December 2021 meeting where Aimee Bock personally solicited donations — with a check made out to a 'School Age Consultant' account owned by Bock. The government also used Bridgewater Bank compliance officer Beth Shipman to show Salim Said's network (Safari/ASA/Salim Limited) received ~$24.5 million in about eight months, structured cash withdrawals, and spent funds on real estate and a car — not food. The remaining cross of Agent Kary was a cleanup operation: government used redirect to highlight that Bock confirmed to MDE that 'different youth were being served' at 2854 Columbus Avenue — a claim the surveillance proved false, and that rosters for both sites there showed the exact same children's names and ages.

Strategic Notes for Defense Counsel

- The Awale donation meeting testimony (December 2021, 'School Age Consultant' account owned by Bock) is new and damaging — Defense counsel must understand whether this account and its purpose are adequately explained by Bock's defense, whether there is documentation of legitimate legal fee payments from this account, and whether other people donated to this account beyond Awale. This is now a central vulnerability. - The loss figure of $246 million has never been offset by actual food purchases — Kary confirmed this on the record. A forensic accountant who can quantify legitimate food expenditures across the Feeding Our Future network could significantly reduce the loss calculation and influence sentencing even if liability is found. - The government's site-specific fraud evidence (2854 Columbus, pole cam, rosters) depends heavily on inferring Bock's knowledge from her position as sponsor. The defense theory that Southside Youth was a legally separate, independently operated site that submitted its own fraudulent records without Bock's personal direction is not foreclosed — but it requires Bock or her employees to testify about internal oversight protocols. - Exhibits D1-994 through D1-996 (Bock's emails requesting site address changes) were excluded through Kary but remain available for the defense case-in-chief. These could directly rebut the government's narrative about what Bock knew about the Taylor/Columbus address situation. - The MDE internal document (Exhibit 853) with staff notes reportedly stating the government was 'setting up this site for failure' remains potentially powerful exculpatory evidence. Defense counsel should pursue its admission aggressively — it goes to MDE's own internal assessment of the program's administration and could support a good-faith defense.

Witnesses
Jared Kary
FBI Special Agent and case agent who conducted surveillance, reviewed program records, and testified about Feeding Our Future's fraudulent meal claims at 2854 Columbus Avenue.
FBI Government
Direct Examination

Kary's second-round direct (from Volume VIII) was followed in this volume by redirect after extensive cross. On redirect, Ebert used Kary to deliver the sharpest moment of the cross: Bock personally responded to MDE's October 4, 2021 inquiry confirming 'We have verified that it is different youth being served at each of the locations in the building' — which Kary testified was false. The government displayed side-by-side rosters from the Taylor site and Southside Youth site showing identical children's names and ages. Kary testified directly: 'She lied.'

Bock responded to MDE's October 4, 2021 inquiry about two sites at 2854 Columbus: 'This is correct. We have verified that it is different youth being served at each of the locations in the building.' The investigation revealed no youth were being served at that location. — Government used this as a direct, documented lie from Bock to MDE, establishing knowledge and intent. The word 'We' in the email implies personal verification. [p. 1923-1927]
Rosters for both Feeding Our Future Taylor and Southside Youth showed 'exact same names and ages' for children supposedly served at separate locations in the same building. — Demonstrates the fraud was not merely administrative confusion but fabricated documentation, and ties both sites to Bock's oversight. [p. 1925-1926]
Total amount of government reimbursements from USDA to Feeding Our Future sites: $246,045,149.65. Kary confirmed food purchases were NOT deducted from this total loss figure. — The government's loss number is inflated by not offsetting actual food costs. This is an opening for any defense. [p. 1920-1921]
Cross-Examination

Mr. Udoibok's cross was lengthy (pages 1863–1921) and achieved several meaningful concessions: Kary admitted he never surveilled the 2501 Taylor address with a pole cam; acknowledged the site applications showed Southside Youth as legally separate from Feeding Our Future; and conceded he could not identify Bock as the creator of the fraudulent rosters. However, the cross was often repetitive and became argumentative, which prompted multiple 'asked and answered' sustained objections and diluted its effectiveness. The most significant defense gain — that Kary never surveilled Taylor Street — was buried under an excess of technical questions about address changes.

Kary admitted: 'We did not back out food purchases from that total amount' of $246 million in losses. — The $246M loss figure does not account for legitimate food actually purchased and served. Incoming defense should challenge the loss calculation with forensic accounting. [p. 1921]
Kary admitted there was no pole cam surveillance at 2501 Taylor Street ('Not with a pole cam, no.'). — The government's surveillance evidence is limited to 2854 Columbus and cannot rule out legitimate operations at the Taylor address. Weakens the geographic specificity of the fraud claim. [p. 1885, 1899, 1911]
Kary admitted he has no evidence Bock personally created the fraudulent rosters: 'Not at this time, no.' — Absence of direct evidence connecting Bock to fabrication of specific documents — only circumstantial connection via office custody of 270 boxes of records. [p. 1928-1929]
Kary acknowledged the email exchange between MDE's Kendra Pace and Bock (A72/A73) was about site naming and identification, not the CACFP application process itself. — Helps frame MDE-Bock communications as administrative coordination, not fraud, at least in that thread. [p. 1886, 1889]
Defense attempt to introduce Exhibits D1-994, D1-995, D1-996 (emails authored by Bock) was blocked on hearsay and foundation grounds. Court ruled they were inadmissible under the theories offered. — Defense was unable to introduce potentially exculpatory correspondence from Bock requesting site address changes. This evidence may be reintroducible in a defense case-in-chief with proper foundation. [p. 1893-1896]
Vulnerabilities Kary's main vulnerability is the binary nature of his surveillance: he only placed a pole cam at 2854 Columbus, never at 2501 Taylor. He admitted not knowing the direction of certain site address transfer requests. He also acknowledged he was uncertain about the specific timing of address changes and admitted he could not identify Bock as the creator of the fraudulent rosters. His $246M total loss figure has not been offset by actual food costs — a significant forensic accounting weakness. In recross, Udoibok elicited the key point that 270 boxes of documents were seized and that Bock had many employees, undermining the inference that she personally knew the contents of all documents at her office. Kary also showed frustration and a combative posture at times, which could affect his credibility with jurors.
For Defense Counsel Defense counsel should consider: (1) retaining a forensic accountant to recalculate actual loss after netting out legitimate food purchases; (2) establishing that the pole cam surveillance gaps mean the government cannot rule out that Feeding Our Future-Taylor had legitimately transferred operations off-site before December 2021; (3) seeking to admit the Bock-to-MDE site change correspondence (D1-994 through D1-996) via a proper vehicle (defense case-in-chief, or as prior consistent statements if Bock testifies); (4) pressing harder on whether Bock personally had access to or visibility into the specific rosters at issue given the volume of records.
Gabrielle Raines
Google custodian of records and legal investigations support team member who testified that Gmail-hosted emails in Minnesota during 2020–2022 necessarily traveled through out-of-state Google servers, establishing interstate wire fraud jurisdiction.
Other Government Government
Direct Examination

Raines established the interstate wire commerce element for the wire fraud counts. She confirmed Google had no servers in Minnesota from January 2020 to July 2022, so every email sent from a Google-hosted account in that period traversed an out-of-state server. She authenticated Z2, Z4, Z5, Z8, and Z12 as Google-account emails sent from Aimee Bock and others with Feeding Our Future addresses, each containing site applications or meal count attachments.

Google had no servers in Minnesota from January 2020 to July 2022; therefore every email from a Google-hosted account necessarily traveled through an out-of-state server. — Establishes the interstate commerce element required for wire fraud counts for all emails sent from Feeding Our Future's Google-hosted accounts. [p. 1932-1933]
Z5 (Count 5) was an email from aimee@feedingourfuturemn.org containing a 'For-Profit Restaurant Clarifications' document with Bock's signature representing that Feeding Our Future staffed sites at Nawal Restaurant, ASA Limited, S&S Catering, and Safari Restaurant. — This document became pivotal in Awale's testimony — he testified it was false because his own employees, not FOF staff, prepared the food. [p. 1938-1939]
Cross-Examination

Udoibok cross was brief and scored one notable point: Raines admitted she cannot determine from an email address alone who the physical person was that sent the email. Montez (for Said) also extracted that admission. Neither cross developed the point into a full challenge to authorship.

Raines admitted: 'No' — by looking at an email address, she cannot ascertain who the physical person is that's sending the email. — Opens authenticity challenges to emails purportedly sent by Bock or others. The government has not yet established through Raines who physically typed and sent each email. [p. 1944-1945]
Vulnerabilities Raines has no knowledge of the content of the emails, no ability to identify who physically sent them, and no ability to verify that the account holder was the sender. She is entirely a technical/jurisdictional witness with no substantive knowledge of the fraud.
For Defense Counsel If Bock or Said claim they did not personally send specific emails (e.g., a different employee used Bock's email account), this witness cannot rebut that. Defense counsel should explore whether Feeding Our Future had shared email access policies and whether other staff had access to the aimee@ account. This may also support a reasonable doubt argument as to specific wire fraud counts.
Abdulkadir Awale
Former defendant and restaurant owner (Karmel Coffee, Sambusa King, Nawal Restaurant) who pleaded guilty to fraud in the Feeding Our Future program; testified as a cooperating witness about how Abdikerm Eidleh coached him to inflate meal counts, the kickback payments he made to Eidleh, and a December 2021 meeting at Feeding Our Future where Bock solicited donations.
Cooperating Witness Government
Direct Examination

Awale gave the government its most humanizing cooperating witness testimony. He described legitimate participation in April 2020 (actually serving 300-400 meals per day) followed by quitting because it was too hard, then rejoining in November 2020 after Eidleh persuaded him to inflate counts to 'make a lot of money.' He admitted submitting inflated meal count forms (Exhibit Q104), paying Eidleh $12,000, $27,000, $22,000, and $22,050 in checks (Exhibit S91) with Eidleh writing the payee name and memo lines. He testified to a December 2021 meeting at Feeding Our Future's basement where Bock asked ~30-40 attendees for donations to hire lawyers, and he wrote two checks totaling $8,800 — including $3,800 to 'School Age Consultant.' On redirect, the government revealed the School Age Consultant account was owned solely by Aimee Marie Bock.

Eidleh told Awale to claim more meals than actually served: 'He told me that this money is to spend — they have that money... it's not important if you say I serve 3,000 or 2,000. What's important is to get this money.' — Direct cooperating witness testimony that a Feeding Our Future employee actively coached vendors to commit fraud, establishing Feeding Our Future's organizational role in the scheme. [p. 1977-1978]
Awale paid Eidleh four checks totaling approximately $83,050, all with payee and memo lines written by Eidleh himself in names like 'Bridge Consulting and Logistics' and 'Eidleh Inc.' with memos saying 'Loan' and 'Consulting.' — Shows systematic kickback payments flowing back to Feeding Our Future employees, and that false documentation was built into the scheme from the start. [p. 1983-1989]
At the December 2021 meeting at Feeding Our Future's office, Bock was present for approximately five minutes, described difficulties with the government, and asked for donations to hire lawyers. Awale wrote checks including $3,800 to 'School Age Consultant' — which the government revealed was an account owned solely by Aimee Marie Bock. — Directly links Bock to soliciting money from fraud participants using a shell-like account in her own name, potentially supporting obstruction or additional fraud theories. [p. 1993-1997, 2016]
Awale identified that the Z5 document (FOF Restaurant Clarifications email from Bock) was false: 'I don't have any [FOF employees]. My employees who work in my restaurant, not Feeding Our Future.' — Cooperating witness directly contradicted Bock's written representations to MDE about site staffing. [p. 1991-1992]
Cross-Examination

Udoibok's cross extracted several favorable concessions: Awale confirmed he never wrote a check or gave cash directly to Bock (only to Eidleh and at the meeting per instructions); it was Eidleh — not Bock — who showed him how to inflate counts; and he had not reported Eidleh to authorities before the FBI contacted him. Awale also confirmed the December 2021 donation was presented as a charitable ask to support a company under government attack. Montez's cross for Said was brief, reinforcing that real meals were served in April 2020 (300-400 per day), before the fraud began.

Awale confirmed: 'No' — he never wrote a check to Aimee Bock personally and never gave her cash throughout their involvement with Feeding Our Future. — Distances Bock from direct financial benefit from Awale's payments. The kickback money went to Eidleh, not Bock. [p. 2006-2008]
Awale confirmed it was Eidleh, not Bock, who taught him to inflate meal counts: 'It wasn't Ms. Bock, was it?' 'No.' — Critical for Bock's defense: the operational fraud instructions came from an employee, not the CEO. [p. 2010]
The December 2021 donation was framed as a charitable contribution to a company under government attack ('the government, but being attacked because they assaulted Somali community'). Awale confirmed it was presented as a donation, not a payoff. — The defense can argue the donation was a legitimate solicitation for legal fees, not a kickback or obstruction payment. [p. 2009-2010]
Awale did not know who wrote 'Shafi Tutoring' in the memo line of check W45: 'That's not my handwriting... I didn't produce it, and I didn't write down that memo.' — Shows Eidleh (or others) were filling in financial documents without Awale's direction — and by extension, without Bock's direct involvement. [p. 2017-2018]
Vulnerabilities Awale has significant credibility vulnerabilities: (1) He is a guilty plea cooperator hoping for sentencing leniency from Judge Brasel. (2) He initially tried to contact the government before having a lawyer and wanted a plea deal, suggesting eagerness to cooperate. (3) His account of the December 2021 meeting does not include any direct quid pro quo between the donation and his fraud proceeds — it was framed as a charitable contribution. (4) He admitted to also defrauding Partners in Nutrition through a third party (Anab Awad), which was not part of his direct testimony, suggesting the government was careful to contain the scope of his admissions. (5) He cannot identify whether Bock knew the specific rosters were fraudulent. (6) His memory of meeting details is imprecise ('I don't remember' appears frequently on dates and specifics).
For Defense Counsel Defense counsel should: (1) Explore whether Awale's plea agreement with Partners in Nutrition fraud was fully disclosed and whether his cooperation with the government has produced any undisclosed benefits; (2) Focus the jury on the fact that the direct fraud instructions came from Eidleh, a mid-level employee, and press whether Bock had operational visibility into what Eidleh told vendors; (3) Challenge the December 2021 donation narrative — the meeting was framed as a legal defense fundraiser for a nonprofit under government attack; characterizing it as evidence of guilt requires Bock's specific knowledge that the attendees had committed fraud; (4) Note that Awale was not participating in the program at the time of the December 2021 meeting, which complicates the inference that Bock was soliciting from fraud co-conspirators; (5) Obtain and scrutinize the FBI interview reports (302s) from Awale's January 2022, January 2023, February 2023, and April 2023 meetings to test for inconsistencies the government blocked under 'improper impeachment' objections.
Beth Shipman
Senior Vice President of Compliance and BSA at Bridgewater Bank, who testified about the bank's compliance investigation into Salim Said's network of accounts (Salim Limited, Safari/Cosmopolitan Business Solutions, ASA Limited, 3017 LLC), the bank's decision to close all four relationships, and the interstate commerce nexus for wire fraud counts tied to Bridgewater transactions.
Other Government Government
Direct Examination

Shipman provided powerful circumstantial evidence of money laundering and fraud against defendant Salim Said. She testified that Salim Said's four interconnected accounts at Bridgewater received nearly $24.5 million from Feeding Our Future in under eight months (October 2020 to July 2021), that the bank identified cash structuring (repeated withdrawals just under the $10,000 CTR threshold), round-dollar payments to entities with no physical locations or business history, and that after the bank questioned Said about the payments he identified as 'contractors,' the round-dollar transaction pattern abruptly ceased — which she said indicated Said 'knew that they weren't valid.' The bank closed all four accounts. She also established the interstate commerce element: all Bridgewater transactions — cashier's checks, internal transfers, and wires — access out-of-state servers. Key specific transactions: Z42 (Salim Limited cashier's check for $47,000 to Lupient Chevrolet), Z51 (Salim Limited cashier's check for $250,000 to Micasa LLC for a real estate purchase at 5150 Alvarado Lane), and Z52/W82 ($2.735 million wire from Cosmopolitan Business Properties to First American Title — a real estate purchase).

Approximately $24.5 million flowed through Salim Said's four Bridgewater accounts in less than a year, with the majority sourced from Feeding Our Future reimbursements. — Establishes the scale of Said's financial activity and anchors the wire fraud counts to specific transactions. [p. 2063]
After Bridgewater reached out to Said about the even-dollar payments to supposed contractors, 'the even dollar payments ceased. So they stopped.' Shipman testified this 'indicated that he knew that they weren't valid.' — Consciousness of guilt inference — Said modified his payment pattern immediately upon bank inquiry, suggesting he knew the transactions were improper. [p. 2047-2048]
Many supposed contractors/vendors receiving payments had no physical location, no operating history, and were newly incorporated — some within eight months to a year of the payments. — Corroborates the government's theory that funds were passed through shell entities as part of a layering scheme. [p. 2045-2046]
Said used $250,000 from the Salim Limited account (funded primarily by Feeding Our Future) to purchase real estate via cashier's check to Micasa LLC (Z51), and nearly $2.74 million via wire from Cosmopolitan Business Properties to First American Title for another real estate purchase (Z52). — Demonstrates that Feeding Our Future fraud proceeds were used for personal real estate acquisitions — classic money laundering. [p. 2055-2057, 2061-2063]
Cross-Examination

Udoibok's cross was minimal — only three questions — confirming that Aimee Bock and Feeding Our Future had no accounts at Bridgewater, and that the bank cannot control where a check is deposited after issuance. This effectively highlighted the separation between Bock and Said's banking activity. Montez for Said offered no questions.

Udoibok confirmed: Aimee Bock had no account at Bridgewater Bank and Feeding Our Future had no account at Bridgewater Bank. — Cleanly separates Bock from the Bridgewater banking activity involving Said. This is relevant to any attempt to tie Bock to the money laundering counts. [p. 2064]
Vulnerabilities Shipman is a credible, experienced compliance professional with 35 years in BSA/AML. Her vulnerabilities are limited: (1) The bank's conclusion that vendors had 'no physical location' was based on public records searches, not exhaustive investigation — some vendors may have had operations not visible in public databases; (2) The 'even dollar payments ceased' observation is circumstantial — Said could argue he stopped on his own initiative after receiving legal advice, not because of guilt; (3) The bank's investigation was internal compliance, not a law enforcement investigation with compulsory process — its conclusions are inferences, not forensic findings. (4) She acknowledged the bank only asked Said to leave; it did not make a formal criminal referral at that time.
For Defense Counsel For Said's defense team: (1) Challenge the bank's methodology for identifying 'no physical location' vendors — public database searches miss many legitimate small businesses; (2) Argue the cessation of even-dollar payments after bank inquiry shows Said was responsive to legitimate compliance concerns, not consciousness of guilt; (3) Consider whether any of the $24.5 million can be traced to legitimate food service operations; (4) The bank closed the accounts but did not report a SAR (Suspicious Activity Report) or criminal referral at the time — explore why and use it to argue the activity, while unusual, was not clearly criminal. For Bock's defense: the Bridgewater evidence does not implicate Bock at all.
Key Evidence
Type Exhibit Description Page Challenge Opportunity
Document Gov. Ex. A73 Email from Aimee Bock to MDE (October 4, 2021) responding to MDE's inquiry about two sites at 2854 Columbus Avenue, confirming: 'This is correct. We have verified that it is different youth being served at each of the locations in the building.' [p. 1923-1927] The email uses 'we' — it could have been drafted based on representations from site operators (Khadra Xaashi, Southside Youth staff) rather than from Bock's own personal verification. Defense can argue Bock was relaying information from the site operator in good faith. The document does not show Bock independently verified, only that she transmitted confirmation.
Data/Summary Gov. Ex. P66 and P77 Side-by-side roster pages for the Feeding Our Future Taylor site (P66) and the Southside Youth site (P77), both purportedly at 2854 Columbus Avenue, showing identical children's names and ages on both rosters. [p. 1925-1929] Kary admitted on recross that he has no evidence Bock created these specific rosters. The rosters could have been fabricated by site operators (Khadra Xaashi or others) without Bock's knowledge. With 270 boxes of documents seized from Feeding Our Future, proving Bock specifically reviewed these rosters is a different matter.
Financial Record Gov. Ex. S91 Four checks from Abdulkadir Awale's business accounts (Karmel Coffee, Sambusa King) to 'Bridge Consulting and Logistics' and 'Eidleh Inc.' totaling approximately $83,050 — payee names and memo lines written by Abdikerm Eidleh. [p. 1982-1989] These payments went to Eidleh personally (or his entities), not to Bock or Feeding Our Future directly. Does not implicate Bock unless the government can show Eidleh shared kickbacks with Bock or that Bock directed Eidleh to collect them.
Financial Record Gov. Ex. S32 and W45 Two checks from Awale written at the December 2021 Feeding Our Future meeting: S32 for $5,000 (payee not described in transcript) and W45 for $3,800 to 'School Age Consultant.' On redirect, government showed the School Age Consultant account was owned solely by Aimee Marie Bock. [p. 1993-1997, 2016] The donation was solicited openly, framed as legal defense fundraising for Feeding Our Future, and Awale testified he had no promise or expectation of benefit. The $3,800 is a small amount. The defense can argue this was a legitimate charitable contribution to a nonprofit leader fighting government overreach, not a kickback. It also occurred in December 2021 — after the program had ended and after the government raid, suggesting it was genuinely litigation-related.
Financial Record Gov. Ex. Z51 Cashier's check for $250,000 from Salim Limited LLC account at Bridgewater Bank, purchased by Salim Said, made out to Micasa LLC, for the purchase of property at 5150 Alvarado Lane. [p. 2055-2057] The government has not yet introduced direct testimony that Micasa LLC is owned by Said or that this was a personal benefit rather than a business investment. Chain of ownership of Micasa LLC should be examined.
Financial Record Gov. Ex. Z52 / W82 p.9 Wire transfer of $2,735,000 from Cosmopolitan Business Properties LLC (Salim Said and Abdulkadir Nur Salah as signatories) to First American Title Insurance Company, requested by Abdulkadir Nur Salah and Salim Said in person at Bridgewater Bank. [p. 2059-2063] The originating funds in Cosmopolitan Business Properties include payments from multiple sources — government has not introduced a specific tracing analysis showing that particular $2.74M came from Feeding Our Future fraud proceeds rather than legitimate food service revenue.
Document Gov. Ex. Z3–Z61 (Z series) Series of exhibits admitted by stipulation at the start of the session — the Z exhibits correspond to the counts in the indictment and include emails, meal count attachments, and bank transaction records underlying the wire fraud counts. [p. 1862] By stipulating to admission, defense counsel may have waived some foundation and authenticity challenges. However, the content of the emails and what they prove remains contested.
Document Gov. Ex. Z5 Email from Aimee Bock (aimee@feedingourfuturemn.org) dated October 20, 2020, with subject 'For-Profit Restaurant Clarifications,' attaching a document stating for each site (ASA Limited, S&S Catering, Safari Restaurant, Nawal Restaurant): 'This site is being staffed by Feeding Our Future.' [p. 1989-1992] The statement 'staffed by Feeding Our Future' may be a regulatory/compliance term of art meaning 'under FOF's sponsorship and oversight' rather than 'FOF employees physically on site.' Awale's contradiction may reflect a misunderstanding of the regulatory terminology rather than a knowing lie by Bock. This argument is worth developing with a program regulations expert.
Legal Rulings & Objections
Court sustained government objection to defense attempts to admit Exhibits D1-994, D1-995, and D1-996 (emails authored by Bock to MDE about site address changes) as hearsay and lacking foundation. Defense argued not offered for truth but to show Agent Kary's reaction and as impeachment; court rejected both theories. — Defense was unable to present potentially exculpatory Bock-authored correspondence through Agent Kary. Defense counsel should consider introducing these documents in a defense case-in-chief with proper foundation — possibly through Kary recalled, through an MDE witness, or through Bock herself if she testifies. [p. 1891-1896]
Court sustained objection that defense questions asking agent to define 'deliberate misrepresentation' called for a legal conclusion. — Standard ruling — but the underlying point (that the application required deliberate misrepresentation, not mere error) should be revisited through jury instructions rather than agent testimony. [p. 1868]
Court allowed defense recross of Kary to confirm the $246M total did not offset food purchases, overruling government's 'beyond the scope' objection. — Defense counsel should use this as a hook to argue the government's loss figure is unreliable and to commission a defense forensic accounting analysis of actual food expenditures. [p. 1920-1921]
Court admonished Udoibok for raising the alleged document alteration by Agent Kary (Exhibit 853) before the jury without first raising it with the government. Court found no evidence of nefarious alteration — Agent Kary had merely pulled a Word document off a SharePoint and saved it, which changed the metadata. — The courtroom confrontation backfired for the defense — the court scolded Udoibok publicly. Defense counsel should note that the underlying document (MDE staff notes about 'setting up this site for failure') may still be worth pursuing through proper channels as potentially exculpatory. [p. 1965-1973]
Court sustained 'improper impeachment' objection to Udoibok's attempts to cross-examine Awale about statements made in FBI interview reports from January 31, 2023, February 8, 2023, and April 2023 meetings. — The court appears to have concluded defense was attempting to use undisclosed FBI 302 reports in a manner that violated the rules for impeaching by prior inconsistent statements. Defense counsel should carefully review all FBI 302s from Awale's pre-plea interviews and ensure timely disclosure of any impeaching material to avoid similar rulings. [p. 2007-2008]
Prior Defense Performance

Udoibok's cross of Kary was the longest examination of the day and achieved real gains — particularly the admissions that (a) the $246M loss figure does not offset food costs, (b) there was no pole cam surveillance at Taylor Street, (c) Bock cannot be identified as the creator of the fraudulent rosters, and (d) the naming controversy between MDE and Bock was about site identification not fraud. However, the cross was far too long and repetitive, drawing multiple 'asked and answered' rulings that undercut the effective points. The attempt to introduce Bock's own emails (D1-994 through D1-996) through Agent Kary was the right instinct but the wrong vehicle — those documents should be saved for the defense case-in-chief. The Exhibit 853 metadata accusation against Kary was poorly handled: raising it before the jury with no prior notice to the government, without adequate preparation, resulted in a judicial admonishment that likely damaged Udoibok's credibility with the jury. His brief cross of Raines was clean. His cross of Awale was effective on the key points (no direct payments to Bock, Eidleh was the fraud instructor) but left on the table the FBI 302 impeachment attempts which the court blocked — suggesting those materials should have been properly noticed as impeachment in advance. His three-question cross of Shipman cleanly insulated Bock from the banking evidence. Montez/LaFavor-Montez for Said was largely passive — no questions of Raines or Shipman; a brief cross of Awale confirming meals were actually served in April 2020 (modest value). The Said defense team will need to address the Bridgewater banking evidence much more aggressively.