Trial II · 22cr223

Vol X

2025-02-25

Day Overview

Volume X covers a full trial day on February 25, 2025, featuring five witnesses. The day opened with brief foundational testimony from Wells Fargo custodian Shayne Driscoll (establishing FDIC jurisdiction for specific checks tied to the counts) and retired FBI SA Robert Blackmore (who participated in the January 20, 2022 search of Bock's Rosemount residence, introducing photos of luxury goods, cash, designer bags, and digital devices seized). The most consequential witness was cooperating witness Hanna Marekegn, an Ethiopian immigrant and Brava Cafe owner who pled guilty to fraud and provided a detailed first-person account of the scheme: Eidleh (FOF employee) recruited her, told her to falsely claim up to 5,000 meals per day, instructed her to vary numbers slightly to look legitimate, collected 5% kickbacks, and that Bock later demanded a $1.5 million cash payment from a $3 million fraudulent invoice — a demand Marekegn refused, resulting in her termination. Next, Genesis Alonso, a 19-year-old former FOF data entry employee recruited through her mother's friendship with Bock, testified to systemic red flags she observed: duplicate invoice numbers, impossibly large claims, non-food items on receipts, and FOF staff filling out blank site visit forms in the office after MDE demanded documentation. The day closed with SA Valerie Eastwood walking through physical documents seized from Salim Said's Plymouth home, including blank-but-signed meal count forms, an MDE denial letter citing Said's sites, payment records showing hundreds of thousands flowing through Cosmopolitan Business Solutions to Salim Limited, and a $2.78 million property purchase agreement. Defense counsel should pay close attention to Marekegn's account of Bock's cash kickback demand — it is the most direct evidence of Bock's personal corrupt intent and is entirely uncorroborated by any recording or documentation.

Government Strategy

The government pursued a multi-pronged strategy on this day aimed at connecting both defendants — Aimee Bock and Salim Said — to the core fraud scheme from multiple vantage points. With Driscoll and Blackmore, the government established the federal (FDIC) nexus for jurisdictional purposes and physically grounded the fraud evidence in Bock's home. With cooperating witness Hanna Marekegn, the government built its most damning narrative: that the entire food program was fraudulent from inception, that Eidleh (a Feeding Our Future employee) orchestrated fraudulent meal counts and kickbacks, and that Bock personally sought a $1.5 million cash kickback from Marekegn's $3 million invoice and used racial discrimination claims as a political cover for the fraud. With Genesis Alonso, a former FOF employee, the government established that Bock personally signed all checks, had full access to all claim and monitoring systems, was aware of red-flag invoices, and suppressed internal concerns. With SA Eastwood, the government introduced physical documentary evidence seized from Said's Plymouth residence — including blank signed meal count forms, consulting agreements, and large financial records — tying Said directly to the program's infrastructure and his personal enrichment.

Strategic Notes for Defense Counsel

- The coffee shop demand ($1.5M cash) is the government's central evidence of Bock's personal criminal intent, and it rests entirely on Marekegn's uncorroborated testimony. No recording, no witness, no document. She is a serial liar who fought for fraudulently obtained money using legal counsel and was simultaneously in a legal dispute with Bock at the time. A thorough timeline attack — comparing when she hired her lawyer, when the alleged meeting occurred, whether she disclosed it to counsel, and what her MDE complaint actually said — could significantly undermine this testimony. - The GG2 document (internal MDE staff chat found printed at Said's home) is an unexplored bombshell. How did Said get an internal MDE investigative communication? If it came through legitimate litigation discovery in FOF v. MDE, it is completely innocent and actually shows Said was monitoring regulatory risk appropriately. If it came through an MDE leak, it opens a different line of investigation. Either way, Eastwood's inability to explain its provenance was a major gap that prior defense failed to exploit. - The 'generic menu' practice and site visit paperwork issues are defensible if FOF had any documented remote visit protocol during COVID. Alonso conceded she did not know whether remote visits occurred. Before defense counsel's trial, obtain all FOF internal communications, training materials, and COVID-period protocols for site monitoring — there may be legitimate documentation of remote/phone-based monitoring that undermines the fabrication narrative. - Marekegn's testimony establishes an Eidleh problem: she describes him as the primary architect of the fraud mechanics at the site level (fraudulent meal counts, kickback collection, false form completion). If Eidleh is not charged in defense counsel's client's case, the defense should argue that FOF's corrupt employees, not FOF's leadership, were driving the fraud at the site level, with Bock serving as an unwitting or reckless (not knowing) conduit. - The lifestyle evidence (luxury goods at Bock's home, Said's Plymouth mansion with indoor basketball court, car purchases via Lupient Chevrolet) is highly prejudicial and will be repeated throughout trial. Defense counsel should consider early motions in limine to limit or structure how such evidence is presented, and prepare jury selection questioning to identify jurors who can evaluate financial circumstantial evidence without prejudging based on displays of wealth.

Witnesses

Shayne Driscoll

Wells Fargo business execution consultant (litigation research/support) who authenticated checks and cashier's checks from FDIC-insured accounts tied to specific counts in the indictment.

Other Government Government

Direct Examination

Driscoll explained the mechanics of personal checks and cashier's checks at Wells Fargo, established that all relevant accounts are FDIC-insured (establishing federal nexus), and authenticated Government Exhibit Z44 — a $60,000 personal check from Anisa Checchekani to Feldman Imports dated March 4, 2021 — as well as cashier's checks in Z51 from Salim Said to Micasa LLC ($178,000, Oct. 8, 2021) and to Results Title ($702,000, July 28, 2021).

▸

Cashier's check for $702,000 purchased by Salim Said, paid to Results Title, dated July 28, 2021, drawn on FDIC-insured Wells Fargo account. — Ties Said directly to a large financial transaction that the government will argue represents proceeds of the fraud, and establishes federal jurisdiction via FDIC insurance. [p. 2077-2078]

▸

Cashier's check for $178,000 purchased by Salim Said, paid to Micasa LLC, dated October 8, 2021. — Supports government's theory that Said was moving large sums of fraud proceeds through LLCs; Micasa LLC likely a real estate or shell entity. [p. 2077]

Cross-Examination

No cross-examination was conducted by either defense attorney.

Vulnerabilities Driscoll is a pure custodial witness with no knowledge of the underlying transactions or what the funds were for. He acknowledged he does not know what Feldman Imports is. His testimony is limited to authentication and FDIC status — he cannot speak to the purpose, legality, or context of any transaction.

For Defense Counsel Challenge whether FDIC insurance alone is a sufficient hook for federal jurisdiction — consider whether the government's jurisdictional theory holds up under scrutiny. Also consider whether cashier's checks to Results Title and Micasa LLC have innocent explanations (e.g., real estate purchases) that undercut the government's fraud narrative for those specific counts.

Robert Blackmore

Retired FBI special agent (22 years) who participated as a searcher on the January 20, 2022 search warrant execution at Aimee Bock's Rosemount, MN residence; introduced search photos and seized physical and digital evidence.

FBI Government

Direct Examination

Blackmore authenticated the entry/exit photo log from the Bock residence search (BB1), described the seizure of luxury goods (Gucci bag, designer items, jewelry with 'Aimee' necklace), cash in a nightstand and safe, a new white Mercedes Benz with a temporary tag, a MacBook, cell phone, and documentary evidence including a Bank of America statement for School Age Consultant LLC (Aimee Bock), checks from food program-related entities to School Age Consultants, and an earnings statement for 'Empress M. Watson' at Handy Helpers LLC at Bock's address. Multiple text message strings from digital devices were admitted (BB30a-f, BB32a-d, BB41a-e, BB50-53).

▸

Nightstand drawer contained a 'large amount of cash'; safe in closet also contained cash. Gucci bag, designer purses, jewelry, new winter coat with tags still on, and a Mercedes Benz with a temporary tag were photographed. — Government uses these to show lavish lifestyle funded by fraud proceeds; highly prejudicial optics for Bock before the jury. [p. 2085-2088]

▸

Checks found at the residence from food-program entities (S&S Catering Inc., Abduljawad K. Omar, Mako Child Care) made payable to School Age Consultants — Bock's LLC — with memo lines referencing 'worthy purpose,' 'youth connect,' and 'FOF Taylor, Southside Youth.' — Suggests that food program entities were making payments to Bock's personal LLC, potentially as kickbacks or disguised personal enrichment, directly implicating her in the financial scheme. [p. 2092-2094]

▸

Earnings statement for 'Empress M. Watson' at Handy Helpers LLC listing Bock's home address (13299 Bronze Parkway, Rosemount) found in the residence. — Suggests Bock may have been using fictitious employees or shell payroll entities at her home address, relevant to showing fabrication of financial records. [p. 2095]

▸

VIP tickets to Graceland (Elvis Presley's home/museum) found in the residence. — Corroborative of lavish lifestyle funded by fraud proceeds; minor but cumulative of the optics evidence. [p. 2094]

Cross-Examination

Udoibok's cross was extremely brief — two questions only. He confirmed Blackmore was not the case agent and had no independent knowledge of what the documents meant or their context. No further cross was conducted by Montez.

▸

Blackmore admitted he 'just know[s] that [documents] were found on site' and has no information about what they were for. — Blackmore cannot connect any document to the fraud scheme through his own knowledge; prior defense largely succeeded in limiting the damage from this witness. [p. 2096]

Vulnerabilities Blackmore is strictly a custodial/search witness with zero contextual knowledge about the case. He cannot explain the significance of any document or device he found. His role was purely physical: enter, secure, seize, photograph. The lifestyle evidence (luxury goods, cash) is prejudicial but Blackmore cannot explain where the money came from. Defense could have pushed harder on: the absence of any inventory or specific accounting of cash amounts; whether the safe was actually examined for contents; whether the Mercedes was registered to Bock or someone else; and the absence of any chain of custody detail for the digital devices.

For Defense Counsel If this witness appears again, focus cross on chain of custody for digital devices — who extracted the data from the phones/computers, under what protocols, and whether there is any possibility of contamination or misattribution. Also explore whether the 'Empress M. Watson' earnings statement could be from a legitimate employee/contractor rather than a fictitious one. The Graceland tickets and designer bags are pure optics; consider a motion in limine in defense counsel's trial to exclude lifestyle evidence as more prejudicial than probative under FRE 403.

Hanna Marekegn

Owner of Brava Cafe (small coffee shop, 13 seats, in industrial Minneapolis), recruited into the Feeding Our Future food program in September 2020 by FOF employee Eidleh; pled guilty to fraud and is cooperating in exchange for potential sentence reduction.

Cooperating Witness Government

Direct Examination

Marekegn provided the most detailed first-person account of the fraud scheme heard to date in this trial. She testified that Eidleh (an FOF employee referred by her friend Anab Awad) recruited her, pressured her to claim 4,000-5,000 meals per day at a 13-seat cafe that normally served fewer than 10 customers daily, filled out her application for her, instructed her to vary meal count numbers slightly so they 'don't look logistic,' collected 5% kickbacks ($36,000 and other amounts) through shell companies (Eidleh Inc., Hope Suppliers LLC), told her to use her husband's initials on meal count forms, and that she received direct deposits of $200,000-$700,000 per month for meals that were never served. She further testified that she met with Bock personally after becoming a vendor for Shamsia Hopes and House of Refuge, that Bock told her to 'keep doing what you and Eidleh agreed,' and that following a dispute over a $3.1 million invoice for the dry food/meal pack program, Bock demanded $1.5 million cash (50% of the invoice) at a private coffee shop meeting where she instructed Marekegn to leave her phone and Apple watch in the car. When Marekegn refused to pay, Bock terminated her contract. Marekegn also testified that Bock organized community pressure campaigns (calling politicians, claiming MDE was racist) to continue the fraud program.

▸

Eidleh instructed Marekegn to claim 4,000-5,000 meals per day at Brava Cafe, which had 13 seats and fewer than 10 customers per day. 'I did not have employee yet... No, sir' — she never served anywhere near those numbers. — Directly establishes the core fraud: fabricated meal counts at a physically incapable site. This is the clearest evidence that the claimed meals never happened. [p. 2111-2113]

▸

Marekegn paid Eidleh 5% kickbacks through checks to Eidleh Inc. and Hope Suppliers LLC, with false memo lines ('Supplies,' 'Supplies and logistics') that she did not write. Specific amounts: $36,000 (Jan. 2021), $17,000 (Dec. 2020), $39,461 (Feb. 2021), $33,000 (March 2021). — Establishes a kickback scheme through FOF employees and shows deliberate concealment via false memo lines, implicating Eidleh and potentially Bock in the kickback structure. [p. 2129-2131]

▸

Bock told Marekegn at a spring 2021 meeting about the kickbacks to Eidleh: 'just keep doing what you and Eidleh agreed. She didn't want to know the detail of it.' — Most direct evidence that Bock was aware of and ratified the kickback arrangement with Eidleh, even if she claimed ignorance of the specifics. This is critical for establishing Bock's knowledge and intent. [p. 2144]

▸

Bock demanded $1.5 million cash (50% of the $3.1M invoice) at a private coffee shop meeting, instructed Marekegn to leave her phone and Apple watch in the car. 'It's normal in the community get recorded, so she's told me like leave your phone and your watch.' — Consciousness of guilt evidence for Bock — she took active steps to prevent recording of a conversation in which she allegedly demanded a cash kickback. This is the most damning single piece of testimony against Bock. [p. 2157-2159]

▸

After Marekegn refused to pay, Bock terminated her contract. Marekegn then filed a complaint with MDE against Bock for demanding a kickback. — Provides motive for Marekegn to cooperate; also shows Bock's control over site contracts as a retaliatory mechanism. [p. 2159-2160]

▸

Bock organized the East African community to call politicians and MDE, claiming racial discrimination, when the program was paused. Marekegn testified: 'From the beginning until -- was a fraud. We were doing wrong.' Bock 'wanted us to make calls... telling them we get shut down for no reason, and it was race issue.' Marekegn: 'It was not true.' — Establishes that the racial discrimination narrative was itself fabricated and orchestrated by Bock to continue the fraud — devastating to any defense claim that Bock genuinely believed in the mission. [p. 2135-2139]

▸

Marekegn testified that FOF told participants 'COVID fraud is not a fraud,' and that after Bock won her legal dispute with MDE, 'everybody thought nobody can not touch Aimee.' A celebration party was held, attended by all food program participants. Marekegn: 'we can make more fraud too... She knew about the fraud.' — Establishes that winning the MDE lawsuit emboldened participants and that Bock's victory celebration was understood by everyone as a green light to continue defrauding the program. [p. 2139-2165]

Cross-Examination

Udoibok's cross was lengthy but only partially effective. He established that Marekegn does not speak Somali (undermining her ability to understand what was said at the celebration party, which was in Somali), that she continued committing fraud under another sponsor after FOF terminated her, that she stopped only because the program ended (not from conscience), that she used a lawyer to fight for payment of a $3 million invoice she knew was fraudulent, and that she never reviewed any legal filings in the FOF/MDE case. He challenged the plausibility of Bock demanding an impossible $1.5M cash payment. However, he failed to fully exploit her credibility as a self-confessed liar who was simultaneously fighting for money she admitted was fraudulently obtained.

▸

Marekegn does not understand Somali — the language spoken at the celebration party (Government Exhibit BB37a). She testified: 'I don't understand the language.' — Undermines her ability to testify about what was said at the party or what FOF participants understood about the fraud at that event. [p. 2166-2167]

▸

Marekegn continued submitting fraudulent claims through a different sponsor after FOF terminated her. She stopped only because 'the program was done.' When asked if she would have continued: 'Yes, sir.' — Devastating to her credibility as a cooperator — she shows no genuine remorse and stopped only when the fraud opportunity ended, not because of conscience. [p. 2177-2178]

▸

Marekegn hired a lawyer to fight for $3 million in payment she knew was fraudulent. 'You wanted to be paid for that $3 million, didn't you? Yes, sir. And you knew it was all fraudulent. Yes, sir.' — Exposes the mercenary nature of her conduct and the hypocrisy of her later cooperation — she was not a naive participant; she aggressively pursued fraudulently obtained funds through legal channels. [p. 2176-2477]

▸

Marekegn initially said Eidleh demanded '15 percent' before correcting to 5 percent on cross-examination. — Minor but meaningful credibility slip — she confused the kickback percentage during direct testimony, suggesting her recollection or candor may be unreliable on financial details. [p. 2187-2188]

▸

Udoibok established that Bock asking for $1.5 million cash is 'almost impossible' and Marekegn agreed: 'Yes, I know.' He also established that the first time Bock ever asked Marekegn for money was in this single alleged coffee shop meeting. — Defense is building a narrative that the coffee shop demand — the centerpiece of Bock's personal culpability — is implausible and uncorroborated. [p. 2189]

Vulnerabilities Marekegn is a deeply compromised cooperating witness. She is a self-confessed liar, fraud, and mercenary who continued committing crimes after her FOF relationship ended, fought aggressively for fraudulent payments using legal counsel, and admitted she lied on every single meal count form for over a year. Her entire account of Bock's coffee shop demand ($1.5M cash) is uncorroborated — no recording, no witness, no document. She did not speak the language of the celebration party. She has a powerful financial incentive to testify favorably (sentence reduction). She initially misstated the kickback percentage. Importantly, her lawyer was fighting against Bock/FOF for $3M at the very time she was supposedly being victimized by Bock — the timeline of her complaint to MDE, her legal dispute, and the alleged coffee shop demand are potentially inconsistent and worth scrutinizing. Her motive to embellish or fabricate the cash demand is obvious: blaming Bock for the $1.5M demand explains why she filed a complaint and potentially earns her a reduced sentence.

For Defense Counsel Defense counsel should consider: (1) A detailed timeline attack on the coffee shop demand — when exactly did this meeting occur relative to when Marekegn hired a lawyer and filed her MDE complaint? Did she tell her lawyer about the meeting? If not, why not? (2) Prior bad acts argument — she is by her own admission a repeat fraudster who lied on every form. Under FRE 608/609, prior inconsistent conduct is fair game on credibility. (3) The Anab Awad angle — Marekegn's partner Anab Awad, who introduced her to the program and was 'banned' from FOF at some point, is a potentially important but unexplored figure. What did Awad know and when? Did Awad's conflict with FOF color what Marekegn understood or reported? (4) The '$1.5M cash demand' is inherently implausible and entirely uncorroborated — press hard on why Bock would make this demand at a coffee shop when she had lawyers handling the dispute. (5) Challenge cooperation agreement terms — has she reviewed them with counsel? What specifically does she need to do to receive her reduction?

Genesis Alonso

Former Feeding Our Future food program coordinator (data entry), age 19 at time of employment (June 2020 – December 2021), hired through her mother Norma Cabadas/Alonso's friendship with Aimee Bock; provided insider account of FOF's internal operations.

Other Government

Direct Examination

Alonso described her data entry role at FOF — entering menus and receipts into CenterPilot and using Monday.com for internal communications. She testified to specific red flags she observed: duplicate invoice numbers on different invoices from the same vendor (particularly S&S Catering), claims much larger than corresponding receipts, non-food items (including feminine hygiene products) appearing on food receipts, and staff filling out blank site monitoring forms in the office after MDE demanded documentation. She confirmed Aimee Bock signed all checks, had access to the claims email address, had a security camera feed only she could view, and was aware of all red-flag invoices brought to her desk. She also testified that FOF employees received $5,000 bonuses after the MDE stop-pay was lifted, that Salim Said ('Blackie') visited FOF frequently and met privately with Bock, and that the fabricated 2018 'offer letter' to Bock bearing her mother's name ('Norma Cabadas') and signature was fake — her mother was in Texas in poverty at the time and never used that name until 2021.

▸

FOF staff filled out blank site visit forms in the office during the MDE documentation drive. 'I believe they were papers she was just filling out. I don't know if she had went to them.' Alonso testified she brought this to Bock's attention and it 'maybe they were just placed on the desk.' — Establishes that FOF fabricated monitoring records in response to MDE's audit demands — this is obstruction-level conduct that Bock was aware of. [p. 2236-2238]

▸

S&S Catering invoices came in with duplicate invoice numbers on different invoices — 'sometimes they had the same invoice number.' Claims were generally paid despite these red flags. Alonso brought them to Bock's attention; Bock 'put them on her desk' and they got paid. — Shows Bock was personally informed of forged or fabricated vendor invoices and approved payment anyway — directly establishing her knowledge of fraud indicia. [p. 2212-2214]

▸

The 2018 letter offering Bock the executive director job at FOF, purportedly signed by 'Norma Cabadas,' is fake. Alonso: 'It's fake. It's fake.' Her mother was in Texas, unemployed, not going by that name, and Alonso recognized the signature as not her mother's. — The government appears to be using this to show Bock fabricated her own nonprofit's founding documents or governance records — potentially relevant to showing the nonprofit itself was built on fraud from the start. [p. 2250-2251]

▸

Alonso's mother Norma raised concerns about someone being paid to get sites into the FOF program and brought it to Bock — Bock disclosed it immediately to Ikram Mohamed, who then confronted Norma. Norma left feeling 'disrespected'; Alonso left shortly after. — Suggests Bock retaliated against an internal whistleblower by disclosing her identity to the person being accused — relevant to consciousness of guilt and the corrupt culture at FOF. [p. 2282-2284]

▸

Alonso testified that only Aimee Bock had access to the security camera feed in the FOF office, and that Bock signed all checks and had final approval authority over all payments. — Establishes Bock's total operational control over FOF — she could not claim ignorance of what was happening in her own office. [p. 2229, 2280]

▸

Salim Said ('Blackie') visited FOF frequently, met privately with Bock, talked about his 'nice car' and a basketball court in his house. — Shows Said's close operational relationship with Bock and his display of wealth consistent with fraud proceeds; corroborates the broader conspiracy theory. [p. 2244-2246]

Cross-Examination

Udoibok's cross was moderately effective for Bock. He established that Alonso did not know the content of the FOF lawsuit against MDE, was not present for the protest, was not involved in site visit decisions, had no independent knowledge of why meal counts were large, and could not see into Bock's office from her own workspace. He also got Alonso to admit that the camera may have been for security, that Bock screened visitors, and that other managers (Coley, Hadith, her mom) were her immediate supervisors — not Bock directly. Montez cross-examined briefly on the Safari visit, establishing that food was being distributed and cars were arriving.

▸

Alonso admitted she did not know whether site coordinators conducted remote site visits (via Zoom/phone), which could explain why staff were completing forms in the office. — Opens a potential defense argument that the paperwork being completed in the office represented remote visit documentation rather than outright fabrication. [p. 2257-2259]

▸

Montez elicited that at the Safari site visit, Alonso saw food being given out in boxes to cars pulling up. She estimated 10-15 cars in under an hour, but could not determine quantities of food in the boxes. — Provides a defense data point that food was actually being distributed at Safari — though far below the claimed numbers. [p. 2276-2277]

▸

Alonso confirmed that Bock disclosed her mother's whistleblower concern to Ikram Mohamed 'right away,' causing a confrontation with her mother. — Udoibok spun this on redirect as evidence that Bock investigated the allegation — however the jury can also read it as Bock protecting her inner circle at the expense of a loyalist employee. [p. 2286-2287]

Vulnerabilities Alonso was 19 years old, worked in data entry, and had limited visibility into management decisions. She freely admitted she did not know many things: what was discussed in Bock's meetings, the contents of the lawsuit, whether site coordinators did remote visits, how checks were specifically issued. Her account of the fabricated site visit forms is secondhand in the sense that she saw a coworker filling forms out but cannot confirm those forms were fraudulent versus documentation of remote visits. The 'Norma Cabadas' letter is explosive but Alonso's only basis for calling it fake is her own knowledge of her mother's whereabouts and signature — she was not present for any discussions between Bock and her mother in 2018.

For Defense Counsel Defense counsel should explore: (1) Remote site visit documentation — whether FOF had any protocol for phone or video-based check-ins that could explain forms being completed in the office; (2) The 'generic menu' practice — Alonso admitted this was standard procedure for sites serving ethnic foods not in CenterPilot's dropdown; this could support a narrative that FOF was adapting to software limitations rather than fabricating meals; (3) The fabricated letter — who actually created this document? Was it introduced through Bock's email? If so, when was it created relative to 2018? The metadata would be critical; (4) The Monday.com 'read receipts' — Alonso admitted everyone got notifications and had access; Bock's 'bubble' appearing does not mean she read the specific flagged content in any meaningful way.

Valerie Eastwood

FBI Special Agent (13 years) assigned to counter-terrorism; participated as a searcher in the January 20, 2022 search warrant execution at Salim Said's Plymouth, MN residence (5150 Alvarado Lane); introduced physical documentary evidence seized from that search.

FBI Government

Direct Examination

Eastwood authenticated search photographs of Said's large Plymouth home (including an indoor basketball/sport court, two-car garage with Mercedes SUV and pickup truck, bar area) and introduced multiple documentary exhibits found in hard copy at the residence: an MDE letter denying Said-linked sites (Hmong Village, ASA Limited, Olive Management, Safari Restaurant) for CACFP 2022; blank but signed Feeding Our Future meal count forms for 'Southcross' site; a filled meal count form for Stigma-Free Mankato found in Said's home; a Bridgewater Bank account closure letter to Cosmopolitan Business Properties LLC; two cashier's checks totaling ~$727,000; a Wells Fargo business account application for Salim Limited LLC (filed two days after the Bridgewater closure); payment receipts from Cosmopolitan Business Solutions to Salim Limited ($277K, $270K, $240K); a $470,000 check from Salim Limited to Lupient Chevrolet; three unsigned consulting agreements between 'Sirta Salim Limited' and clients (Brava Restaurant/Rochester, Mankato, Willmar); and a $2.78 million property purchase agreement signed by Said.

▸

Blank but signed Feeding Our Future meal count form (GG4) for 'Southcross' site found in Said's home — signed at the bottom certifying accuracy, but all data fields are blank. No date, no week, no meal counts. — Pre-signed blank forms found in Said's home are powerful evidence of fraud infrastructure — they show Said (or those in his orbit) maintained forms ready to be filled in with fabricated numbers. [p. 2307-2309]

▸

An MDE denial letter dated December 3, 2021 (addressed to Aimee Bock) listing Said's sites — Hmong Village ASA, ASA Limited, Olive Management, and Safari Restaurant — as denied for CACFP 2022 was found printed in Said's residence. — Said possessed an MDE correspondence addressed to Bock about his own sites' denial — suggests close coordination between Said and Bock, and that Said was tracking the regulatory status of his sites. [p. 2305-2306]

▸

Internal MDE staff chat (GG2) found printed at Said's home, showing MDE employees discussing Stigma-Free Willmar's implausible claim of 3,000 meals when the Willmar school district only had 4,100 students total, and that a local MDE contact 'Annette in Willmar' was 'unaware of this organization about three blocks from her that serves 3,000 meals.' — Said possessed internal MDE investigative communications — potentially showing that either someone inside MDE leaked this to Said or FOF, or that Said obtained this through other means. This is a highly significant document. [p. 2303-2305]

▸

Bridgewater Bank closure letter (July 7, 2021) to Cosmopolitan Business Properties stating the bank was closing the account because activity 'exceeded the services and capabilities for monitoring.' Two days later, Said opened a new Wells Fargo business account for Salim Limited LLC. — Shows Said's entity was flagged by a bank for suspicious activity and he immediately opened a new account at a different bank — classic financial concealment/structuring behavior. [p. 2311-2313]

▸

Three unsigned consulting agreements between 'Sirta Salim Limited' and sites (Brava/Rochester, Mankato, Willmar) with identical boilerplate language, found in Said's home. — These appear to be template contracts designed to create the appearance of legitimate consulting relationships between Said's entity and food program sites — potential evidence of fabricated business justifications for money flows. [p. 2319-2322]

▸

Purchase and sale agreement signed by Said (as general manager/president of Cosmopolitan Business Properties) for a $2.78 million Minneapolis property at 2722 Park Avenue South, dated June 23, 2021. — Demonstrates the scale of Said's financial activity during the fraud period and the government's theory that fraud proceeds funded real estate acquisitions. [p. 2323-2324]

Cross-Examination

No cross-examination was conducted by either defense attorney.

Vulnerabilities Eastwood, like Blackmore, is a search witness only — she was not the case agent and has no contextual knowledge of the fraud scheme itself. She cannot explain what documents mean, how they connect to the conspiracy, or whether the consulting agreements were actually used for legitimate purposes. The blank signed meal count form (GG4) could theoretically have been pre-signed for administrative convenience rather than fraud preparation. The MDE internal chat (GG2) possession by Said raises significant questions about how he obtained it that Eastwood cannot answer. The consulting agreements being unsigned could be interpreted as meaning they were never executed (i.e., never actually used to conceal money flows).

For Defense Counsel Defense counsel should investigate: (1) The GG2 MDE internal chat — how did Said obtain an internal MDE staff communication? If this came through FOF's litigation discovery or was shared by an MDE contact, it could have an innocent explanation; alternatively, it could be a powerful additional lead. (2) The blank pre-signed meal count form (GG4) — challenge the government's interpretation; explore whether FOF had any practice of pre-signing forms as an administrative convenience and filling them in later. (3) Chain of custody for all documents — Eastwood admitted she did not recognize GG25 as something she personally seized. How were items logged and tracked? Is there any possibility of misattribution? (4) The Bridgewater closure — explore whether the closure was for routine monitoring reasons unrelated to fraud (banks sometimes exit relationships for non-fraud reasons).

Key Evidence

Type	Exhibit	Description	Page	Challenge Opportunity
Document	Gov. Ex. BB1	Photographic log from the January 20, 2022 search of Aimee Bock's residence at 13299 Bronze Parkway, Rosemount, MN. Includes entry/exit photos showing luxury goods, cash in nightstand and safe, designer purses (Gucci, Louis Vuitton), jewelry including a custom 'Aimee' necklace, new white Mercedes Benz with temporary tag, and MacBook/cell phone.	[p. 2084-2088]	Photos show items exist but cannot establish origin of funds. Many items could have been legitimately purchased. No cash amounts are specified. The Mercedes had a temporary tag — unknown if it was Bock's or a visitor's. Consider FRE 403 motion in future trials.
Financial Record	Gov. Ex. BB2	Bank of America statement for School Age Consultant LLC, with Aimee Marie Bock listed as the account holder at 202 North Cedar Avenue, Suite 1, Owatonna, MN — seized from Bock's residence.	[p. 2092]	School Age Consultant may have been a legitimate consulting business. Government must prove the specific payments into this account were fraudulently obtained.
Financial Record	Gov. Ex. BB3	Copies of checks seized from Bock's residence: from S&S Catering Inc. to School Age Consultants ($2,800, Jan. 10, 2022); from Abduljawad K. Omar to School Age Consultants ($2,800, Jan. 5, 2022, memo: 'Worthy purpose to'); from Mako Child Care to School Age Consultants ($5,600, Jan. 11, 2022, memo: 'worthy work/youth connect'); from I-Care Home Health Care LLC to School Age Consultants ($5,600, Jan. 11, 2021, memo: 'FOF Taylor, Southside Youth'). Also a Bank of America deposit slip showing $65,000 deposit with available balance of $2.76 million.	[p. 2092-2094]	The payments could reflect legitimate consulting or administrative fees. Government must tie each check to fraudulent reimbursements. The $2.76M balance could reflect legitimate reserves.
Document	Gov. Ex. GG2	Printed hard-copy screenshot of an internal MDE staff chat (participants include Jenny Butcher @state.mn.us, Cindy Anderson, Camille Jones), discussing suspicions about Stigma-Free Willmar claiming 3,000 meals/day when the local school district only has 4,100 students and a local contact 'Annette in Willmar' was unaware of the organization. Found at Salim Said's Plymouth residence.	[p. 2303-2305]	How this document came to be in Said's home is unexplained. It may have been obtained through litigation discovery in the FOF v. MDE case, which would be completely legitimate. Government needs to explain the provenance.
Document	Gov. Ex. GG4	Feeding Our Future after-school meal count worksheet for 'Southcross' site, signed at the bottom by supervisor Kiin Anod certifying accuracy, but with all data fields (week of, date, meal counts) completely blank. Found in hard copy at Said's Plymouth residence.	[p. 2307-2309]	The form could have been pre-signed as administrative convenience and simply never completed. There is no direct evidence Said himself created or intended to use this form fraudulently.
Document	Gov. Ex. GG6	Bridgewater Bank account closure letter dated July 7, 2021, to Cosmopolitan Business Properties LLC at 2722 Park Avenue South, Minneapolis, stating the account was being closed because activity 'exceeded the services and capabilities for monitoring.' Found at Said's Plymouth residence.	[p. 2311]	Banks close accounts for many reasons unrelated to fraud (e.g., business volume, compliance costs). The letter does not say 'fraud' or 'suspicious activity' explicitly — it uses euphemistic language.
Document	Gov. Ex. GG24	Purchase and sale agreement signed by Salim Said as general manager/president of Cosmopolitan Business Properties LLC, for the purchase of property at 2722 Park Avenue South, Minneapolis, for $2,780,000, dated June 23, 2021.	[p. 2323-2324]	Said may have had legitimate business income. Government must trace the actual source of funds used for the purchase.
Document	Gov. Ex. GG25, GG26, GG27	Three unsigned consulting agreements between 'Sirta Salim Limited' (consultant) and three clients: Brava Restaurant/Rochester (GG25), 'Mankato' (GG26), and 'Willmar' (GG27). All contain identical boilerplate 'services provided' language. None are signed or dated. Found at Said's Plymouth residence.	[p. 2319-2322]	Unsigned agreements are not contracts and may never have been used. The existence of templates could reflect legitimate business planning. Government must establish a link between these templates and actual fraudulent money flows.
Document	Gov. Ex. AA5	Physical T-shirt seized from FOF with text: 'FOF feeds our kids. MDE won't.' — worn by FOF employees and community members at a rally/protest at MDE during the legal dispute.	[p. 2240-2241]	The shirt reflects a legitimate political/advocacy position that FOF was entitled to take. Advocacy against a government agency is protected activity.
Document	Gov. Ex. A4	Email from Aimee Bock attaching a fabricated 2018 offer letter to herself as FOF executive director, purportedly signed by 'Norma Cabadas,' offering a $85,000 salary. Alonso testified the letter is fake — her mother was in Texas, unemployed, not using that name in 2018, and the signature is not her mother's.	[p. 2247-2251]	The government has not yet established who actually created the document or when the email was sent. Metadata analysis of the PDF would be critical. The letter's purpose and how it was used are not yet clear from this testimony alone.

Legal Rulings & Objections

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At sidebar, Udoibok objected to the admission of text message exhibits (BB30a-f, BB32a-d, BB41a-e, BB50-53) from devices seized at Bock's residence, citing inability to review them and potential hearsay. Government responded that the exhibits were being offered for foundation only (not published to jury) and that computer reports had been disclosed for 'weeks or months' with some text clips coming in 'in the last couple days.' Court admitted all exhibits. — Defense raised a legitimate late-disclosure concern that the court effectively dismissed. In defense counsel's trial, any late-produced digital evidence should be challenged with a formal motion to exclude or for a continuance — the court's tolerance here for rolling disclosure of digital evidence is a risk for future defendants. [p. 2090-2091]

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Udoibok objected (leading) to Thompson's question to Marekegn: 'What were the sites under the sponsorship of Feeding Our Future doing? How were they doing wrong?' Court overruled. — The court is allowing broad leading questions on direct that essentially invite cooperating witnesses to confirm prosecution theories. Defense counsel should be prepared to see this pattern continue and consider when objections are worth making versus when they draw attention to damaging testimony. [p. 2136]

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Udoibok objected to Thompson asking Marekegn whether Aimee Bock 'knew that the people in the program were making a lot of money,' arguing it called for speculation. Court overruled and allowed the witness to answer if she could. — Court is giving cooperating witnesses wide latitude to testify about the mental states of co-conspirators. This is standard co-conspirator exception territory but worth challenging in future trials. [p. 2137]

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Udoibok objected to Bobier showing the jury the 'Norma Cabadas' offer letter (Government A4) on hearsay grounds. Government responded it was 'not offered for the truth.' Court overruled over repeated hearsay objections. — The government is admitting a fabricated document (not for truth) to show that Bock possessed and transmitted a fake employment letter — this is an operative fact/verbal act theory. defense counsel's team should be prepared to address how fabricated documents in clients' files will be handled and whether limiting instructions can be obtained. [p. 2709-2712]

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Udoibok objected (foundation) to Udoibok's own question to Marekegn characterizing the FOF/MDE legal action as a 'discrimination lawsuit.' Thompson objected on foundation (she hadn't reviewed the lawsuit). Court sustained Thompson's objection to the follow-up but overruled the initial foundation objection. — The court is carefully managing the characterization of the FOF v. MDE litigation — preventing defense from mischaracterizing it as a 'discrimination lawsuit' when it was actually a mandamus action. This is a subtle but important distinction that could affect how Bock's motivations are framed. [p. 2184-2185]

Prior Defense Performance

Prior defense counsel had a mixed day. Udoibok's cross of Blackmore was perfectly appropriate — brief, targeted, limited to establishing Blackmore had no contextual knowledge. His cross of Marekegn was the most important work of the day and was partially effective: he scored points on her language limitations, her continued fraud after FOF, her mercenary pursuit of payment, and the implausibility of the $1.5M cash demand. However, he left significant ground unexplored: he never attacked the timeline of the coffee shop meeting versus her legal dispute; never confronted her with the specific dates of her lawyer engagement versus the alleged meeting; never probed whether she told her lawyer about Bock's demand; never challenged the financial math on her kickback claims (did 5% of her receipts match her claimed payments to Eidleh?); and never explored the Anab Awad relationship in depth. His cross of Alonso was adequate — he established her limited vantage point and the alternative explanations for some concerning observations — but he missed an opportunity to press harder on the 'Norma Cabadas' letter (conceding it was fake instead of probing its creation). His cross of Driscoll and Eastwood was appropriately waived given those witnesses' limited scope. Montez's cross of Alonso on the Safari visit was brief and targeted — appropriately establishing that food was being given out. The most significant missed opportunity was not challenging Eastwood on the provenance of the GG2 MDE internal chat document found at Said's home — this is potentially the most revealing piece of evidence suggesting either an MDE leak or legitimate litigation discovery.