Trial II · 22cr223

Vol XII

2025-02-27

Day Overview

Volume XII covers nearly a full trial day. It opened with the conclusion of IRS Special Agent Joshua Parks's cross-examination by both defense teams, focusing on whether Bock had any direct role in creating or sending the fake rosters — Parks conceded she did not personally create them but on redirect established she collected thousands of pages of rosters and that FOF's own sites had duplicate-named rosters found in physical files. Cooperating witness Mohamed Hussein then testified at length on direct: he and his wife Lul Ali ran fraudulent SFSP/CACFP sites through Lido Restaurant and his nonprofit SAFE, claimed up to 2,500 meals per day they never served, and paid Aimee Bock $30,000/month in cash and an additional ~$100,000 in checks through Eidleh, all coordinated via FaceTime. John Senkler, a bartender and social acquaintance of Bock, confirmed she recruited him as a nominal board member in 2016 with no expectation of actual duties — and board minutes show his name appearing at meetings he never attended. FBI SA Wilmer closed the day by linking phone data to the scheme: Bock texting Salim Said pictures of million-dollar Stigma-Free checks the day they were cut; Said's phone holding rosters identical to those seized at FOF; shell-company registrations for the Jama family paid for by Said; and email chains showing FOF's attorney threatening racism lawsuits against MDE within days of any compliance question, forcing site approvals in under 48 hours. Defense counsel should pay close attention to Hussein's FaceTime testimony — it is the most direct evidence of Bock's personal knowledge and direction — and to the gaps and inconsistencies defense cross revealed.

Government Strategy

The government continued its multi-layered narrative of systemic, coordinated fraud. With Agent Parks's cross-examination wrapping up, the government used redirect to neutralize the defense's COVID-waiver argument and hammer home the absurdity of fabricated roster names (Amen Love, Putify Nop). The government then introduced Mohamed Hussein, a cooperating guilty-plea witness whose wife had already testified, to deliver direct first-person testimony that Aimee Bock personally — via FaceTime through her agent Eidleh — instructed sites to falsely claim 1,000–2,000 meals per day, collected 15% off the top of every check, demanded $30,000/month in cash kickbacks, and warned site operators not to buy conspicuous assets. John Senkler was called to show Bock used unsuspecting acquaintances as sham board members, lending false legitimacy to Feeding Our Future. FBI Special Agent Travis Wilmer returned to synthesize prior testimony, introduce new phone data from both defendants (texts showing real-time coordination over checks, rosters on Said's phone matching those found at FOF, shell-company registration confirmations), and document FOF's aggressive legal intimidation of MDE via racism allegations to force approval of fraudulent sites.

Strategic Notes for Defense Counsel

• The FaceTime narrative is the spine of the government's case against Bock and its most vulnerable link. Mohamed Hussein's entire account of Bock's personal direction rests on observing Eidleh's phone during a FaceTime call. Defense counsel must immediately subpoena Eidleh's complete phone records, Bock's phone records (already seized), and any FaceTime/Apple logs showing calls between their numbers. If those calls don't exist, Hussein's core testimony is impeachable. Eidleh himself — who is apparently not yet testifying — may be the single most important witness in the case. • The government's 'keeping the pressure on MDE' narrative (rally, legal threats, racism accusations) can be reframed as evidence that Bock genuinely believed in the legitimacy of her program and fought for it — not consciousness of guilt. Defense counsel should commission an expert on USDA/CACFP program history to testify about genuine discrimination against Somali-owned food businesses during this period, which would give the jury an innocent explanation for aggressive advocacy. • The sham board evidence (Senkler) is damaging but under-explored. Prior defense did almost no cross. Defense counsel should investigate who actually drafted and submitted the board minutes — if a specific staff member did so without Bock's direction, that is exculpatory. The board legitimacy issue goes to Bock's knowledge of FOF's legal obligations, not directly to whether meals were served. • Wilmer's testimony synthesizing phone data is sweeping but based on selective review (his own admission). Before his cross in the next volume, Defense counsel must obtain a full forensic extraction of both defendants' phones and have an independent analyst run a complete content analysis — the government's 'extremely few food communications' vs. 'numerous check communications' summary should be challenged with actual counts. • The COVID-waiver/roster-necessity argument was blocked through Parks but survives as a closing argument. Defense counsel must identify and retain a USDA or MDE regulatory expert who can testify about the precise scope of COVID waivers (whether rosters were required during the specific time periods charged), because the prior defense tried and failed to introduce this theory through a witness who lacked personal knowledge of the regulations.

Witnesses

Joshua Parks

IRS Criminal Investigation Special Agent who analyzed fraudulent meal-count rosters submitted by Feeding Our Future sites, comparing names against public school enrollment data.

IRS/Forensic Government

Direct Examination

Parks had testified the prior day about fabricated rosters. On redirect after cross, he explained that Aimee Bock and Feeding Our Future collected thousands of pages of rosters, that the names were immediately obviously fake upon first review, and that FOF's own maintained sites (Taylor and Southside Youth) had duplicate children's names across simultaneously submitted rosters.

▸

Parks stated: 'The first roster that I opened I didn't believe it to be true. The names were ridiculous.' He cited 'Amen, Praise and Blessings all in one family, all with the last name of Love' and 'Putify Nop' and 'Mopey Nop' as examples of obviously fake names. — Preempts any defense claim that FOF staff could have been deceived by rosters — Parks established the fabrication was patent on its face to any reviewer. [p. 2639]

▸

Aimee Bock received rosters in emails, her organization received them, her employees received them, and rosters were found in search warrants at Feeding Our Future — Parks estimated 'thousands' of pages. — Directly counters defense argument that Bock had no connection to the rosters by establishing she was a collector and holder of them. [p. 2640]

▸

Rosters for FOF's own Taylor site and Southside Youth (the graffiti building under surveillance) were submitted simultaneously in November 2021 and found in Bock's physical files with duplicate children's names across both. — Ties Bock directly to the roster fraud at sites she personally operated, not just sites she sponsored. [p. 2641-2642]

Cross-Examination

Mr. Udoibok (for Bock) methodically walked through every roster-related exhibit and elicited concessions that Bock did not send, create, or author any of the emails or Excel attachments containing the fake rosters. Mr. Montez (for Said) established a timeline showing Abdihakim Ahmed of ASA was communicating with 'Faaris Studio' to generate fake surnames before those rosters ever reached Said or FOF. Parks also admitted he did not review USDA COVID-era waiver regulations and relied on MDE witnesses for program rules, did not check private or charter school records, and that his broader comparisons to neighboring districts were not documented.

▸

Parks admitted: 'I did not have private school records' and 'I did not' check charter schools when comparing roster names to enrollment. — Opens methodological challenge: Parks's analysis excluded private schools, charter schools, and home-schooled children, potentially undercounting legitimate eligible kids — though Parks testified he looked at Census home-school data and neighboring districts. [p. 2621, 2629-2630]

▸

As to every roster exhibit in the summary charts (LL3 through LL10, C20-C48, Z12, K3, P22), Parks conceded: 'Not on this summary chart' when asked whether Bock sent any roster to anyone. He also conceded he had no evidence Bock created any specific roster. — Creates a clean record that Bock's direct fingerprints are absent from the roster creation and distribution chain — useful for a distancing argument. [p. 2618-2628, 2643]

▸

Parks admitted he did not consult the USDA regulations governing the food program and relied on MDE employees for his understanding of the program rules. — Potential foundation for attacking the entire investigation's regulatory framework, though the court blocked most follow-on questioning on waivers as argument rather than fact. [p. 2613-2614]

▸

Montez established: Abdihakim Ahmed emailed 'Faaris Studio' at 2:44 p.m. on October 7, 2021 asking it to make all children ages 6–17; Faaris Studio responded at 7:14 p.m. with a list of surnames with hyperlinks to a name-generator website; Ahmed then emailed Said and TFS Auditors at 9:32 p.m. with the populated roster — Said never asked for fake names and was downstream of that chain. — Creates the cleanest trial record separating Said from the mechanics of roster fabrication; the scheme was initiated by Ahmed, not Said. [p. 2633-2637]

▸

Parks stated his broader analysis (looking at multiple school districts, neighboring cities, Census home-school data) was 'not documented in the summary rosters I've shared.' — The undocumented nature of Parks's broader methodology is a discovery and Daubert target — if defense counsel's client is charged and Parks testifies, demanding full documentation of this analysis is critical. [p. 2732]

Vulnerabilities Parks's most significant vulnerability is methodological: he excluded private schools and charter schools from his comparison, did not review USDA regulations (relying instead on MDE informants), and did not document his expanded analysis. His analysis can be attacked as incomplete and circular — he was told by MDE what was required, then investigated based on those representations, never independently verifying the regulatory framework. He also admitted the first roster comparison he did with neighboring school districts was undocumented. A Daubert challenge to his roster analysis methodology is viable. Additionally, his concessions that Bock personally created no roster and sent no roster were clean wins for the prior defense — they could be used to argue she was as much a victim of site operators submitting fake documentation as she was a participant.

For Defense Counsel If Parks testifies in defense counsel's trial: (1) mount a Daubert challenge to the roster comparison methodology based on failure to document expanded school-district analysis; (2) obtain all raw data underlying his comparisons; (3) commission an expert to quantify home-schooled, private, and charter school children in the relevant geographic areas; (4) focus cross on the fact that Parks himself never reviewed program regulations — only took MDE's word for what was required; (5) explore whether COVID waivers were in effect during the periods at issue through an independent USDA/regulatory expert rather than through Parks, since the court blocked that line.

Mohamed Hussein

Pled-guilty co-defendant and husband of prior government witness Lul Ali; operated two fraudulent Feeding Our Future food sites (Lido Restaurant and SAFE nonprofit) in Faribault, MN, and testified he paid kickbacks directly to Aimee Bock via her agent Eidleh.

Cooperating Witness Government

Direct Examination

Hussein testified extensively about how he and his wife were recruited into the program by Shafi (a FOF employee), then taken over by Eidleh, and how Aimee Bock personally instructed them via FaceTime — on Eidleh's phone — to claim 1,000 meals per day at Lido Restaurant and 2,000–2,500 per day at SAFE, promising 'American dream' wealth. He confirmed the meal counts were entirely fabricated, the invoices (including a $12,000 fake sugar invoice from 'Banadir Restaurant') were made up, and that he paid Bock $30,000/month in cash plus ~$100,000 in checks to Bridge Logistics LLC on Eidleh's instruction. He testified that Bock warned site operators at an in-person meeting not to buy cars or houses to avoid scrutiny, and described her termination threat if payments weren't made. He received approximately $3.17 million from SAFE and millions more through Lido, used to buy two houses and luxury cars, all forfeited.

▸

Hussein testified Bock told him via FaceTime: 'When you doing the meal counts, write down 1,000, you provide foods for 1,000 kids every day' and 'if you do 1,000 meal every day, you are going to get more money. You are going to get big check.' He stated: 'We never feed 1,000 kids meal, ever.' — This is the most direct evidence of Bock personally instructing a site to falsify meal counts — it goes directly to her knowledge and intent. [p. 2661-2663]

▸

Hussein testified Bock said 'I will give you 1,000 meal every day' — and clarified she meant to write that number on paper, not actually provide food. He confirmed she told him 'more invoices, more money' and instructed him to create fake invoices. — Establishes Bock as the architect of the invoice inflation scheme, not merely a passive administrator. [p. 2663-2664, 2688-2689]

▸

Hussein testified: 'He say we, we be, you pay 30,000 cash. And then before the check comes, we cut 15 percent, and then that's how I work, she said.' He confirmed: Eidleh called Bock on FaceTime every month when collecting $30,000, saying 'I have the money in my hand.' — Directly connects Bock to the kickback scheme with specific dollar amounts and corroborated by bank records (checks to Bridge Logistics LLC confirmed at Exh. W62). [p. 2666-2667, 2678]

▸

At an in-person office meeting, Hussein testified Bock told assembled site operators: 'You guys don't buy cars, don't buy houses' and 'you become obvious, people can see you easier' — interpreted by Hussein as concealing the fraud proceeds from government scrutiny. — Consciousness-of-guilt evidence that Bock instructed participants to conceal wealth to avoid detection — potentially relevant to obstruction or concealment charges. [p. 2694-2697]

▸

Hussein testified SAFE received approximately $3.17 million from Feeding Our Future over ten months (confirmed by Exhibit X1), for meals never served. — Concrete quantum of loss traceable to Bock's program — will be used by forensic accountants to establish total fraud damages. [p. 2715]

Cross-Examination

Udoibok attacked the FaceTime narrative — noting Hussein could not identify what kind of phone Eidleh used, did not know FaceTime leaves records, and never directly communicated with Bock by phone himself. Hussein admitted he met Bock in person only once, that all communications ran through Eidleh, that he himself created the fake invoices and meal counts, that he initially lied to the FBI out of fear, and that he hopes for leniency at sentencing. The defense partially eroded the chain of attribution but could not dislodge the core FaceTime narrative. No cross was conducted by Montez for Said.

▸

Hussein admitted: 'I met one time in her office' when asked if he would not have committed fraud had he not met Bock — establishing the relationship was mediated almost entirely through Eidleh. — Creates distance: Hussein's direct dealings were with Eidleh, not Bock. If Eidleh is acting autonomously (or implicating Bock falsely to protect himself), that chain is severable. [p. 2874]

▸

Hussein admitted he never called Bock directly, Bock never called him directly, and all FaceTime contact was through Eidleh's phone — and he cannot identify the type of phone Eidleh used or confirm FaceTime records exist. — The entire kickback-payment FaceTime narrative depends on a chain: Eidleh calls Bock, Hussein observes a face on a screen. If phone records don't corroborate FaceTime calls between Eidleh and Bock at those times, the testimony is impeachable. [p. 2707-2714]

▸

Hussein acknowledged: 'Did Ms. Bock suggest that you use Sysco? No.' and 'Did Ms. Bock tell you to spend that money the way you did? No. I did it my own.' He created the fake invoices himself and signed all the meal counts himself. — Limits Bock's direct liability for specific fraudulent acts Hussein committed independently — he exercised his own judgment in executing the fraud even if instructed generally to inflate. [p. 2676-2677, 2715-2716]

▸

Hussein admitted that in his initial 2022 FBI interview he 'wasn't tell everything I knew for involvement' because he was scared — and that he decided to cooperate only after getting a lawyer and pleading guilty. He has not yet been sentenced and hopes for leniency. — Standard cooperator bias: his entire testimony is colored by the hope of a reduced sentence and an admission of prior dishonesty with law enforcement. [p. 2654, 2748-2749]

▸

Hussein acknowledged that his wife Lul Ali testified before him, that he drove her to the courthouse, and that he knew she was testifying — though he denied discussing the substance of her testimony. — Potential witness coordination issue between husband and wife, both cooperating witnesses; worth exploring whether they discussed their accounts prior to testifying. [p. 2751-2753]

Vulnerabilities Hussein is the government's most powerful cooperating witness and also its most vulnerable. His entire narrative of Bock's personal involvement rests on FaceTime observations through Eidleh's phone — never independently corroborated by phone records admitted into evidence during his testimony. He admitted lying to the FBI initially, has a strong sentencing incentive, and all direct contact with Bock was mediated through Eidleh. His wife testified earlier and they drove to court together, raising coordination concerns. His English comprehension issues caused repeated confusion during cross. Hussein admitted he created the fake invoices and meal counts himself without direction for each individual document. His identification of 'Bridgewater' as the Bridge Logistics payee was confused. He could not specify the months he paid cash versus checks or how many cash payments he made. Udoibok's cross was hampered by the court sustaining 'asked and answered' objections repeatedly — some potentially legitimate cross was cut off.

For Defense Counsel Defense counsel must obtain Eidleh's phone records to verify or impeach the FaceTime calls Hussein described. If Eidleh's phone shows no FaceTime calls to Bock's number at the times Hussein described, the entire kickback narrative collapses. Additionally: (1) Eidleh himself should be subpoenaed or called — he is the linchpin and his testimony or invocation of Fifth Amendment rights are both powerful; (2) subpoena Hussein's own phone records to check for any direct contact with Bock; (3) explore whether husband-and-wife cooperators discussed their testimony (potentially grounds for a Sixth Amendment/witness-coaching inquiry); (4) attack the 'American dream' and 'don't buy cars' statements as ambiguous — nothing Hussein said proves Bock knew the program was fraudulent, as opposed to simply knowing it was lucrative; (5) press on the gap between Hussein's general instruction narrative and his independent execution of specific fraudulent invoices.

John Senkler

Bartender and social acquaintance of Aimee Bock, recruited as a nominal Feeding Our Future board member in 2016 with no actual duties, whose name appeared on fabricated board meeting minutes he never attended.

Other Government

Direct Examination

Senkler testified he met Bock at Fabulous Fern's bar 2010–2015, was briefly hired by her to deliver meals in summer 2016 (distributing 50–100 real lunches per day), and at the end of 2016 was asked to join the FOF board while having drinks at a bar. He thought it was a joke, was told by Bock she just needed names temporarily and would dissolve the initial board, said fine, and then never thought about it again. He was shocked in 2022 when a friend sent him a news article listing him as a board member. Board minutes (Exh. A80) showed his name as secretary at multiple meetings he never attended, with motions he never made.

▸

Bock told Senkler she 'just needed names to start the organization and was going to dissolve it, the board, once the organization got going and create a new board internally.' Senkler responded he could put his name on it and understood he would have to do 'absolutely nothing.' — Establishes that Bock knowingly created a sham governance structure with no-show board members — directly relevant to the fraud scheme's design to appear legitimate while being hollow. [p. 2760-2761]

▸

Board minutes (Exh. A80) showed Senkler listed as 'secretary,' present at multiple meetings including a March 2020 board meeting, a conference call where he supposedly 'made a motion,' a January 2021 meeting, and an April 2021 special meeting — none of which he attended. — Fabricated board minutes submitted to regulators or funders as evidence of governance constitutes an independent fraud on MDE and the USDA. [p. 2762-2765]

▸

When Senkler texted Bock in 2022 after learning from a news article that he was on the board, she replied she would contact him later and never did. — Bock's failure to return contact after the investigation became public reflects consciousness of guilt — she did not want to address the sham board issue with someone who could expose it. [p. 2765]

Cross-Examination

Udoibok's cross was minimal: confirmed the timeline (met 2010–2015, asked to join board 2016, last personal contact 2016), confirmed Senkler never received any MDE correspondence, and asked whether Senkler knew who completed the board documents. Senkler said he did not. Very brief cross. Montez had no questions.

▸

Senkler confirmed he never received any correspondence from MDE as a board member and did not know who completed the board meeting documents. — While useful background, this does little to undermine the core point — Bock recruited him knowing he'd be a placeholder, and then fabricated his attendance at meetings. [p. 2767]

Vulnerabilities Senkler is a sympathetic, low-stakes witness whose testimony is largely one-directional against Bock. His vulnerability is that Bock could argue she legitimately intended to replace the founding board (as she told him) and that the board minutes were prepared by staff without her direction. There is no evidence she personally signed or submitted the fake minutes. However, these arguments are weak given that board minutes showing his attendance are in evidence. A stronger defense angle: the sham board arguably predates the period of criminal conduct and could be argued to be negligent governance rather than fraud.

For Defense Counsel Senkler adds institutional-fraud evidence against Bock that is hard to contest. defense counsel's best approach: (1) focus any cross on who actually prepared the board minutes — if a staff member did so without Bock's knowledge or direction, that employee could be the responsible party; (2) explore whether nonprofits commonly use informal founding boards before formalizing governance; (3) note that Senkler himself had no harm — he was not defrauded, and the fake board minutes were an internal governance issue. This witness is likely not worth extended cross in defense counsel's trial unless the board governance is central to his client's charges.

Travis Wilmer

FBI Special Agent assigned to the white-collar squad, Minneapolis, who served as the case's in-court agent throughout trial; testified about phone data from both defendants, the Stigma-Free franchise model, kickback evidence, shell company registrations, and Feeding Our Future's legal intimidation of MDE.

FBI Government

Direct Examination

Wilmer was re-called to synthesize prior testimony and introduce new evidence from phone extractions and search warrants. He covered: (1) the roster-waiver issue, testifying rosters were required during the investigation period; (2) Bock texting Said photos of two million-dollar-plus Stigma-Free checks the day they were cut (Exh. BB30a); (3) rosters saved on Said's phone matching those found in paper at FOF (Exh. GG39 vs. G50); (4) shell-company registration confirmations (GG33–36) on Said's phone corroborating Jama testimony; (5) the Afrikan Village LLC Ohio building purchase funded by food-program proceeds; (6) Bock's June 2021 text to Said organizing the MDE rally ('keep the pressure on,' Exh. BB30b); (7) April–May 2020 email chain (Exh. A21 and A23) in which FOF's attorney threatened racism lawsuits to force MDE to approve eight sites within 48 hours, characterizing routine compliance questions as 'the epitome of systemic racism.' Wilmer also testified that his review of Bock-Said texts showed communications were predominantly about check availability, not about feeding children.

▸

Bock texted Said on May 19, 2021 — the same day they were cut — photos of two checks to Stigma-Free International totaling over $2 million (one for Willmar site, one for Mankato site). Said had saved 950+ documents on his phone, majority being images of checks. — Demonstrates real-time financial coordination between Bock and Said and that Said was managing cash flow across his sites — not just passively benefiting. [p. 2779-2782]

▸

Roster found saved on Said's phone (GG39) was identical to paper roster found at Feeding Our Future during the search warrant (G50) — same name, same ages, same attendance marks. Said had multiple such rosters on his phone. — Directly ties Said to the roster-based fraud at his Stigma-Free sites — he possessed the fraudulent rosters that were submitted to FOF for reimbursement. [p. 2797-2799]

▸

Six Minnesota Secretary of State business registration confirmations were found saved on Said's phone (GG33-36), all paid with Said's Discover card on the same day — corresponding to the six Jama-family shell companies. Corroborates Sharmake Jama's testimony that Said created those shells. — Hard documentary evidence of Said creating shell companies for site operators — undermines any claim he was merely a passive restaurant owner. [p. 2790-2791]

▸

Bock texted Said in June 2021: 'We are doing a rally at MDE parking lot Tuesday at 11. It would be great if you guys came and brought people to help keep the pressure on.' Said responded 'Okay' and sent many people. Bock then sent a rally flyer and texted: 'Channel 5 is coming to the rally. Please remind everyone to be here.' — Establishes Bock and Said acted in concert to obstruct MDE's oversight — this coordinated pressure campaign is consciousness-of-guilt evidence and may support obstruction theories. [p. 2823-2825]

▸

April 28–May 1, 2020 emails (A21 and A23): FOF attorney threatened MDE with a racism lawsuit within 48 hours if eight sites were not approved; MDE capitulated within one day; two days later, when MDE's Kendra Pace asked routine questions about two sites sharing the same Hopkins address, the FOF attorney escalated to the MDE assistant commissioner and called Pace's compliance question 'the epitome of systemic racism.' — Establishes a systematic pattern of using legal threats and racism accusations to suppress MDE oversight — a sustained course of conduct, not a one-time event. [p. 2827-2844]

▸

Wilmer testified that across all text communications reviewed between Bock and Said, there were 'extremely few' communications about feeding children, obtaining food resources, or logistics; and 'numerous' and 'very frequent' communications about check availability and getting paid. — Powerful circumstantial evidence that the program's actual purpose was financial extraction, not child nutrition. [p. 2830-2832]

Cross-Examination

There was no cross-examination of Wilmer on this volume — direct examination concluded at 3:25 p.m. and the court recessed for the weekend with Wilmer's direct still ongoing. Cross will occur in Volume XIII.

Vulnerabilities Cross has not yet occurred. Key vulnerabilities to develop: (1) Wilmer reviewed phone data selectively — he admits not exhaustively reviewing all 950 saved documents or all texts; a complete review might show more food-related communications; (2) he is testifying about what the evidence means (coordination, intent) rather than just what it shows — this opinion testimony from a non-expert lay witness is subject to objection; (3) the 'extremely few' food-related communications vs. 'numerous' check-related ones is a qualitative judgment without precise counts, vulnerable to follow-up; (4) the Afrikan Village Ohio building purchase is tangential to the core fraud counts and may be prejudicial under FRE 403; (5) Wilmer's testimony about the legal threat emails characterizes FOF's attorney's aggressive advocacy as evidence of guilt — the defense will want to argue the First Amendment right to petition government and that aggressive legal advocacy is not consciousness of fraud.

For Defense Counsel This witness's cross is the most important cross in the trial so far and is pending. Defense counsel should note: (1) challenge the 'extremely few food communications' narrative with a quantitative breakdown — how many texts total, how many food-related, how many check-related; (2) explore whether the 'Keep the pressure on' rally was a legitimate advocacy response to what Bock and her clients believed was discriminatory regulatory treatment; (3) attack the FRE 403 prejudice of the Ohio building purchase — it's a collateral transaction; (4) separate Wilmer's knowledge from what was told to him by other agents; (5) challenge the agency theory embedded in his testimony that Said 'directed' various things — Wilmer is inferring direction from texts, not from direct observation.

Key Evidence

Type	Exhibit	Description	Page	Challenge Opportunity
Document	Gov. Exh. A82	April 18, 2021 email from Aimee Bock to FOF office staff instructing them to return 'menus, receipts, meal counts, attendance records, or any other docs' to the office in all-caps, in response to MDE's request for documentation supporting FOF's reimbursement claims.	[p. 2774]	Bock could argue she was complying in good faith with MDE's request, not concealing fraud. The instruction to return documents is consistent with legitimate business operations. The email does not direct staff to fabricate or destroy anything.
Document	Gov. Exh. BB30a	May 19, 2021 text from Aimee Bock's phone (number ending 2480) to Salim Said's phone (saved as 'Safari,' number ending 8354) attaching images of two Feeding Our Future checks to Stigma-Free International, Willmar and Mankato, each over $1 million, cut the same day.	[p. 2779-2782]	A sponsor notifying a site operator that a check was issued is not inherently criminal — if the program were legitimate, this would be routine communication. Defense needs to show this pattern is consistent with legitimate operations or find innocent explanations.
Financial Record	Gov. Exh. W62	SAFE nonprofit bank records showing checks from SAFE to Bridge Logistics LLC in amounts of approximately $26,000 each in June and July 2021, signed by Mohamed Hussein.	[p. 2677-2678]	Bridge Logistics LLC is not proven to be Bock's company in this testimony — Hussein only said Eidleh claimed he and Bock 'owned something.' The chain from Hussein's check to Bock receiving money is: Hussein → Bridge Logistics → Eidleh → (allegedly) Bock. Each link requires separate proof.
Data/Summary	Gov. Exh. X1	Summary exhibit showing total reimbursements received by various FOF sites; SAFE (Somali American Faribault Education) received $3,170,702.03 from the federal food program.	[p. 2715]	X1 is a summary exhibit — it must be traced back to underlying payment records. Defense counsel should verify whether the $3.17M figure includes any legitimate meals served and whether returns or clawbacks are reflected.
Document	Gov. Exh. GG39 (vs. G50)	Roster for Stigma-Free International, Willmar site found saved as a digital document on Salim Said's phone — identical to paper roster found at FOF offices during the January 2022 search warrant execution.	[p. 2797-2799]	The roster being on Said's phone proves possession, not creation or direction. He could have received it from a site operator. The defense needs to establish who sent it to Said and whether receiving a document for review is the same as directing its fabrication.
Document	Gov. Exhs. GG33-36	Minnesota Secretary of State business registration confirmations found saved on Said's phone, showing payment via Said's Discover credit card for the creation of six Jama-family LLCs (including Mumu LLC and Nukamad LLC) all on the same date.	[p. 2790-2791]	Said paying registration fees for someone else's businesses could theoretically reflect a legitimate loan, investment, or administrative assistance. Defense must probe whether any consideration was given, whether the Jamas could have obtained this financing themselves, and whether a legitimate business purpose existed.
Document	Gov. Exh. T91 / GG36	Email showing discussion of Nukumad LLC (one of the Jama shell companies) alongside the SOS registration confirmation saved on Said's phone.	[p. 2792-2794]	The government had some confusion at trial about whether GG36 was already admitted — the court had to reconcile. This is worth checking in the exhibit log for any foundation gaps.
Document	Gov. Exh. BB30b	June 2021 texts between Bock and Said: Bock organizes MDE rally, attaches rally flyer, asks Said to 'bring people to help keep the pressure on,' confirms Channel 5 media coverage, and requests 'more people ASAP.'	[p. 2822-2825]	Organizing a rally at a government agency is constitutionally protected advocacy. The defense can argue this is protected First Amendment activity and that Bock genuinely believed MDE was wrong. The 'keep the pressure on' language is aggressive but not per se criminal.
Document	Gov. Exhs. A21 and A23	April 28–May 1, 2020 email chain between FOF attorney Rhyddid Watkins and MDE Assistant Commissioner Daron Korte (copying Bock): Watkins threatened a discrimination lawsuit within 48 hours if MDE didn't approve eight sites; MDE capitulated in one day; two days later, when MDE's Kendra Pace asked routine compliance questions about two sites at the same Hopkins address, Watkins escalated to Korte, called MDE's conduct 'the epitome of systemic racism,' and forced approval.	[p. 2827-2844]	This is attorney conduct, not Bock's conduct directly — she was copied but did not write the emails. A client is not automatically liable for every tactic her attorney uses. Defense must argue Bock genuinely believed MDE was discriminating (a belief that is not implausible given documented MDE scrutiny of Somali-owned sites) and that legal advocacy, even aggressive advocacy, is not evidence of guilty knowledge.
Document	Gov. Exh. A80	Feeding Our Future board meeting minutes showing John Senkler listed as secretary and 'present' at multiple meetings (March 2020, conference call, January 2021, April 2021 special meeting) that he never attended, making motions he never made.	[p. 2762-2765]	Bock did not personally author these minutes. A staff member could have prepared them without her explicit direction to falsify attendance. Defense should probe who specifically drafted and submitted the board minutes.
Document	Gov. Exh. GG50b	August 2021 group text between Salim Said, Abdirahman Ahmed ('Abcoos'), and Abdulkadir Salah ('Fish') about closing on a commercial property in Ohio through Afrikan Village LLC, including wire instructions and logo mockups for the planned business center.	[p. 2816-2821]	The Afrikan Village purchase is charged conduct against Said's co-conspirators but its relevance to the specific counts against the trial defendants needs careful evaluation. Under FRE 403, its prejudicial effect (millions spent on a building in Ohio) may outweigh probative value if the Ohio building purchase is not itself a charged act.
Document	Gov. Exh. U10	Photograph of the commercial building in Ohio purchased by Afrikan Village LLC (a former culinary institute) using food-program proceeds by Said, Ahmed, and Salah.	[p. 2819]	The photograph itself is not damaging if the legal connection to the charged offense is unclear. The FRE 403 challenge is whether showing jurors a large building creates improper prejudice.

Legal Rulings & Objections

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Sidebar at pages 2614-2617: Court sustained government's objection to Udoibok's cross of Parks about USDA COVID waivers and whether the roster was 'unnecessary,' ruling that Parks had no knowledge of whether rosters were required and that the necessity of rosters was a closing argument, not a question for this witness. — The court effectively blocked the defense's primary regulatory-necessity theory from being developed through Parks. Defense counsel must introduce this theory through an MDE or USDA regulatory expert, not through an IRS agent. The court's ruling ('you can argue that in closing') leaves the argument alive but only as a legal/factual theory for summation. [p. 2614-2617]

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Court admonished Udoibok at sidebar (pages 2738-2743) for repetitive questioning, leading questions, and asking questions 'for which [witnesses] have no foundation to answer.' Government moved to note for the record that the pattern of 'do you have any evidence that' questions was improperly opening the door for broad government redirect. — The court signaled it will intervene more actively to move cross along and will sustain 'asked and answered' objections more readily. defense counsel's trial counsel must be crisp and efficient on cross. The 'do you have any evidence' formulation should be avoided — it invites the agent to affirmatively testify about the entire investigation. [p. 2738-2744]

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Court admonished Udoibok during trial (sidebar, pages 2672-2673) to caution Bock against facial expressions — noting the cooperating witness was 'repeatedly glancing over at her as his answer is interrupted,' and that scoffing or laughing during testimony is impermissible. — Defendant courtroom conduct is actively monitored. This suggests the prior defense team had not adequately prepared Bock for the emotional discipline required during devastating cooperating-witness testimony. [p. 2672-2673]

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Court struck Agent Wilmer's answer characterizing the Stigma-Free payment to Ama Green Market as a 'front' as a legal conclusion (sidebar, pages 2810-2813), directing Bobier to rephrase and avoid conclusory characterizations. However, 'franchise model' was expressly permitted as descriptive rather than a legal conclusion. — The court will strike agent testimony that crosses into legal conclusions, but the government successfully got 'franchise model' — a highly persuasive framing — into evidence as permissible description. Defense should object early and specifically to agent opinions that characterize the nature of business relationships. [p. 2810-2813]

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Court overruled Montez's objection to Wilmer's testimony that the Cosmopolitan/Bridge Logistics check to Eidleh 'is a kickback payment that's signed by Salim Said and is charged as one of the counts,' ruling it did not call for an impermissible legal conclusion. — The court is permitting agent witnesses to characterize payments as 'kickbacks' directly — this is powerful framing that the defense should continue to object to and preserve for appeal. [p. 2785]

Prior Defense Performance

Prior defense counsel delivered a mixed performance. Udoibok's cross of Parks was methodically effective at establishing Bock's non-involvement in creating or sending rosters, and Montez's cross for Said produced the cleanest timeline showing Abdihakim Ahmed (not Said) initiated the fake-roster scheme with Faaris Studio before Said received any communication. However, both defenses were hampered by poor cross technique: repetitive questioning led to sustained 'asked and answered' objections that cut off potentially productive cross, and foundationless questions about USDA waivers were properly shut down. Udoibok's attempted impeachment of Hussein via the FaceTime channel was conceptually sound but executed poorly — he got the key concession (never direct contact with Bock, always through Eidleh) but could not develop the phone-records angle because he apparently lacked the underlying records. The attempt to impeach Hussein on whether he discussed his wife's testimony was blocked by vague questions that prompted sustained objections. Udoibok failed to fully exploit Hussein's internal contradictions (how many cash payments before July 2021, confusion about the meeting timeline), and the cross meandered in ways that frustrated the court. The sham-board cross of Senkler was essentially non-existent — a brief two questions — missing opportunities to probe who drafted the minutes and whether any document contained Bock's signature. Wilmer's direct ended without cross, which means Defense counsel will see that cross in the next volume and should study carefully what questions the prior defense raises.