Vol XV
March 6, 2025 was a pivotal day in which the government concluded the direct and cross-examination of its forensic accountant Pauline Roase (FBI/IRS) and began the testimony of a second forensic accountant, Sonja Jansma (FBI). Roase provided the capstone financial overview of the Safari group's fraud: $44.1 million to the Safari group alone out of $246 million total paid to Feeding Our Future, with Salim Said personally receiving approximately $5.9 million and Bock's employees (Ikram Mohamed, Abdikerm Eidleh, Hadith Ahmed) collectively receiving another $18-20 million. The most significant moments were: (1) Roase's testimony about Bock's password-protected bedroom laptop spreadsheets (password: 1729CCBOCK$) tracking every Safari payment — notes in the spreadsheets listed 'Safari/Cosmopolitan' as the recipient for multiple non-Safari sites, directly implicating Bock in knowingly routing money to Said; (2) the 'prepaid claims' folder from Bock's office containing $5.3 million in unauthorized prepayments, with $3 million going to the Safari group; (3) a text message from Bock to Said on January 19, 2022 (the day before overt day) in which Bock explicitly stated 'I have been prepaying you as a favor'; and (4) Jansma's money laundering evidence showing Said used food fraud funds to buy two luxury vehicles and two properties. Defense counsel must pay close attention to the cross-examination, which was largely ineffective but did surface a few potential defense angles around Bock's lack of access to Safari's bank accounts, MDE's approval of site applications, and the distinction between Ikram Mohamed personally versus her LLC.
The government spent this day completing its financial forensics presentation through two IRS/FBI forensic accountants. With Pauline Roase, it systematically walked the jury through the entire Safari group financial network — Safari Restaurant, ASA Limited, Stigma-Free International, Tunyar Trading, Horseed Management, Feeding Our Youth, Olive Management, and Brava Restaurant — showing that virtually 100% of funds in each account derived from the Federal Child Nutrition Program and that minuscule percentages (0–10%) were spent on actual food. The government then used Roase to tie Aimee Bock and Salim Said together through shared documents (the 'Safari group' list found at both locations), password-protected spreadsheets on Bock's bedroom laptop tracking every payment, prepayment records in a folder labeled 'Prepaid claims' in Bock's office, and text messages between the two defendants. To close Roase's testimony, the government mapped specific wire fraud counts (2, 4, 5, 8, 12) to specific emails and meal count submissions. The second forensic accountant, Sonja Jansma, then focused on the money laundering counts, tracing Federal Child Nutrition Program funds through Salim Said's entities to the purchase of a Chevy Silverado truck ($47,000), a Mercedes GLS SUV ($60,000 down), a $1.175 million Plymouth home, and a $2.78 million Park Avenue commercial property — all purchased with food fraud proceeds.
- The password-protected spreadsheets (BB53a/b/c) are the government's most damaging evidence and the hardest to explain away. Defense counsel must find a way to contextualize them — the most viable argument is that the Notes column reflects information Bock was receiving (from Eidleh and Said about how to route payments), not her own direction, and that tracking payments is normal sponsor recordkeeping. Consider whether the spreadsheet content tracks MDE-approved data in CenterPilot (Roase acknowledged that is possible), which would undercut the 'secret' framing. - The government's comparison of meal claims to Minneapolis Public School enrollment (59,000 meals/day vs. 33,000 enrolled children) will resonate powerfully with the jury. Defense counsel must address this directly — SFSP allowed any child under 18 to receive meals during summer, not just enrolled students, and COVID-era emergency rules expanded eligibility further. Obtain USDA/FNS waivers from 2020-2021 that expanded eligibility and allowed unlimited meals per child. - The prepayment issue is legally underexplored. Emily Honer (MDE) testified it was not allowed, and Roase parroted that. But Roase admitted she never reviewed USDA regulations or MDE written guidance. Defense counsel should commission a regulatory review — if prepayment was a gray area or was implicitly permitted under COVID emergency flexibilities, the entire 'prepaid claims' folder loses its significance. - Salim Said's money laundering exposure is severe and distinct from Bock's — the tracing to specific luxury assets is tight. defense counsel's client may face different charges, but if similar money laundering exposure applies, challenge the tracing methodology through a forensic accounting expert. The government used account-balance tracing (not dollar-for-dollar), which is legally acceptable but scientifically challengeable. - The MDE's own approval of every site application (including those underlying specific wire fraud counts) is an underutilized defense argument. If the regulator reviewed and approved the applications, the fraud-in-the-application theory requires explaining why MDE failed to catch it — which creates an opportunity to argue good-faith reliance on MDE's approval process.
Roase completed her multi-day direct examination by walking through sources-and-uses charts for every Safari group entity (Safari Restaurant, ASA Limited, Stigma-Free International, Tunyar Trading, Horseed Management, Feeding Our Youth, Olive Management, Brava Restaurant, and Salim Limited LLC), showing that 99–100% of funds in each account derived from the food program while 0–10% was spent on actual food. She then presented geographic evidence (Lake Street corridor claiming 59,000 meals/day in 1.8 miles when all Minneapolis public schools enrolled only 33,000 children), the 'prepaid claims' folder from Bock's office, password-protected Excel spreadsheets from Bock's bedroom laptop, and text messages tying Bock and Said together. She connected specific documents to specific wire fraud counts in the indictment.
Mr. Udoibok's cross for Bock was largely ineffective — he asked primarily about whether Roase could differentiate what Bock personally received versus what went to her employees' LLCs, whether MDE approved the site applications underlying the wire fraud counts, and whether prepayment was specifically prohibited by USDA/MDE regulations Roase had personally reviewed (she had not). Salim Said's counsel (Montez/Colich) asked no questions. The defense drew out that Bock did not have access to the Safari entities' bank accounts and could not control how they spent funds once paid. The most useful concession was that the site applications underlying wire fraud Counts 2 and 4 were in fact approved by MDE.
Jansma's testimony was focused and narrow: she walked through four specific money laundering purchases using Salim Said's Salim Limited LLC account (funded 100% by food fraud proceeds) — a 2021 Chevy Silverado ($47,000, Count 42), a 2021 Mercedes GLS SUV ($60,000 down, Count 44), a $1.175 million Plymouth home at 5150 Alvarado Lane (Count 51), and a $2.78 million commercial property at 2722-2742 Park Avenue in Minneapolis (Count 52). She introduced flow-of-funds charts (U16, U17, U18) showing the money tracing from MDE to Feeding Our Future to Safari group entities to Salim Limited to each purchase. The testimony was cut short at the end of the day with her direct examination not yet complete.
Jansma's direct examination was not completed before the court adjourned; cross-examination had not yet occurred as of the close of this volume.
| Type | Exhibit | Description | Page | Challenge Opportunity |
|---|---|---|---|---|
| Document | Gov. Ex. BB53a, BB53b, BB53c | Password-protected Microsoft Excel spreadsheets recovered from Aimee Bock's HP laptop found in her bedroom. Password was '1729CCBOCK$'. Spreadsheets contained tab-by-tab tracking of every MDE payment to FOF and corresponding payments to each site, including 'Notes' columns listing which entities (often 'Safari/Cosmopolitan') received funds even for non-Safari sites. Covered fiscal years 2020 and 2021. | [p. 3406-3425] | Defense argued password-protection is normal business practice. The laptop may have belonged to FOF, not Bock personally — Roase admitted she did not know. Chain of custody from the bedroom to evidence could be challenged if search warrant scope is questioned. The notes columns represent Bock's interpretation of payment routing, not necessarily her orders — they could reflect information she was given, not her direction. |
| Document | Gov. Ex. A90 | 62-page 'Prepaid Claims' file folder found in Box 97 from Aimee Bock's office at Feeding Our Future, containing CenterPilot printouts for multiple Safari group sites marked 'PREPAID' in handwriting, totaling over $5.3 million in unauthorized prepayments, with approximately $3 million to Safari group entities. | [p. 3374-3382] | Defense could argue that 'prepaid' notations were a tracking mechanism for claims pending MDE approval, not evidence of improper advance payment. Roase admitted she did not personally review USDA/MDE regulations on prepayment. The defense should obtain MDE's actual written guidance on the timing of sponsor payments to sites. |
| Document | Gov. Ex. BB30e | Text message chain between Aimee Bock and Salim Said, dated January 19, 2022. Bock states: 'I have been prepaying you as a favor to be nice when I am able to... For almost two years I have prepaid you when I can.' | [p. 3383-3386] | The defense attempted to argue that the text shows Said's sites had pending, legitimate invoices that had not been paid. The word 'favor' could support the argument that Bock viewed prepayments as permissive discretionary advances, not fraud. The context — that Bock was refusing to pay more and telling Said to stop — could support a narrative that she was withdrawing from the relationship. |
| Data/Summary | Gov. Ex. X70 | Demonstrative exhibit showing Lake Street corridor (1.8-mile stretch) with 21 FOF sites claiming 12.8 million meals total (April 2020 - November 2021) for $34.3 million from MDE, including a single month (April 2021) in which 59,000 meals/day were claimed — nearly double the 33,000 total enrollment of all Minneapolis Public Schools (Exhibit LL2). | [p. 3387-3396] | The comparison to MPS enrollment is misleading — the SFSP program was open to any child 18 or under, not just MPS students, and during COVID-era summer feeding programs, eligibility was often universal regardless of school enrollment. Defense counsel should retain an expert on SFSP/CACFP program rules to challenge this comparison at his trial. |
| Data/Summary | Gov. Ex. X51 | Multi-page summary of all claims submitted and paid by MDE for Safari group sites, showing 14.9 million meals claimed and $45.8 million paid for the Safari group alone, including green-coded 'prepaid' amounts of approximately $2.9 million that MDE had not yet paid but FOF had already disbursed. | [p. 3368-3382] | The chart is a derivative summary by a government expert — the underlying MDE claims data should be cross-examined for accuracy. The 'prepaid' coding in green was added by Roase, not inherent in the original documents. |
| Document | Gov. Ex. AA3 | Document found in Box 122 at FOF office listing Safari group entities with notations about missing backup receipts and milk deliveries for various months. | [p. 3443-3444] | Roase admitted she does not know who created AA3 and only guessed it was from FOF. Authorship is not established. The content (requesting missing receipts) could support the defense narrative that FOF was doing its job monitoring sites. |
| Financial Record | Gov. Ex. U16, U17, U18 | Three flow-of-funds charts created by Sonja Jansma tracing Federal Child Nutrition Program funds from MDE through FOF, through Safari group entities, to Salim Said's Salim Limited LLC, and ultimately to the Chevy Silverado ($47K), Mercedes GLS ($60K down), and Plymouth home ($952K). | [p. 3503-3526] | The tracing methodology uses account balance analysis rather than dollar-for-dollar tracing. If the defense can show any legitimate funds were ever in Salim Limited (restaurant income, personal savings pre-2020), the 'taint' analysis becomes more complex. The intermingling of funds from multiple sources (Safari restaurant, ASA, Olive, etc.) creates a methodological challenge — the government uses a 'pro-rata' or 'all-tainted' approach that should be challenged. |
| Surveillance | Gov. Ex. GG73 | Video recording of Salim Said at the Feldmann Imports dealership picking up his 2021 Mercedes GLS SUV, recovered from Said's phone or Google Drive. | [p. 3512] | The video itself shows only Said at a dealership — it does not establish the source of funds. Foundation for its recovery from Said's Google Drive should be verified. |
| Document | Gov. Ex. X38 / X38a | Summary chart showing Salim Said received the most money of all Safari defendants — $5.9 million from May 2020 to January 2022, with a detailed breakdown showing funds flowing from Safari Restaurant, Olive Management, ASA Limited, FOF directly, Horseed, Feeding Our Youth, Tunyar, 1130 Holdings, and Brava Restaurant all into Salim Limited. | [p. 3422-3423] | The $5.9 million figure aggregates all receipts into Salim Limited — some of these were cross-payments between related entities, not necessarily Said's personal enrichment. Defense counsel should examine whether any of these receipts represent legitimate vendor payments or pass-throughs. |
Udoibok's cross-examination of Roase was largely ineffective. He spent significant time on relatively minor points (whether $12M went to Ikram 'personally' vs. her LLC, whether the GoFundMe was Bock's personal account), which did not meaningfully undercut the government's narrative. He failed to seriously challenge Roase's food expense exclusion methodology — never asking her to define her criteria for excluding Afro Produce/Premium Fresh or to quantify the uncertainty in her zero-percent-on-food conclusions. He did not ask about the COVID-era programmatic context (emergency flexibilities, relaxed program rules during the pandemic) that might explain why MDE kept approving sites despite anomalous meal counts. His most effective moments were: (1) getting Roase to concede she hadn't reviewed USDA/MDE regulations on prepayment; (2) the MDE approval of the wire fraud count applications; and (3) the suggestion that Bock lacked access to the Safari entities' bank accounts. However, he failed to follow up on these concessions with focused narrative development. Montez asked zero cross-examination questions of Roase — a striking decision given that Said is charged with far more money laundering counts. The defense did not object to most of the government's leading questions or the repeated 'has the investigation revealed whether X occurred?' framing that allowed Roase to repeatedly declare 'it did not' without admissible basis.