Trial II · 22cr223

Vol XVII

2025-03-12

Day Overview

Volume XVII is entirely Aimee Bock's continued defense direct examination by her attorney Kenneth Udoibok. Bock testified at length about Feeding Our Future's internal claims review process, growth management, COVID-era attendance waivers, site application procedures, her investigation and termination of over 50 sites and nearly 10 vendors (including Empire Cuisine, Brava Cafe, and L&F Foods), the Handy Helpers renovation payments to her then-boyfriend Empress Watson, her School Age Consultants LLC and the $78,000 she earned selling a policy/procedure kit, and the physical evidence seized from her home. The most significant moments are her detailed narrative of internal fraud-detection activities — she terminated sites, banned vendors, and documented fraudulent invoices — which directly contradicts the government's theory that she was the orchestrator of fraud rather than a sponsor trying to police it. Defense counsel should pay close attention to: (1) the wire fraud counts tied solely to site ID request emails (Counts 2, 4, 5, 12) that Bock characterizes as routine administrative communications; (2) the CLiCS system's hard caps on meal claims, which she says made it structurally impossible to over-claim; and (3) the government's sustained hearsay objection strategy, which prevented essentially all defense documentary evidence from reaching the jury.

Government Strategy

The government had no active witness on this day — the entire volume is Aimee Bock's defense direct examination by her attorney Kenneth Udoibok. The government's role was purely reactive: objecting repeatedly (and successfully) to the admission of defense exhibits on hearsay grounds, thereby preventing the jury from seeing documentary support for Bock's narrative. The government also used sidebar arguments to frame Bock's exhibits as fabricated or litigation-created documents, and to remind the court that her attorney did not cross-examine MDE witnesses (Emily Honer) on the regulatory issues he now wants to litigate through Bock. The government's sustained objection campaign functioned as a strategic tool to undermine the defense's documentary case while leaving Bock's oral testimony unchallenged until cross.

Strategic Notes for Defense Counsel

- The wire fraud counts (Counts 2, 4, 5, 12) appear to rest on routine site ID request emails and one inadvertent copy-to on a claims submission email. Bock's structural defense — that these communications could not themselves cause any payment and contained no false statements — is strong and underdeveloped. Defense counsel should obtain a CLiCS technical expert and a USDA program official to establish the system's actual architecture so the jury hears this from an independent source, not just the defendant. - The CLiCS hard-cap argument is the most powerful mechanical defense in the case: if the system automatically rejected any claim over the approved site maximum, it is structurally impossible to over-claim by inflating meal counts in CLiCS. Verify this with discovery from MDE about how CLiCS validation works and consider a demonstrative showing the rejection mechanism. - Bock terminated Hadith Ahmed — her own employee/consultant — after learning he had taken $100,000-$200,000 to fabricate AFEAP invoices and push them through FOF's claims process. Hadith Ahmed is a potentially critical witness whose role, charges (or lack thereof), and any cooperation agreement Defense counsel must understand before trial. If Ahmed cooperated against Bock, his testimony must be aggressively challenged; if he was not prosecuted, that asymmetry is itself a defense point. - The government sustained its evidentiary exclusion campaign so effectively that the jury heard almost no defense documentary evidence in a full day of direct. Defense counsel must build a proper foundation for all business records (FRE 803(6) certification), regulatory documents (MDE or USDA witnesses), and Bock's own emails (non-hearsay verbal act or effect-on-listener theory) before trial. The single winning exhibit ruling (D1-615 photos admitted as non-hearsay reaction evidence) shows the court will admit documents that have a valid non-truth purpose — Defense counsel should structure his exhibit list around this theory wherever possible. - The School Age Consultants revenue ($78,000 in two weeks, $2,800/site) from sites FOF was sponsoring is a serious conflict-of-interest problem even if Bock's characterization of it as legitimate consulting is accurate. Defense counsel needs to determine whether any FOF regulation, USDA rule, or MDE requirement prohibited sponsors from selling services to their own sites, and whether any MDE official was aware of and approved the arrangement. Proactive disclosure of this in opening (and distinguishing it from a kickback) is likely better than waiting for cross.

Witnesses

Aimee Marie Bock

Executive Director of Feeding Our Future and Defendant; testifying in her own defense about FOF's operations, internal fraud controls, wire fraud counts, and personal finances.

Defense Defense

Direct Examination

Bock walked the jury through FOF's multi-step internal claims review process, including dual-department review of invoices and meal counts, a red-folder escalation system, and her personal role only at the final CLiCS submission step. She testified about COVID attendance waivers, site growth rationale (food deserts after George Floyd riots, record unemployment), her termination of 50+ sites and banning of ~10 vendors for fraud, and her characterization of the wire fraud counts (Counts 2, 4, 5, 12) as routine site ID request emails that could not themselves submit or inflate any meal claims. She also addressed Handy Helpers renovation work, School Age Consultants revenue, and the items seized from her home at the time of the search warrant.

▸

Bock testified that when she submitted claims to MDE through CLiCS, she only saw a summary report of total numbers — she never reviewed individual invoices, meal count forms, or attendance rosters, which were handled by separate claims staff and coordinators. — Directly supports a lack-of-knowledge defense: Bock argues she had no visibility into fraudulent invoices submitted by sites or vendors, insulating her from knowing the underlying claims were inflated. [p. 3748-3749]

▸

CLiCS imposed hard caps: each site had an approved maximum meal count, and 'should that site distribute 3,001, anything over 3,000, that claim is going to be rejected because the established and approved cap is 3,000.' — This is a structural defense against fraud theory — the system itself allegedly prevented over-claiming, and Bock could not have submitted fraudulent quantities even if she wanted to. Defense counsel should verify this with a CLiCS technical expert. [p. 3786]

▸

Government Exhibit Z2 (Count 2) and Z4 (Count 4) are site ID request emails to MDE that Bock characterized as simply requesting numbers to unlock CLiCS applications — not meal count submissions, not claims, and not capable of causing any payment by themselves. — If the wire fraud counts are predicated only on these administrative emails, the defense can argue there was no fraudulent scheme element in those specific communications, which contained no false statements about meal counts. [p. 3795-3810]

▸

Government Exhibit Z5 (Count 5) is an email responding to MDE's own request for clarification about restaurant-based sites. Bock denied it was misleading: 'I was not' misleading anyone, explaining that paid FOF employees — not restaurant owners — distributed the food. — Undercuts the government's narrative that Z5 was a deceptive communication; instead frames it as a responsive, clarifying message to regulators who had questions. [p. 3810-3813]

▸

Bock testified she terminated Empire Cuisine & Market, Brava Cafe, U.S. Halal Foods, Haji's Kitchen, The Produce, Minnesota Food Grocery, and L&F Foods — banning them from FOF after internal fraud investigations revealed fraudulent invoices, and she terminated over 50 participating sites. — This is the heart of the defense narrative: far from running a fraud scheme, Bock was actively policing one. The question Defense counsel must probe is whether these terminations were genuine or whether they occurred after fraud payments had already been extracted. [p. 3828-3834]

▸

Bock described her investigation of Action For East African People (AFEAP): Ayan Abukar arrived with a box of claims for five sites that FOF records showed had never served food. Bock found invoices from L&F and Minnesota Food Grocery were 'clearly fraudulent' — same template, same foods, same prices from two supposedly unrelated vendors. She terminated all sites and vendors and fired consultant Hadith Ahmed, who she learned had been paid $100,000-$200,000 to fabricate and push these claims through FOF's process. — This testimony, if believed, shows Bock caught and stopped a major internal fraud scheme — and also implicates Hadith Ahmed (a FOF employee/consultant who is not a defendant) as a key fraudulent actor. Defense counsel should explore whether Hadith Ahmed was investigated or became a cooperating witness. [p. 3864-3871]

▸

Bock testified that Empress Watson's Handy Helpers received $906,613.78 over ~2 years for renovating FOF's 28+ offices on the third floor of a building with no functioning elevator, explaining other contractors refused the job due to work comp liability. — This explains the government's theory of a sham contractor relationship as a money-laundering mechanism. Bock's explanation — a difficult job no one else would take — is plausible but needs corroboration (before/after photos, building permit records, contractor refusal documentation). [p. 3944-3948]

▸

Bock disclosed she earned approximately $78,000 in two weeks from selling School Age Consultants policy/procedure kits at $2,800 each, which she stated was not a kickback but legitimate consulting — sites were not required to buy it and could develop their own. — The government apparently views the School Age Consultants payments as kickbacks from sites that received FOF reimbursements. Bock's rebuttal is that she disclosed it at a December 2021 meeting, offered alternatives, and the product took months to develop. Defense counsel needs to verify how many buyers were active FOF sites. [p. 3939-3940]

▸

Bock testified she has no money, no bank account, no car, lives with her parents, and was evicted from her home after the prosecution. 'I don't even have a bank account. I couldn't keep a positive balance long enough, so that was also closed.' — Powerful humanizing testimony undercutting the government's wealth/fraud narrative. However, jurors may question how she spent money if she is now destitute. [p. 3934]

▸

MDE was held in contempt of court by a state judge (Judge Guthmann) for violating a stipulated agreement to timely process FOF's site ID requests. The court excluded this ruling on hearsay grounds. — Even though excluded, this establishes that MDE was not a passive victim — it was at times a recalcitrant regulator. Defense counsel should explore admissibility via stipulation or calling a witness with personal knowledge of the state court proceedings. [p. 3895-3902]

Cross-Examination

There was no cross-examination in this volume. The day ended mid-direct. The government's Thompson made no formal cross examination attempt; all government participation was limited to hearsay objections during direct.

Vulnerabilities Bock's testimony is sweeping, detailed, and internally consistent in this volume, but several vulnerabilities will be exposed on cross: (1) She acknowledges that Hadith Ahmed — her own employee/consultant — was accepting kickbacks and fabricating invoices for sites she sponsored, raising the question of how she failed to discover this sooner or whether she benefited; (2) Her explanation for the $906K paid to her live-in boyfriend for construction work will be heavily attacked — no contracts produced, no third-party bids, the relationship is obvious; (3) The $78,000 School Age Consultants income from sites she regulated as a sponsor is a textbook conflict of interest even if technically legal; (4) She repeatedly says she 'terminated' and 'banned' sites, but government evidence likely shows these sites simply moved to other sponsors and continued claiming — undermining the argument that her terminations were effective fraud prevention; (5) Her explanation for wire fraud counts — 'I just sent a routine site ID email' — does not address what happened downstream with those sites, and the government will tie those emails to large fraudulent claims submitted later.

For Defense Counsel Defense counsel should consider: (1) Calling a CLiCS technical witness to validate Bock's claim about hard caps and rejection of over-limit claims; (2) Calling Hadith Ahmed — who appears to be a central bad actor — as a witness or exploring whether he cooperated and what he said; (3) Seeking admission of the MDE contempt order through an MDE employee with personal knowledge rather than through Bock; (4) Introducing before/after renovation photos and any building permit records for the FOF office to support the Handy Helpers payments; (5) Presenting the USDA attendance waiver documents through a USDA official or MDE employee rather than through Bock's description alone; (6) Establishing through the Feeding Our Future employee payroll records the genuine scale of FOF operations to show it was a real organization, not a shell.

Key Evidence

Type	Exhibit	Description	Page	Challenge Opportunity
Document	D1-997	MDE Nutrition Program Bulletin from April 13, 2020, containing USDA Q&A guidance on COVID waivers including attendance requirements for noncongregate dining.	[p. 3759-3760]	Government argued this is one of 113 waivers and Bock is cherry-picking favorable guidance out of context. The full waiver landscape and its precise application to specific sites should be explored with an MDE expert.
Document	D1-0007	Automated CLiCS email confirming MDE issued a site ID number for Stigma-Free International, Willmar.	[p. 3815]	Government can argue the site ID is merely ministerial and that subsequent fraudulent claims are what matter.
Document	D1-615	Photos Bock took on her phone of Brava Cafe/U.S. Halal Foods invoices during her August 2021 internal investigation, showing logo inconsistencies, wrong email addresses, backward invoice numbering, and food shipped before it was ordered.	[p. 3861]	Government argued these photos were gathered in the context of a legal dispute with Hanna Marekegn (who accused Bock of demanding a 50% kickback). The photos' relevance to Bock's overall character as a fraud detective is disputed.
Document	D1-721	Before photos of the FOF third-floor office space, taken by Bock around the time the lease was signed, showing existing damage, holes in walls, and the condition prior to Handy Helpers renovation.	[p. 3949]	No after photos are in evidence in this volume. The before photos alone do not verify $906K of legitimate work was actually performed.
Document	Gov. Ex. Z2	Email from Bock to MDE requesting a site ID for ASA Limited LLC — the basis of wire fraud Count 2.	[p. 3795]	Defense can argue the email contained no false statements and was a ministerial communication. The fraud, if any, occurred downstream when others submitted inflated meal claims.
Document	Gov. Ex. Z4	Email from Bock to MDE requesting a site ID for Stigma-Free International, Willmar — the basis of wire fraud Count 4.	[p. 3806]	Defense argument is strong if the email itself contained no misrepresentations — the fraud theory must rest on what happened after MDE approved the site.
Document	Gov. Ex. Z5	Email from Bock to MDE providing clarification about how restaurant-based sites would operate (staff distribution, not restaurant owners) — the basis of wire fraud Count 5.	[p. 3810]	Bock testified MDE itself had requested the clarification, and her response accurately described FOF's intended staffing model. If MDE's own records show it asked for this response, the deception theory collapses.
Document	Gov. Ex. Z12	Email from ASA Limited to FOF claims department (with Bock copied) attaching meal counts for October 2021 — the basis of wire fraud Count 12.	[p. 3815-3821]	The government must prove Bock's receipt of this email was part of a scheme she controlled. Bock's defense — she was an inadvertent recipient — is plausible and hard to disprove unless she took affirmative steps in response.
Financial Record	Gov. Ex. X24	Summary showing $906,613.78 in total payments from FOF to Handy Helpers (Empress Watson) from March 2020 through January 2022.	[p. 3944]	No contracts, invoices, or permits were admitted in this volume. Defense needs independent corroboration of the scope and legitimacy of the work.
Financial Record	Gov. Ex. W45 (pages 54, 58, 68)	Checks from FOF-sponsored sites (Inspiring Youth and Outreach, Urban Learning Center, Academy for Youth Excellence) to School Age Consultants LLC for $2,800 each, memoed as 'Policy' or 'Policy, P.'	[p. 3910]	The conflict of interest is obvious — a sponsor receiving payments from sites it regulates and reimburses. Even if technically legal, it raises serious questions about Bock's role and intent.
Document	Gov. Ex. Q98	Brava Cafe invoice for House of Refuge for July 2021, showing $38.50 per breakfast-and-lunch unit and billing for July 5th and 6th before the site began operations on July 7th.	[p. 3848]	Government used the same exhibit during its case to establish fraudulent invoice submissions. Whether FOF ultimately paid any portion of these invoices remains a factual question.
Document	Gov. Ex. BB37a	Video of community celebration at Benadir Hall in which Bock was honored alongside politicians and community leaders, with Somali chanting.	[p. 3892-3894]	The video's probative value is minimal — being honored at a community event does not establish guilt. Defense counsel should consider whether a limiting instruction would help.

Legal Rulings & Objections

⚖

Defense Exhibit D1-660 (Bock's internal 'Managing Growth Over 35 Percent' management plan) excluded as hearsay. Judge Brasel ruled it does not qualify as a business record under FRE 803(6). — The defense cannot introduce Bock's own internal policy documents as exhibits. Udoibok must rely on Bock's testimony alone to establish that FOF had documented oversight procedures. Defense counsel should reconsider the foundational strategy for admitting FOF business records. [p. 3756]

⚖

Defense Exhibit D1-224 (USDA COVID attendance waiver memo) excluded as hearsay. Court found it does not qualify as a public record under FRE 803(8) and also had authentication issues. Court allowed Bock to testify about her understanding of the regulations. — Defense cannot put regulatory documents directly into evidence through Bock. Proper admission requires a USDA or MDE custodian. Defense counsel should subpoena the relevant USDA or MDE official to authenticate and admit these documents. [p. 3764-3768]

⚖

USDA meal portion posters (unnamed defense exhibits) excluded as hearsay. Court sustained objection even after defense argued 803(7), 803(1), and 803(8) exceptions. — Same authentication/hearsay problem. An expert witness on USDA meal portion requirements would be a more effective vehicle for this information. [p. 3775-3776]

⚖

Defense Exhibit D1-996 (site ID request emails for FOF 1-27 locations) excluded as hearsay. — Pattern: defense cannot admit Bock's own emails through Bock alone. These need a different foundational approach — either a business records certification from FOF's email server custodian, or the government's own production of these as discovery materials. [p. 3882-3883]

⚖

Defense Exhibit D1-781 (state court order from Judge Guthmann finding MDE in contempt for violating the FOF stipulated agreement) excluded as hearsay and under FRE 403. Court noted it would cause mini-trial on the state court proceedings. — This is a significant blow to Bock's narrative that MDE was complicit in the program's dysfunction. Defense counsel should explore whether the contempt finding can come in through judicial notice, through MDE witnesses on cross, or through the parties' stipulation. [p. 3896-3902]

⚖

Defense Exhibit D1-699 (Bock's March and May 2021 emails to MDE raising concerns about shared site IDs) excluded as hearsay. MDE never responded. — If admitted, this would show Bock proactively raised compliance concerns to MDE. Defense counsel should try to admit it through MDE witness cross-examination as a prior inconsistent omission (MDE received a compliance concern and ignored it). [p. 3877-3879]

⚖

Defense Exhibit D1-983 (catering contract between FOF and Brava Cafe for House of Refuge) excluded as hearsay. — Defense cannot establish the contractual relationship between FOF and Brava Cafe through documentary evidence admitted through Bock. The contract terms (capped reimbursement rates, etc.) that Bock testified about verbally need a different admission vehicle. [p. 3727]

⚖

Government hearsay objection to D1-615 (photos Bock took during Brava investigation) overruled by Judge Brasel, who admitted the exhibit as non-hearsay (not offered for truth, but for Bock's reaction and to show investigation was conducted). — This is one of the few defense evidentiary wins. The ruling establishes that photos taken during investigations are admissible for non-truth purposes. Defense counsel can use this precedent to admit similar investigation documentation. [p. 3861]

⚖

Court admonished defense counsel Udoibok about the pattern of offering clearly inadmissible hearsay exhibits, stating it 'doesn't look good to the jury that I keep saying sustained, sustained, sustained' and urging counsel to review FRE before offering documents. — The court is visibly concerned that the sustained objection pattern is creating an improper impression that the court is hiding evidence from the jury. Defense counsel must have a more disciplined evidentiary strategy to avoid the same problem. [p. 3897-3902]

⚖

Government speaking objection ('They had left to become their own sponsor') sustained; court ordered the speaking portion stricken from the record after defense objected at sidebar. — Both sides have evidentiary discipline issues. The court is actively managing conduct of both counsel. [p. 3872-3873]

⚖

Defense Exhibit D1-899 (list of terminated sites Bock compiled) excluded as hearsay, court finding it was 'clearly not a proper demonstrative' and could not be used to substitute for Bock's direct testimony. — Defense counsel's attempt to use a summary list as a demonstrative was rejected. Defense counsel should prepare properly formatted summary exhibits under FRE 1006 (summaries of voluminous records) if this category of evidence is needed. [p. 3837-3840]

Prior Defense Performance

Udoibok's direct examination of Bock covers critical ground thematically — the CLiCS system's mechanical caps, the claims process's multi-department review, Bock's internal fraud investigations — and Bock is a compelling, detailed, and credible oral witness on these issues. However, the performance was significantly undermined by a series of avoidable evidentiary errors. Udoibok repeatedly attempted to admit Bock's own emails, internal documents, USDA memos, a state court contempt order, and vendor contracts through Bock alone, without meeting any recognized hearsay exception. The court sustained nearly every government objection and explicitly admonished Udoibok about the pattern, warning that the sustained objections were creating a negative impression with the jury. Missed opportunities include: (1) Udoibok never pressed MDE witness Emily Honer (in earlier volumes) about the attendance waiver regulations, leaving him unable to argue those documents come in to rebut her testimony — a strategic error the government specifically called out; (2) The CLiCS system's hard-cap architecture is a powerful defense but was established only through Bock's oral testimony rather than through a CLiCS technical expert who could have demonstrated the system's actual controls to the jury; (3) No attempt was made to have FOF business records properly authenticated through a records custodian foundation; (4) The renovation payments to Handy Helpers were addressed only through Bock's characterization and the before-photos — no third-party corroboration (building permits, contractor refusals in writing, post-renovation photos, or a structural engineer) was offered; (5) The Hadith Ahmed termination story is compelling but Udoibok did not clarify Ahmed's current status — whether he cooperated, was prosecuted, or remained unaccountable — which a juror might wonder about.