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Home Court filings United States v. Bock (MND 203016) POSITION ON SENTENCING/SENTENCING MEMORANDUM by USA as to Aimee Marie Bock — United Sta…

Court filing

POSITION ON SENTENCING/SENTENCING MEMORANDUM by USA as to Aimee Marie Bock — United States v. Bock (Dkt. 875)

Filed May 18, 2026 in Bock Mnd 0 22 Cr 00223 B; one of 4 filings from this case.

Record facts

CourtU.S. District Court for the District of Minnesota
Filed2026-05-18

U.S. District Court for the District of Minnesota · No. 0:22-cr-00223-NEB-DTS · Doc. 875 · 2026-05-18 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT 
DISTRICT OF MINNESOTA 
Criminal No. 22-223(1) (NEB/DTS) 
 
UNITED STATES OF AMERICA, 
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GOVERNMENT’S POSITION 
REGARDING SENTENCING 
 
 
 
 
 
 
Plaintiff, 
v. 
AIMEE MARIE BOCK, 
 
Defendant. 
The United States of America, by and through its attorneys, Daniel N. Rosen, 
United States Attorney for the District of Minnesota, and Rebecca E. Kline and 
Matthew C. Murphy, Assistant United States Attorneys, submits the following 
sentencing memorandum and respectfully requests that the Court impose a sentence 
of 50 years in prison.   
I. 
BACKGROUND 
On March 19, 2025, a federal jury found Aimee Bock guilty of carrying out a 
massive fraud scheme. A scheme of unprecedented scale in this country. The ripple 
effects of her actions are profound, immeasurable, and will have lasting consequences 
for both Minnesota and the nation. Bock was the central figure in what became the 
largest COVID-19 fraud scheme in the United States. The brazen and staggering 
nature of her crimes has shaken Minnesota to its core, leaving lasting damage and 
eroding public trust. Her actions have permanently altered the state, and not for the 
better. 
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The Court must send a clear and unequivocal message to Bock and to anyone 
who might believe they can exploit state and federal safety net programs that such 
conduct will be met with the strongest possible consequences. Stealing funds intended 
to feed children is a profound breach of trust that demands accountability. 
A. 
Aimee Bock’s Use of Her Non-Profit, Feeding Our Future 
Aimee Bock deliberately exploited a public program designed to feed children 
during one of the most vulnerable periods in a generation. She took a social safety 
net program intended to serve hungry children and repurposed it to enrich herself, 
her non-profit, her employees, and her co-conspirators, and to elevate her standing in 
the community.  
Bock was not just central to the scheme but was routinely celebrated as its 
lynchpin. As co-conspirator Hanna Marekegn testified at trial, “Aimee was a god.” 
The Court will recall the testimony and evidence adduced at trial regarding Bock’s 
participation in a June 2021 event at Benadir Hall—a banquet hall unironically 
purchased with proceeds from the very fraud she orchestrated. At that event, Bock 
was openly praised by both her co-conspirators and members of the community, 
underscoring the extent of her influence and the culture of complicity she fostered. 
See, e.g. Gov’t Ex. R-39, BB-37a. 
  From the outset, Feeding Our Future was a sham organization, as evidenced 
by its very origins.  As the Court heard during trial, the Board of Directors was not 
legitimate.  Testimony from three purported members of Feeding Our Future’s Board 
of Directors revealed that they never attended board meetings and did no real work 
on behalf of the non-profit.  The individual identified as the Board’s “President” 
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testified that he did not actually serve on the board. Other listed board members 
testified that they didn’t sign meeting minutes or the organization’s formation 
documents. The testimony makes clear that the Board of Directors existed in name 
only, further demonstrating that Feeding Our Future was not a legitimate 
organization, but a façade used to carry out fraud. See, e.g., Gov’t Ex. A-5, A-80. 
Additionally, Bock maintained complete control of Feeding Our Future from 
an administrative and financial perspective. She oversaw the spigot of millions of 
federal dollars flowing into the Feeding Our Future bank account. Scheme 
participants received million dollar check after million dollar check— all signed by 
Aimee Bock.  See, e.g., Gov’t Ex. W-1, W-2. 
 
Example check distributed by Aimee Bock to her con-conspirators 
Early in the pandemic, amid widespread public vulnerability and pleas to 
“flatten the curve” through social distancing, Bock exploited a safety net system that 
had been adapted to help children. She used it to benefit herself and her co-
conspirators. While many companies were struggling to stay afloat while the country 
was shut down, Bock aggressively pursued the enrollment of food sites to defraud the 
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Federal Child Nutrition Program, threatening and then ultimately suing the 
Minnesota Department of Education when it refused to approve new food sites 
sponsored by Feeding Our Future.  
Bock unquestionably led the scheme. She recruited myriad participants into 
the fraud and exploited others to expand the scheme. Those individuals are 
responsible for their own conduct, and many have and will be held accountable 
through federal charges.  Nonetheless, many co-conspirators were particularly drawn 
into the fraud by the opportunity Bock created and oversaw. Dozens of conspirators 
were given the chance, by Bock, to exploit a program meant to benefit children, and 
instead used it to fund lavish lifestyles.  As the Court heard from multiple cooperating 
defendants in their testimony, many now regret ever joining the scheme. Bock 
promised the “American Dream,” but it became a nightmare for so many.  
Meanwhile, Bock took substantial steps to avoid the fraudulent nature of 
Feeding Our Future’s work from being detected. She advised her co-conspirators not 
to be obvious— warning them against making conspicuous purchases like houses and 
cars that could draw attention.  She herself routed her spending of fraud proceeds 
through her live-in boyfriend Empress Watson’s company Handy Helpers. 
For 21 months, Bock submitted thousands of fraudulent reimbursement 
claims, one after another, day after day. Each claim represented meals for children 
who did not exist, yet the money was real. Taxpayer dollars were diverted to fund 
kickbacks for Bock and her co-conspirators. Those funds were then spent 
extravagantly, fueling a large-scale abuse of federal resources. Through calculated 
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deception, persistence, and a lack of remorse, Bock and her co-conspirators caused 
more than $242 million in losses. Feeding Our Future was Bock, and Bock was 
Feeding Our Future.  Perhaps most importantly for loss calculations in this case, 
Bock herself certified each false claim being submitted for reimbursement. See, e.g., 
Gov’t Ex. X-1, W-2, V-2. 
 
Aimee Bock certified each fraudulent claim. 
B. 
Aimee Bock Always Had a Work Around  
Further, Bock herself took substantial steps to ensure that the flow of funds 
did not turn off.  On April 29, 2020, as MDE was adapting to changes in the Federal 
Child Nutrition Program, Bock aggressively pushed the agency to allow for-profit 
restaurants to participate in the program.  Bock demanded that MDE quickly issue 
site identification numbers to those restaurants.  She warned that if the sites were 
not approved, legal action would follow.  
When MDE raised concerns about the sites or pointed out serious deficiencies, 
Bock responded with excuses, criticized the program and staff, and made additional 
demands. Rather than addressing the issues, she responded with attacks whenever 
MDE questioned her.  
 
Bock had her attorney attack when MDE questioned anything (Gov’t Ex. A-21) 
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Claims of racism were used by Feeding Our Future when questioned (Gov’t Ex. A-23) 
 
Text Message from Aimee Bock to Ikram Mohamed (Gov’t Ex. BB-32b) 
By fall 2020, MDE had made further changes to the program, due to concerns 
about the high volume of meal claims being submitted. Evidence in the case, 
including testimony from MDE employee Emily Honer, showed that MDE repeatedly 
tried to curb the excessive claims submitted by Feeding Our Future. MDE ultimately 
decided that for-profit organizations would no longer be allowed to participate, and 
that all meal distribution sites would be required to operate through non-profits.   
 In response, Bock pivoted to falsely claiming to MDE that Feeding Our Future 
employees themselves would be staffing the sites, rather than the site operators.  
Feeding Our Future worked around the rule change and continued submitting claims, 
resulting in millions more in taxpayer funds being paid out. This was further 
supported by email evidence testified in detail during Special Agent Jared F. Kary’s 
testimony.  
 
 
 
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Bock’s lie to MDE to circumvent the new requirement (Gov’t Ex. Z-5) 
In spring 2021, MDE issued a “stop payment” to Feeding Our Future.  MDE 
required documentation to verify that meals were actually being served to children, 
including rosters, invoices, and meal counts, in order to confirm that program 
requirements were being met. This, again, prompted retaliation from Bock and 
Feeding Our Future. 
In the fall of 2020 and spring of 2021, Feeding Our Future filed two separate 
lawsuits against MDE, accusing MDE of racial discrimination and improper funding 
delays through the stop payment. Bock prevailed in both lawsuits. When MDE 
removed the stop pay and money began to flow, the co-conspirators celebrated the 
victory over MDE with a party honoring Aimee Bock where they circled around her 
and sang “Oh sweet Aimee,” and presented her with awards. See Gov’t Ex. BB-37a. 
Under Aimee Bock’s control, Feeding Our Future operated like a cash pipeline, 
open to anyone willing to submit fraudulent claims and pay kickbacks. As long as the 
kickbacks were made, the money kept flowing. In return, Feeding Our Future 
retained approximately $18 million, all derived from false and fraudulent claims. 
Bock did whatever was necessary to keep the “bank” open. As the Court saw, 
Feeding Our Future distributed shirts to participants attending a rally outside MDE 
(Gov’t Ex. AA-5), promoting the message: “FOF Feeds Our Kids—MDE Won’t.” Bock 
also exchanged text messages with her co-conspirator and co-defendant, Salim Said, 
discussing the support they sought to generate for their efforts. 
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June 25, 2021 Text Message from Bock to Salim Said (Gov’t Ex. BB-30B) 
There are countless examples of Bock being questioned about site 
discrepancies by MDE and giving answers that were not consistent with the facts.  In 
one example, there were multiple purported food sites operating in a nearly empty 
building near the Greenway in South Minneapolis.  This building was not capable of 
serving meals to thousands of children daily. Despite this, numerous sites were 
within the same building were claiming to serve thousands of meals per day.  Bock 
personally perpetuated this myth— in an email, she told MDE that the site was 
serving two separate groups of youth at different locations within the building.  
 
Email from Bock to MDE with false statements about Greenway site (Gov’t Ex. A-75) 
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Crime Lab and No Activity (Gov’t Ex. P-76)        False Meal Counts (Gov’t Ex. P-78) 
Special Agent Jared Kary testified during trial about his review of the video 
surveillance of the Greenway site over multiple days on which the sites claimed to be 
serving thousands of meals to children.  However, the surveillance showed little to no 
activity consistent with meal service for thousands of children taking place at this 
location on the days claimed.  Once again, Aimee Bock lied to MDE to keep the flow 
of funds going. 
C. Feeding Our Future Kickbacks to Employees and Service Fees 
The testimony at trial also showed that Aimee Bock, along with numerous of 
her employees at Feeding Our Future— including Ikram Mohamad, Hadith Ahmed, 
and Abdikerm Eidleh— made participation in the food program a pay-to-play scheme. 
Despite Bock’s self-serving testimony that she was working to detect and stop fraud, 
the evidence is clear that she knew fraudulent activity was happening and did 
nothing to stop it. Instead, she continued to certify false claims to the state, allowing 
funds to keep flowing to herself and her co-conspirators. 
 
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Email showing Bock knew the sites weren’t providing food. (Gov’t Ex. Q-85) 
 
In one example, Hadith Ahmed told Bock that one food site operator, Xogmaal 
Media Group, did not “work with children.” However, Bock took no steps to stop 
Xogmaal from getting food program funds. Instead, she falsely certified that the 
organization had served meals to real children. Based on that certification, the funds 
were paid to Feeding Our Future, and Bock then issued payments to Xogmaal Media 
Group. The company never provided any meals, making the claims used to obtain 
those funds false. 
 
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Feeding Our Future check to Xogmaal Media Group (Gov’t Ex. W-222) 
In July 2021, after Xogmaal Media Group received over $330,000 in 
reimbursement, its owner and operator, Mohamad Noor, was required to pay a 
kickback to continue his company’s participation in the scheme. Xogmaal then paid 
Bridge Consulting, an entity associated with Feeding Our Future employee Abdikerm 
Eidleh, over $180,000 to secure the company’s continued participation in the pay-to-
play scheme. 
 
Xogmaal Media Group kickback payment to Abdikerm Eidleh (Gov’t Ex. W-66) 
Mohamad Noor, the operator of Xogmaal Media Group, has pleaded guilty to 
his role in the scheme and is awaiting sentencing. He admitted to making kickback 
payments to remain in the program. 
This is just one example of how the scheme operated. The Court heard many 
similar accounts at trial. Co-conspirator Qamar Hassan of S&S Catering testified, “If 
I say no, I’m not getting any more money.” And co-conspirator Hanna Marekegn of 
Brava Café stated, “If I don’t pay kickbacks, I would lose the contract and wouldn’t 
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get paid.” Marekegn was ultimately excluded from the program after refusing to pay 
Bock a $1 million cash kickback.  
Another witness testified about his own observations about Bock’s awareness 
of and involvement in the kickback scheme. Mohamed Hussein, the operator of the 
SAFE food site in Faribault, testified he observed Feeding Our Future employee 
Abdikerm Eidleh on a FaceTime call with Bock during a SAFE site visit.  Eidleh 
collected a kickback payment from Hussein while he was on the phone with Bock. 
Hussein further testified: “The kickbacks were so that Feeding Our Future would not 
terminate us from participating in the program.” 
As proven at trial, Aimee Bock personally received kickbacks from the Feeding 
Our Future scheme by orchestrating a sham transaction involving the purported sale 
of a nonexistent daycare. Through this fraudulent “sale,” Bock obtained funds as a 
disguised personal payment derived from the scheme. 
 
Purported sale of Learning Journey Child Care (Gov’t Ex. HH-26) 
Aimee Bock was not operating a legitimate nonprofit; she was running a sham 
organization designed to funnel money to fraudsters. As testified by Feeding Our 
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Future employee Hadith Ahmed during the trial of United States v. Abdiaziz Farah 
et al. (File No. 22-CR-124, Trial Tr. Vol. XII, p. 2781): “I think the best way to put 
that is Feeding Our Future was a bank. You come and you get money.” Bock herself 
was aware of and perpetuated Feeding Our Future’s perception in the community.  
 
Text Message from Aimee Bock to Hadith Ahmed (Gov’t Ex. BB-40a) 
D. 
Bock’s Conduct During and After Trial 
Aimee Bock placed Minnesota at the center of a significant and damaging 
chapter in the state’s history. Bock herself claimed that her goal was to make Feeding 
Our Future “nationally recognized.”  She has met that goal. Feeding Our Future is 
now synonymous nationwide with one of the largest fraud schemes in Minnesota 
history.   
 
Text message from Aimee Bock to Ikram Mohamed (Gov’t Ex. BB-32F) 
 
Bock has never accepted any responsibility or shown any remorse for her 
crimes.  On the contrary, not only did Bock testify falsely at trial, but she also showed 
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complete contempt for the Court and the criminal justice system.  She repeatedly 
sought to minimize her involvement in fraudulent activity.  Instead, she pointed the 
finger at her absent co-defendants, Hadith Ahmed and Abdikerm Eidleh, as well as 
other members of the Feeding Our Future staff— as if she did not even have oversight 
of the company at all.  She also repeatedly blamed MDE for not doing more to prevent 
fraud and claimed that site participants (her co-conspirators) had concealed the fraud 
from her.  She claimed that she had legitimately brought on and regularly met with 
each of Feeding Our Future’s board members. She self-servingly claimed she was 
doing everything in her power to “root out fraud.”  Finally, she lied about having sold 
a daycare to Cosmopolitan Business Solutions, alleging that there was a real daycare 
there.   However, the jury flat-out rejected her testimony.  
In the year since Bock’s conviction at trial, she has used the media and the 
public domain to repeatedly deny any criminal culpability and point the finger at 
others. In February 2026, she gave an interview to CBS News from her jail cell.1 She 
took zero accountability for her crimes. She claimed that she was a “scapegoat,” who 
relied on state administrators to approve Feeding Our Future’s site applications and 
claims. She denied being the mastermind of the scheme and claimed that she 
“believed in accountability. If I had done this, I would have pled guilty.”  She claimed 
that she was relying on the state to see red flags.  
 
1 
https://www.cbsnews.com/minnesota/video/woman-convicted-as-key-player-in-
minnesota-fraud-scheme-speaks-out/ 
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Subsequently, Bock took egregious steps, in violation of the Court’s Protective 
Order, to turn media coverage and public opinion in her favor.  As explained in the 
government’s motion for sanctions (ECF No. 848), she directed one of her sons to send 
emails to Minnesota state legislators and media outlets from an anonymous email 
address, claiming that “Tim Walz, Keith Ellison, and the Minnesota Department of 
Education intentionally set Feeding Our Future and Aimee Bock up as a scapegoat.” 
In jail calls, Bock claimed she “wasn’t even supposed to be convicted at trial.”  She 
also described to her son an interview she did with the Star Tribune for an upcoming 
article about fraud in the Federal Child Nutrition Program, purporting to discuss an 
uncharged individual and “why she never got indicted, including all the evidence that 
exists against her.” Bock went on to direct her son to share material from her Dropbox 
with the Star Tribune.  The same reporter who Bock spoke to also represented to 
witness lawyers that he had in his possession numerous interview reports from 
government witnesses and cooperators.  In an April 19, 2026, call with an 
unidentified female, Bock said that someone had given the Star Tribune reporter 
“every interview the FBI did with people.” She added that her criminal defense 
attorney, Kenneth Udoibok, and the editor of the Star Tribune were making plans as 
to when to publish the article to garner the most strategic advantage.   
Just as Bock said would happen, on Sunday, May 17, the Star Tribune 
published its article on claims that fraud warnings about the Federal Child Nutrition 
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Program were not acted on by state officials.2  The reporter repeatedly referenced 
interviews that MDE witnesses did with the FBI during the government’s 
investigation, including screenshots of the interview reports themselves.   The article 
noted the Court’s recent rulings on the government’s motion for sanctions against 
Bock but did not deny that the Star Tribune received the interview reports from Bock. 
 
 
The reporter detailed his interview with Bock, including her self-serving 
claims that she herself “was the one raising concerns about fraud among other 
nonprofits and operators in her organization – and being ignored by state officials.”  
Perhaps most preposterously, Bock claimed that she had given prosecutors evidence 
of fraud “on a silver platter.”  Bock herself sought the publication of this on the eve of 
her sentencing. Bock’s brazen post-sentencing conduct evidences someone who has 
zero respect for the law and no remorse for the untold harms she has caused.  
II. 
THE GUIDELINES RANGE 
Bock raised substantial objections about the Guidelines range applicable to her 
case.  However, the government agrees with the PSR’s conclusions about all of the 
applicable Guidelines calculations, including the loss amount. 
 
2 
https://www.startribune.com/an-open-secret-new-records-reveal-officials-failed-to-act-on-
fraud-warnings/601838325 
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The base offense level is 7 pursuant to Guidelines § 2B1.1(a)(1). PSR ¶101. The 
base offense level is increased by 26 levels pursuant to Guidelines § 2B1.1(1)(N) 
because the loss was more than $150 million but less than $250 million. PSR ¶102.   
The government’s position is that the entire loss of $242 million that Feeding Our 
Future obtained from the Federal Child Nutrition Program should be part of the loss, 
as the testimony at trial established that Bock personally submitted all of the site 
applications, monitored all of the sites, and signed each and every claim for 
reimbursement and check to participants in the program. Bock also controlled 
Feeding Our Future’s bank account and the organization as a whole.  Accordingly, 
Bock is responsible for all fraudulent claims submitted on behalf of all the sites.  
The offense level is increased an additional 2 levels pursuant to Guidelines 
§2B1.1(b)(9)(A) because the offense involved a misrepresentation that Bock was 
acting on behalf of a charitable or educational organization. PSR ¶103. The offense 
level is increased 2 levels pursuant to Guidelines § 2B1.1(b)(10) because the offense 
involved sophisticated means. PSR ¶104. The offense level is increased 2 levels 
pursuant to Guidelines § 2B1.1(b)(12) because the offense involved conduct described 
in 18 U.S.C. § 1040 (Fraud in Connection with a Major Disaster or Emergency 
Benefits). PSR ¶105. 
The offense level is increased by 4 levels because Bock was an organizer or 
leader of the criminal activity involving five or more participants under Guidelines § 
3B1.1(a). PSR ¶ 107. The offense level is increased by 2 levels pursuant Guidelines § 
3C1.1 because Bock willfully attempted to obstruct or impede the administration of 
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justice with respect to the investigation of the offense on account of her lawsuit on 
behalf of Feeding Our Future, alleging misconduct by MDE in their oversight of the 
food program.  PSR ¶ 108.  
Because all of her counts of conviction group together, the adjusted offense 
level is 45, reduced to 43.  PSR ¶ 112.  With a Criminal History of I, her Guidelines 
range is life.  The statutory maximum is 1,200 months or 100 years. PSR ¶ 168. 
III. 
GOVERNMENT’S SENTENCING RECOMMENDATION 
A. Nature and Circumstances of the Offense  
Bock participated in one of the largest fraud schemes in the history of the 
District of Minnesota, and the single largest COVID-19 fraud scheme in the country. 
She took advantage of a once-in-a-century global pandemic to enrich herself and 
obtain glory. She abused the generosity of Minnesotans and the state’s substantial 
social safety net, a system designed to ensure that no child goes without food.  
Bock’s Feeding Our Future served as the central component of a massive fraud 
scheme, enabling significant amounts of taxpayer funds intended to feed children to 
be diverted. She and her conspirators used the money for personal enrichment, 
including international travel, commercial real estate purchases, luxury vehicles, 
homes, and other lavish spending. 
Bock claimed she was opening the door for the community to achieve the 
American Dream. Instead, her actions led to criminal charges and convictions, with 
dozens of defendants now facing lengthy prison sentences for their actions.  
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B. History and Characteristics of the Defendant 
Bock’s history and characteristics reveal a career centered on non-profit work 
involving advocacy or direct services. Prior to founding Feeding Our Future, Bock 
was a co-founder of another sponsor of the Federal Child Nutrition Program, Partners 
in Nutrition. Bock attended college and previously worked at a daycare. She had a 
middle-class upbringing and her parents remain involved in her life. While she and 
her ex-husband had financial difficulties during their marriage, there is nothing to 
indicate in Bock’s history anything that would have predisposed her to this conduct.  
C. The Need for Deterrence and to Protect the Public 
Bock was the leader of one of the largest fraud schemes in the history of the 
District of Minnesota, and the single largest COVID-19 fraud scheme in the country. 
But Bock didn’t just take advantage of the COVID-19 pandemic to enrich herself and 
her co-conspirators. She took advantage of our state’s compassion and its efforts to 
ensure no child went hungry. Make no mistake, Bock’s fraud has done great damage 
to the state. It has eroded trust in the government and raised questions about the 
sustainability of the state’s system of social services. Her crime undermined and 
endangered legitimate nonprofit organizations that rely on donations and taxpayers’ 
funds to carry out necessary and important charitable work. 
Bock has suggested that she “opened doors” for a disadvantaged community. 
In a tragic sense, that is true. But the door she opened was not one of opportunity or 
feeding hungry children. It was a door that led to federal indictments, convictions, 
and prison sentences. 
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To this day, Bock has denied responsibility for her crimes. She has not 
expressed an ounce of remorse for her actions. She appears to have felt no shame. 
Cases like this are difficult to investigate and prosecute, which results in the widely 
held belief that perpetrators routinely get away with these crimes. The Court must 
send a message that fraud schemes like this are not worth it and will be met with 
severe sanctions. 
Bock has continued to portray herself as a victim or scapegoat in this 
deplorable fraud scheme, despite the evidence presented against her. She has not 
accepted responsibility and instead, has sought to manipulate the public record to 
present herself as a scapegoat. She has gone so far as to anonymously leak protected 
materials in order to harm others. Her actions since her conviction alone warrant a 
serious punishment.   
Protection of the public is also paramount. The defendant’s conduct was not 
impulsive. It was sustained, organized, and defended aggressively. Even under oath, 
facing overwhelming evidence, she chose dishonesty over responsibility. That speaks 
directly to her risk of reoffending and her respect for the rule of law, particularly 
given her lengthy career in the non-profit industry. 
Taking into consideration the Sentencing Guidelines, as well as all of the other 
factors required to be considered under § 3553(a), the government respectfully 
suggests that a sentence of 50 years in prison appropriately reflects the seriousness 
of Bock’s crimes, promotes respect for the law, provides a just punishment, and 
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creates adequate deterrence not only to Bock, but to all other individuals who take 
advantage of the state and believe that they are above the law.  
IV. 
CONCLUSION 
For the reasons stated above, the government respectfully requests that the 
Court impose upon Aimee Bock a sentence of 50 years in prison. 
 
Dated:  May 18, 2026 
 
 
 
Respectfully Submitted, 
 
 
 
 
 
 
 
DANIEL N. ROSEN 
United States Attorney 
 
 
 
 
 
 
 
 
/s/ Rebecca E. Kline  
 BY:    REBECCA E. KLINE 
 
MATTHEW C. MURPHY 
 
Assistant U.S. Attorneys 
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