Sentencing Stipulations — No. 0:22-cr-00124 (Dkt. 842, D. Minn.)

Summary

A plea agreement and sentencing stipulations in United States v. Mahad Ibrahim, Criminal No. 22-124(8) (NEB/DTS), in the U.S. District Court for the District of Minnesota, filed July 24, 2025 as Doc. 842. Ibrahim agrees to plead guilty to Count 5 of the superseding indictment, wire fraud under Title 18, United States Code, Section 1343, and Count 36, a monetary transaction in criminally derived property. The stipulated facts state that an invoice from Empire Cuisine and Market claimed $988,212 in federal child nutrition program funds, and that on or about August 20, 2021 he paid $200,000 from MIB Holdings LLC toward his residence in Lewis Center, Ohio, from fraud proceeds. The agreement runs 16 pages.

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CASE 0:22-cr-00124-NEB-DTS Doc. 842 Filed 07/24/25 Page 1 of 16

UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
Criminal No. 22-124(8) (NEB/DTS)
UNITED STATES OF AMERICA,

Plaintiff, PLEA AGREEMENT AND
SENTENCING STIPULATIONS

v.
MAHAD IBRAHIM,
Defendant.

The United States of America and the defendant Mahad Ibrahim agree to
resolve this case on the terms and conditions that follow. This plea agreement binds
only the defendant and the United States Attorney’s Office for the District of
Minnesota. This agreement does not bind any other United States Attorney’s Office
or any other federal or state agency.

1. Charges. The defendant agrees to plead guilty to Count 5 of the
Superseding Indictment, which charges the defendant with wire fraud, in violation
of Title 18, United States Code, Section 1343, and Count 36 which charges the
defendant with money laundering, in violation of Title 18, United States Code,
Section 1957. The defendant fully understands the nature and elements of the crimes
with which he has been charged. At the time of sentencing, the United States agrees
to move to dismiss the remaining charges against him in the Superseding Indictment.

2. Factual Basis. The defendant is pleading guilty because he is, in fact,

guilty of Count 5 and Count 36 of the Superseding Indictment. In pleading guilty, the

defendant admits the following facts and that those facts establish his guilt beyond a

SCANNED

; JUL 25 2025

U.S. DISTRICT COURT

|

MPLS


CASE 0:22-cr-00124-NEB-DTS Doc. 842 Filed 07/24/25 Page 2 of 16

reasonable doubt and constitute relevant conduct pursuant to the United States
Sentencing Guidelines:

From approximately September 2016 to June 2021, the defendant served as
the president and founder of ThinkTechAct Foundation (“ThinkTechAct”), a
Minnesota nonprofit educational organization that also operated under the name
Mind Foundry Learning Foundation ("Mind Foundry"). During this period, the
defendant’s organizations participated in the federal child nutrition program
activities under the oversight of authorized program sponsors — Partners in Nutrition
and Feeding Our Future. More specifically, the defendant’s nonprofit worked with
vendor organizations such as Abdiaziz Farah’s “Empire” group, which purported to
service more than two dozen Federal Child Nutrition Program sites throughout the
State of Minnesota during 2020 and 2021, including in Minneapolis, St. Paul,
Bloomington, Burnsville, Faribault, Owatonna, Shakopee, Circle Pines, and Willmar.

The defendant was generally aware of the high likelihood that vendor
organizations then used ThinkTechAct to fraudulently bill program sponsors for food
that was not provided to children that did not exist, using signed meal count sheets
that inflated the number of meals actually served and rosters that contained false
names of children and families they claimed they had fed. Unlike other defendants,
the defendant purchased more than a $1.5 million dollars in food for the distribution
to children as part of the program, and provided online and in-person education to
children and their parents throughout 2020-2021. While he did not participate

directly in his co-conspirators’ signing of fraudulent meal count sheets or fabrication

CASE 0:22-cr-00124-NEB-DTS Doc. 842 Filed 07/24/25 Page 3 of 16

of rosters, the defendant was nonetheless aware of the high likelihood that his co-
conspirators were abusing the lack of oversight from sponsors to profit from the
federal food program. Defendant took deliberate steps to avoid learning about the full
scale of his co-conspirators’ fraudulent activities at sites the Sponsor organizations
believed were operated by his nonprofit. Nonetheless, the defendant knowingly
participated in the scheme by continuing to allow his nonprofit, ThinkTechAct, to be
used to bill the food program, from which he directly profited.

Defendant deliberately closed his eyes to what should have been obvious to him
about the nature and scale of the scheme to defraud the federal food program. The
Defendant benefitted from the scheme and knowingly took advantage of it by
personally receiving substantial compensation from vendor organizations who used
his nonprofit to defraud the federal food program. The defendant became aware of
improprieties in connection with the federal child nutrition programs but chose not
to investigate to confirm a high probability of fraud and took no corrective action.

Count 5

On or about August 2, 2021, the defendant received an email from Abdiaziz
Farah that traveled in interstate commerce with the subject line “Empire Summer
Food Claim.” The email contained an invoice from Abdiaziz Farah to Partners in
Nutrition, a sponsoring organization. Attached to the email was an invoice from
Empire Cuisine and Market claiming it was entitled to $988,212 in federal child
nutrition program funds. Attached to the email were numerous delivery receipts and

weekly consolidated meal counts claiming many of these sites had consistently fed

CASE 0:22-cr-00124-NEB-DTS Doc. 842 Filed 07/24/25 Page 4 of 16

thousands of children every week for most of the summer of 2021.

The Defendant knew that Partners in Nutrition would use this communication
to support claims for federal food program reimbursement and was further aware of
the high probability that his co-conspirators had inflated and otherwise falsified
information to make it appear to the sponsor that the claimed services had been
provided at sites that the sponsor believed were operated by the defendant’s

nonprofit.

The defendant ultimately profited from the money that his co-conspirator,
Abdiaziz Farah, received as the result of this fraudulent invoice being sent and took
deliberate steps to remain ignorant as to how much food the Empire Group had
actually provided, and how many children the Empire group had truly fed, even
though he knew the sponsor would use this communication to support claims for

federal program reimbursement.

Count 36
On or about August 20, 2021, Defendant made a $200,000 payment from MIB
Holdings LLC toward his residential property in Lewis Center, Ohio, using funds
derived from fraudulent activity related to federal child nutrition programs. The
defendant used money furnished to him by his co-conspirator, Abdiaziz Farah, to

as the defendant knew through his deliberate and

make a house payment, and

willful ignorance—such payment constituted a monetary transaction in criminally

derived property of a value greater than $10,000.

CASE 0:22-cr-00124-NEB-DTS Doc. 842 _ Filed 07/24/25 Page 5 of 16

3. Waiver of Pretrial Motions. The defendant understands and agrees

that he has certain rights to file pre-trial motions in this case. As part of the plea
agreement, and based upon concessions of the United States within this plea
agreement, the defendant knowingly, willingly, and voluntarily gives up the right to
file any pre-trial motions in this case. The defendant agrees that, by pleading guilty,
he is withdrawing any motions previously filed.

4. Waiver of Constitutional Trial Rights. The defendant understands

that he has the right to go to trial. At trial, the defendant would be presumed
innocent, have the right to trial by jury or, with the consent of the United States and
of the Court, to trial by the Court, the right to the assistance of counsel, the right to
confront and cross-examine adverse witnesses, the right to subpoena witnesses to
testify for the defense, the right to testify and present evidence, and the right to be
protected from compelled self-incrimination. The defendant understands that he has
the right to an attorney at every stage of these proceedings and, if necessary, one will
be appointed to represent him. The defendant understands that he has the right to
persist in a plea of not guilty and, if he does so, he would have the right to a public
and speedy trial. By pleading guilty, the defendant knowingly, willingly, and
voluntarily waives each of these trial rights, except the right to counsel. The
defendant understands that a guilty plea is a complete and final admission of guilt
and, if the Court accepts the guilty plea, the Court will adjudge the defendant guilty

without a trial.

CASE 0:22-cr-00124-NEB-DTS Doc. 842 Filed 07/24/25 Page 6 of 16

5. Additional Consequences. The defendant understands that as a

result of his conviction, he could experience additional consequences, such as the loss

of the right to carry firearms, the right to vote, and the right to hold public office. If

the defendant is not a United States citizen, as a result of a plea of guilty, the

defendant may be removed from the United States, denied citizenship, and/or denied

admission to the United States in the future. The defendant has discussed with his

attorney the punishments and consequences of pleading guilty, understands that not

all of the consequences can be predicted or foreseen, and still wants to plead guilty in

this case.

6. Statutory Penalties. The defendant understands that Count 5 of the

Superseding Indictment, charging wire fraud in violation of 18 U.S.C. § 1348, is a

felony offense that carries the following statutory penalties:

a.

b.

a maximum term of imprisonment of 20 years in prison;
a supervised release term of up to three years;

a fine of up to $250,000, or twice the gross gain or loss from the
offense, whichever is greater;

assessment to the defendant of the costs of prosecution as
authorized by 28 U.S.C. §§ 1918(b) and 1920; and

a mandatory special assessment of $100 under 18 U.S.C.
§ 3013(a)(2)(A).

The defendant understands that Count 36 of the Superseding Indictment,

charging money laundering in violation of 18 U.S.C. § 1957, is a felony offense that

carries the following statutory penalties:

a.

a maximum of 10 years in prison;

CASE 0:22-cr-00124-NEB-DTS Doc. 842 Filed 07/24/25 Page 7 of 16

b. a supervised release term up to a maximum
supervised release term of 3 years;

C. 4 maximum fine of $250,000, or twice amount of the criminally
derived property, whichever is greatest;

d. restitution to victims as agreed to by the parties in this
agreement;
e. a mandatory special assessment of $100 under 18 U.S.C.

§ 3013(a)2)A);

7. Revocation of Supervised Release. The defendant understands that

if he were to violate any supervised release condition while on supervised release, the
Court could revoke his supervised release, and the defendant could be sentenced to
an additional term of imprisonment up to the statutory maximum set forth in 18
U.S.C. § 3583(e)(3). See U.S.S.G. §§ 7B1.4, 7B1.5. The defendant also understands
that as part of any revocation, the Court may include a requirement that he be placed
on an additional term of supervised release after imprisonment, as set forth in 18
U.S.C. § 3583(h).

8. Guidelines Calculations. The parties acknowledge that the defendant

will be sentenced in accordance with 18 U.S.C. § 3551, et seq. Nothing in this plea
agreement should be construed to limit the parties from presenting any and all
relevant evidence to the Court at sentencing. The parties also acknowledge that the
Court will consider the United States Sentencing Guidelines in determining the
appropriate sentence and stipulate to the following guideline calculations:

a. Base Offense Level. The parties agree that for Count 5 the base
offense level is 7. U.S.S.G. § 2B1.1(a)(1).

The parties agree that for Count 36 the base offense level is the
offense level for the underlying offense from which the laundered

7

CASE 0:22-cr-00124-NEB-DTS Doc. 842 Filed 07/24/25 Page 8 of 16

funds were derived, pursuant to U.S.S.G. § 2S1.1(a)(1). Therefore,
the base offense level for Count 36 is 7 as calculated under Count
7.

b. Specific Offense Characteristics. The government reserves the
right to argue that for Count 7 a 20-level enhancement applies
pursuant to Guidelines § 2B1.1(b)(1)(K) because the loss was
more than $9.5 million but not more than $25 million. The
defendant reserves the right to argue that for Count 7 an 18-level
enhancement applies pursuant to Guidelines § 2B1.1(b)(1)@)
because the loss was more than $3.5 million but not more than
$9.5 million.

The parties agree that pursuant to Guidelines § 2B1.1(b)(9)(A)
the offense level should be increased by 2 levels because the
offense involved a misrepresentation that the defendant was
acting on behalf of a charitable and/or educational organization.
The government reserves the right to argue that pursuant to
Guidelines § 2B1.1(b)(10) the offense level should be increased by
2 levels because the conduct involved sophisticated means, and
the defendant reserve the right to argue that this enhancement
does not apply. The parties agree that pursuant to Guidelines
§ 2B1.1(b)(12) the offense level should be increased by 2 levels
because the offense involved conduct described in 18 U.S.C. §
1040 (Fraud in Connection with a Major Disaster or Emergency
Benefits). The parties agree that no other specific offense
adjustments apply.

The parties agree that for Count 36 a one-level enhancement
applies pursuant to U.S.S.G. § 2S1.1(b)(2)(A) because defendant
was convicted under 18 U.S.C. § 1957.

C. Chapter 3 Adjustments. The parties agree that Count 5 and
Count 36 of the Superseding Indictment are grouped together into
a single group because both counts embody conduct that is treated
as a specific offense characteristic in the guideline applicable to
the other count. U.S.S.G. § 3D1.2(c). Therefore, the offense level
applicable to the group will be the highest offense level of the
counts in the group, which, depending upon the loss calculation
under Guidelines § 2B1.1(b)(1) and the sophisticated means
enhancement, would be either 29 (as the government believes) or
25 (as the defendant believes). The parties agree that no Chapter
3 adjustments apply, and particularly that §3B1.1 (aggravating
role) does not apply.


CASE 0:22-cr-00124-NEB-DTS Doc. 842 _ Filed 07/24/25 Page 9 of 16

d. Acceptance of Responsibility. The government agrees to
recommend that the defendant receive a 2-level reduction for
acceptance of responsibility pursuant to U.S.S.G. § 3E1.1(a). As
the defendant has timely notified the government of his intention
to enter a plea of guilty, the government agrees to recommend
that the defendant receive an additional 1-level reduction
pursuant to U.S.S.G. § 3E1.1(b). Whether these reductions will be
imposed shall be determined by the Court in its discretion.
However, the defendant understands and agrees that the
government’s recommendations are conditioned upon the
following: (1) the defendant testifies truthfully during the change
of plea and sentencing hearings; (2) the defendant provides full,
complete and truthful information to the United States Probation
Office in the pre-sentence investigation; and (3) the defendant
engages .in no conduct inconsistent with acceptance of
responsibility before the time of sentencing, including frivolously
denying facts in the Presentence Report. Nothing in this
agreement limits the right of the government, pursuant to
U.S.S.G. § 3E1.1 and/or § 3C1.1 to seek denial of a reduction for
acceptance of responsibility or an enhancement for obstruction of
justice should the defendant engage in any conduct inconsistent
with acceptance of responsibility, including moving to withdraw
his guilty plea after it is entered.

e, Criminal History Category. The parties believe that, at the time
of sentencing, the defendant will fall into Criminal History
Category I. U.S.S.G. § 4A1.1. This does not constitute a
stipulation, but a belief based on an assessment of the
information currently known. The defendant’s actual criminal
history and related status will be determined by the Court based
on the information presented in the Presentence Report and by
the parties at the time of sentencing. The defendant understands
that if the presentence investigation reveals any prior adult or
juvenile sentence which should be included within his criminal
history under the U.S. Sentencing Guidelines, the defendant will
be sentenced based on his true criminal history category, and he
will not be permitted to withdraw from this Plea Agreement.
U.S.S.G. § 4A1.1.

f. 7ero-Point Offender Adjustment. Because the defendant has zero
criminal-history points and no disqualifying conduct, the parties
agree the defendant qualifies for a 2-level adjustment under
U.S.S.G. § 4C1.1.


CASE 0:22-cr-00124-NEB-DTS Doc. 842 Filed 07/24/25 Page 10 of 16

g. Guidelines Range. If, as the government believes, the adjusted
offense level is 29 and the criminal history category is I, the
Sentencing Guidelines range is 87 - 108 months of imprisonment.
If, as the defendant believes, the adjusted offense level is 25 and
the criminal history category is I, the Sentencing Guidelines
range is 57 - 71 months of imprisonment.

h. Fine Range. If, as the government believes, the adjusted offense
level is 29, the Sentencing Guidelines fine range is $30,000 to
$300,000. If, as the defendant believes, the adjusted offense level
is 25, the Sentencing Guidelines fine range is $20,000 to
$200,000. U.S.S.G. § 5E1.2(c)(8).

9. Discretion of the Court. The foregoing stipulations are binding on

the parties, but do not bind the Court. The parties understand that the Sentencing
Guidelines are advisory and their application is a matter that falls solely within the
Court’s discretion. The Court may make its own determination regarding the
applicable guideline factors and the applicable criminal history category. The Court
may also depart from the applicable Guidelines. If the Court determines that the
applicable guideline calculations or the defendant’s criminal history category are
different from that stated above, such a determination shall not provide a basis for
the parties to withdraw from this agreement, and the defendant will be sentenced
pursuant to the Court’s determinations.

10. Agreements as to Sentencing Recommendation. The parties are

free to recommend whatever sentence they deem appropriate. The parties reserve the
right to make a motion for departures from the applicable Guidelines range pursuant
to 18 U.S.C. § 3553(a), to oppose any such motion made by the opposing party, and to

argue for a sentence outside the applicable Guidelines range. If the Court does not

10

CASE 0:22-cr-00124-NEB-DTS Doc. 842 Filed 07/24/25 Page 11 of 16

accept the sentencing recommendation of the parties, the defendant will have no right
to withdraw his guilty plea.

11. Special Assessment. The Sentencing Guidelines require payment ofa

special assessment in the amount of $100 for each felony count of which the defendant
is convicted. U.S.S.G. § 5E1.3. The defendant agrees that the special assessment is
due and payable at the time of sentencing.

12. Restitution Agreement. The defendant understands and agrees that

the Mandatory Victim Restitution Act, 18 U.S.C. § 3663A, applies and that the Court
is required to order the defendant to make restitution to the victims of his crime. The
defendant understands and agrees the Court may order the defendant to make
restitution to any victim of the scheme regardless of whether the victim was named
in the Superseding Indictment. The parties agree that the defendant owes restitution
in an amount that does not exceed $7,324,412 and that is not less than $1,500,000.

13. Disclosure of Assets. The defendant will fully and completely disclose

to the United States Attorney’s Office the existence and location of any assets in
which the Defendant has any right, title, or interest, or over which the defendant
exercises control, directly or indirectly, including those assets held by a spouse,
nominee or other third party, or any business owned or controlled by the defendant.
The defendant agrees to assist the United States in identifying, locating, returning,
and transferring assets for use in payment of fines and/or forfeiture ordered by the
Court. The Defendant agrees to complete a financial statement within two weeks of

the entry of his guilty plea. The defendant further agrees to execute any releases that

11

CASE 0:22-cr-00124-NEB-DTS Doc. 842 Filed 07/24/25 Page 12 of 16

may be necessary for the United States to obtain information concerning the
defendant’s assets and expressly authorizes the United States to obtain a credit
report on the defendant to evaluate his ability to satisfy financial obligations imposed
by the Court. If requested by the United States, the defendant agrees to submit to
one or more asset interviews or depositions under oath.

14. Forfeiture. The defendant agrees to forfeit to the United States,
pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c), all property, real or
personal, which constitutes or is derived from proceeds traceable to the wire fraud.
scheme, as charged in the Superseding Indictment, including but not limited to:

a. The real property located at 5657 Maple Drive, Lewis Center,
Ohio;

b. $1,842,797.55 seized from US Bank account No. 104785323379,
held in the name of ThinkTechAct Foundation;

c. $456,968.36 seized from Spire Credit Union account No. 752231-
00, held in the name of MIB Holdings LLC; and

d. $448,285.14 seized from Spire Credit Union account No. 752231-
11, held in the name of MIB Holdings LLC.

The defendant agrees that the United States may, at its option, forfeit the
property through civil, criminal or administrative proceedings, waives any deadline
or statute of limitations for the initiation of any such proceedings, and abandons any
interest he may have in the property. The defendant waives all statutory and
constitutional defenses to the forfeiture and waives any right to contest or challenge
(including direct appeal, habeas corpus, or any other means) such forfeiture, directly

or through any company he owns or controls, on any grounds. To the extent the

12

CASE 0:22-cr-00124-NEB-DTS Doc. 842 Filed 07/24/25 Page 13 of 16

defendant has requested remission or mediation of the forfeiture of the property, he
withdraws any such requests. The defendant agrees not to assist any third party in
challenging the forfeiture of the property.

With respect to the real property located at 5657 Maple Drive, Lewis Center,
Ohio, the defendant agrees that he paid $620,000 from an MIB Holdings LLC bank
account, all of which was traceable to the fraud scheme, toward the construction of a
residence on this property. The defendant agrees that the equity in this property
resulting from the $620,000 referenced above is subject to forfeiture. With respect to
this property, the United States agrees that it will forfeit a sum of money equal to the
equity in this property that is traceable to payments made with fraud proceeds in lieu
of forfeiting that real property, provided that any such payment to the United States
is made using funds not traceable to the fraudulent scheme described above and that
such payment is made at least 60 days prior to the defendant’s sentencing hearing.

The defendant consents to the entry of a money judgment forfeiture in the
amount of not more than $7,324,412 but not less than $1.5 million, which represents
the amount of proceeds he obtained from the wire fraud scheme alleged in
Superseding Indictment. The defendant will receive a credit against the money
judgment forfeiture for the net value of all property that is forfeited from him in this
matter. The United States reserves the right to seek forfeiture of substitute assets
and any additional directly forfeitable property.

15. Waivers of Appeal and Collateral Attack. The parties hereby waive

the right to appeal any non-jurisdictional issues. This appeal waiver includes, but is

13

CASE 0:22-cr-00124-NEB-DTS Doc. 842 Filed 07/24/25 Page 14 of 16

not limited to: the defendant’s waiver of the right to appeal guilt or innocence, any
issues relating to the negotiation, taking or acceptance of the guilty plea, the sentence
imposed or any issues that relate to the calculation of the Guidelines range, the
supervised-release term and conditions imposed, any restitution obligations, and the
constitutionality of the statutes to which the defendant is pleading guilty. The
parties agree, however, that excluded from this waiver is an appeal by defendant of
the substantive reasonableness of a term of imprisonment above the top of the
Guidelines range, and an appeal by the government of the substantive
reasonableness of a term of imprisonment below the bottom of the Guidelines range.

The defendant also waives the right to collaterally attack his conviction and
sentence under 28 U.S.C. § 2255 except based upon a claim of ineffective assistance
of counsel. This collateral-review waiver does not operate to waive a collateral
challenge under 28 U.S.C. § 2255 based on new legal principles enunciated in
Supreme Court case law decided after the date of this Plea Agreement that are both
substantive and have retroactive effect. For purposes of this provision, legal
principles that are substantive and retroactive are those that narrow the reach of the
offense of conviction and render the defendant’s conduct non-criminal or that render
the sentence imposed illegal.

The defendant has discussed these rights with the defendant’s attorney. The
defendant understands the rights being waived, and the defendant waives these

rights knowingly, intelligently, and voluntarily.

14

CASE 0:22-cr-00124-NEB-DTS Doc. 842 Filed 07/24/25 Page 15 of 16

16. FOIA Requests. The defendant waives all rights to obtain, directly or

through others, information about the investigation and prosecution of this case
under the Freedom of Information Act and the Privacy Act of 1974, 5 U.S.C. §§ 552,
552A.

17. Complete Agreement. This, along with any agreement signed by the

parties before entry of plea, is the entire agreement and understanding between the
United States and the defendant. By signing this plea agreement, the defendant
acknowledges: (a) that the defendant has read the entire agreement and has reviewed
every part of it with the defendant’s counsel; (b) that the defendant fully understands
this plea agreement; (c) that no promises, agreements, understandings, or conditions
have been made or entered into in connection with his decision to plead guilty, except
those set forth in this plea agreement; (d) that the defendant is satisfied with the
legal services and representation provided by defense counsel in connection with this
plea agreement and matters related to it; (e) that the defendant has entered into this

plea agreement freely, voluntarily, and knowingly; and (f) that the defendant’s

15

CASE 0:22-cr-00124-NEB-DTS Doc. 842

Filed 07/24/25 Page 16 of 16

decision to plead guilty in accord with the terms and conditions of this plea agreement

is made of the defendant’s own free will.

Dated:

BY:

Dated: a/oy /2025

ome op ob

16

JOSEPH H. THOMPSON

Acting d States oy
Wht.

HEE S. EBERT
HARRY M. JACOBS
DANIEL W. BOBIER
Assistant United States Attorneys

lia

NAHAD IBRAB

Congh J. [Lhe
WILLIAM AM R. DOOLING
Counsel for Defendant

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