United States District Court, District of Minnesota — Case 0:22-cr-00223, Doc. 626

Summary

Defendant Aimee Marie Bock's Motion for Judgment of Acquittal or a New Trial with a supporting memorandum of law, filed 04/02/25 as Doc. 626 in United States v. Aimee Marie Bock (1), Criminal No. 22-CR-223 (NEB/DTS), in the U.S. District Court for the District of Minnesota. Through counsel Kenneth Udoibok, Bock asks the court to set aside the jury verdict on Counts 1, 2, 4, 5, 12, 15 and 40. She argues that the evidence was insufficient and that the verdict was against the weight of the evidence. She states that the false claims came from site operators and vendors, that MDE approved all the reimbursement claims, and that the jury deliberated less than 5 hours after a 6-week trial. The motion is dated April 2, 2025.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Cite this document

“United States District Court, District of Minnesota — Case 0:22-cr-00223, Doc. 626.” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-united-states-v-bock-dkt-626-d-minn-bbb61e7d4f/, SHA-256 7309c319c0e2a98f0441447ceae8bdaff206a02d61aeb72678c25e3789900c56.

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CASE 0:22-cr-00223-NEB-DTS Doc. 626 Filed 04/02/25 Page 1 of 18

UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA

United States of America,

Plaintiff,
CRIMINAL NO: 22-CR-223 (NEB/DTS)
vs.
Aimee Marie Bock (1),

Defendant.

MOTION FOR JUDGMENT OF ACQUITTAL OR A NEW TRIAL

Pursuant to Rule 33(a) and 33 (b)(2) of the Federal Rules of Criminal Procedure,

Defendant Aimee Marie Bock (hereinafter “Defendant”) respectfully moves this Court

for a judgment of acquittal or a new trial because the evidence posited by the United

States of America (hereinafter “Government”) at trial was insufficient to sustain a

conviction on Counts 1, 2, 4, 5, 12, 15 and 40 of the indictment against the Defendant.

It was apparent that the Government needed a convenient defendant, such as the

Defendant among a host of executive directors of food nutrition organizations in the state

of Minnesota, to justify the errors created by the relaxation of regulations governing the

COVID-19-era federal food nutrition programs. The Government ignored that all the

reimbursement claims submitted by Feeding Our Future through the Defendant to the

Minnesota Department of Education (hereinafter referred to as “MDE”) were approved

by MDE.

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The parties who submitted false reimbursement claims were site operators and

vendors, not the Defendant. Unlike MDE, the Defendant had limited authority to

uncover clever fraudulent activities of site and vendor operators and should not be held

responsible for other people’s criminal behavior.

After six weeks of trial, the Government failed to present any evidence that the

Defendant orchestrated, and personally benefited from, the millions misappropriated by

other entities. The Government paraded as evidence flamboyant purchases and lifestyles

of co-defendants involved in the food program and the Defendant’s African American

former boyfriend to inflame the jury. The Government even improperly suggested that

the Defendant accused MDE of racial or national origin discrimination. This strategy

was intended to inflame the jury, who could not have considered all the exhibits

presented after six weeks of trial in less than five hours of deliberation.

The verdict in this case is against the weight of evidence in favor of the Defendant.

The Government failed to present sufficient evidence linking the Defendant to the

offenses, let alone show that the Defendant conspired with Defendant Salim Ahmed Said

or any other person to commit wire fraud or federal program bribery.

Furthermore, the Government failed to present sufficient evidence that the

Defendant committed wire fraud and engaged in bribery in the federal nutrition program.

The trial revealed that the Government presented speculative testimony linking the

Defendant to the alleged crimes. Indeed, even the prima facie evidence weighed heavily

against the verdict because it lacked a causal link to the Defendant.

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Accordingly, a miscarriage of justice will occur if the verdict is not vacated and/or

a new trial is not set. The Defendant was convicted because of the crimes of others. The

speed with which the jury returned its verdict after six weeks of trial lends credence to the

need for a new trial.

Respectfully Submitted

KENNETH UBONG UDOIBOK, P.A.

April 2, 2025 s/Kenneth U. Udoibok
Kenneth U. Udoibok (#0262523)
Flour Exchange Building, Suite 5010
310 Fourth Avenue South
Minneapolis, MN 55415
Phone: (612) 808-6031
k@KenULaw.com

ATTORNEY FOR DEFENDANT
AIMEE MARIE BOCK

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UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA

United States of America,

Plaintiff,
vs.
CRIMINAL NO: 22-CR-223 (NEB/DTS)

Aimee Marie Bock (1),

Defendant.

DEFENDANT’S MEMORANDUM OF LAW IN SUPPORT OF DEFENDANT’S
MOTION FOR JUDGMENT OF ACQUITTAL OR A NEW TRIAL

I. SUMMARY OF FACTS
On September 13, 2022, 14 defendants were indicted for a massive scheme to

defraud the federal child nutrition program of millions of dollars during the COVID-19

pandemic. The defendants were alleged to have exploited changes to the program meant

to ensure children received meals during school closures. Instead of feeding children,

they were alleged to have misappropriated millions in federal funds for their personal

gain. (ECF. Doc. 1). But the Government failed to demonstrate that the Defendant

orchestrated or personally benefited from the misappropriated funds.

Background of the Federal Child Nutrition Program

The Food and Nutrition Service of the United States Department of Agriculture

(hereinafter referred to as “USDA”) administers programs that provide free meals to

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children, including the Summer Food Service Program and the Child and Adult Care

Food Program. The programs reimburse organizations for serving meals to children in

low-income areas. During the pandemic, the USDA waived specific requirements,

allowing for-profit restaurants to participate and distribute meals outside of educational

programs.

The Defendants and Their Roles

The Defendant was the executive director of Feeding Our Future, which is alleged

to have sponsored hundreds of fraudulent meal sites. Other defendants created shell

companies and fake meal sites that claimed to be serving thousands of meals daily. Key

players included Abdikerm Eidleh and Hadith Yusuf Ahmed, who recruited sites for

Feeding Our Future that fraudulently claimed to have served millions of meals. The

Defendant only submitted reimbursement claims that were initially approved by the site

operators and ultimately approved by MDE.

The Fraudulent Scheme

The defendant owners of some sites submitted unbeknownst to Defendant Bock

false reimbursement claims for millions of meals that were never served to children.

Feeding Our Future received over $18 million in administrative fees for sponsoring sites,

unaware that some of these sites were submitting fraudulent reimbursement claims.

Some people paid kickbacks to Feeding Our Future employees, such as Abdikerm Eidleh

and Hadith Yusuf Ahmed, in exchange for sponsorship; however, the Government failed

to show that the Defendant knew or received the bribes or kickbacks.

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Defendant Aimee Bock’s Indictment

The Defendant was charged with conspiracy to commit wire fraud, federal

programs bribery, and wire fraud, as well as bribery of federal programs. The Defendant

faced trial for conspiring with Salim Ahmed Said and others to commit wire fraud and

federal program bribery. On March 19, 2025, less than 5 hours after a 6-week trial, the

jury returned a guilty verdict on all counts against the Defendant. However, the

Government failed to present sufficient evidence that the Defendant conspired to commit

wire fraud and federal program bribery and engaged in wire fraud and bribery involving

federal programs.

II. CONSPIRACY—COUNTS 1 & 15
Introduction

The Government failed to present sufficient evidence to the jury to prove beyond a

reasonable doubt that the Defendant conspired to submit false reimbursement claims for

meals that were never served to children. Under the legal standards governing conspiracy

and sufficiency of evidence in the Eighth Circuit, the evidence presented at trial was

insufficient to establish the essential elements of conspiracy.

Legal Standards

To prove conspiracy, the Government must establish three elements: (1) an

agreement between two or more persons to pursue an unlawful objective, (2) the

Defendant’s knowledge of the unlawful objective and voluntary agreement to join the

conspiracy, and (3) an overt act by one or more members of the conspiracy in furtherance

of the objective. United States v. Wrehe, 628 F.2d 1079 (8th Cir. 1980); United States v.

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Pardue, 983 F.2d 835 (8th Cir. 1993). Each element may be proven by circumstantial

evidence, and proof of a tacit conspiratorial agreement is sufficient. United States v.

Mauskar, 557 F.3d 219 (5th Cir. 2009). Fraudulent intent need not be proved directly and

can be inferred from the facts and circumstances surrounding a defendant’s actions.

United States v. Hetherington, 256 F.3d 788 (8th Cir. 2001). Circumstantial evidence

alone can prove the elements of conspiracy, including knowledge. United States v.

Woods, 2018 U.S. Dist. LEXIS 126132, 2018 WL 3579477 (W.D. Ark., July 2018).

However, a defendant challenging the sufficiency of the evidence in a conspiracy

case faces a heavy burden. The jury may draw reasonable inferences from the evidence

presented about the defendant’s state of mind. On appeal, the denial of a motion for a

judgment of acquittal is reviewed de novo. The appellate court will affirm the jury’s

verdict unless, viewing the evidence in the light most favorable to the Government, no

reasonable jury could have found the defendant guilty. United States v. Little, 961 F.3d

1035 (8th Cir. 2020); United States v. Izaguirre Guerrero, 674 Fed. Appx. 604, 2017 U.S.

App. LEXIS 2081, 2017 WL 480505 (8th Cir. 2017).

Failure to Prove an Agreement to Commit an Unlawful Objective

The Government failed to present sufficient evidence to establish that the

Defendant agreed with others to submit false reimbursement claims. While circumstantial

evidence may be used to prove a conspiracy, the evidence must demonstrate more than

mere speculation or conjecture. The Government did not provide direct evidence of an

agreement, nor did it present circumstantial evidence sufficient to infer a tacit

understanding between the Defendant and any alleged co-conspirators. Without evidence

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of a meeting of minds, the Government failed to satisfy the first element of conspiracy.

United States v. Wells, 706 F.3d 908 (8th Cir. 2013).

Insufficient Evidence of Knowledge and Intent

The Government also failed to prove that the Defendant had knowledge of the

alleged unlawful objective or that she voluntarily agreed to join the conspiracy.

Fraudulent intent cannot be presumed and must be established through evidence. While

the Government may rely on circumstantial evidence to prove intent, the evidence

presented at trial did not support a reasonable inference that the Defendant knowingly

and intentionally participated in a scheme to defraud. United States v. Davis, 901 F.3d

1030 (8th Cir. 2018). The absence of direct evidence of the Defendant’s intent, combined

with the lack of compelling circumstantial evidence, renders the Government’s case

insufficient.

No Overt Act in Furtherance of the Conspiracy

The Government failed to demonstrate that the Defendant committed or

participated in any overt act in furtherance of the alleged conspiracy. An overt act is a

necessary element of conspiracy, and the Government must prove that such an act was

taken to advance the unlawful objective. United States v. McCarty, 611 F.2d 220 (8th Cir.

1979); United States v. Hermes, 847 F.2d 493 (8th Cir. 1988). The evidence presented at

trial did not establish that the Defendant took any specific actions to further the alleged

scheme to submit false reimbursement claims. For example, the reimbursement claims

that she filed with MDE were approved by MDE. The childcare business she sold was a

well-established business, except for the enrollment of children. The School Age

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Consulting’s manual was purchased by people not involved in the child food nutrition

business. The Government failed to demonstrate the Defendant’s overt conspiratory act.

Failure to Meet the Standard for Sufficiency of Evidence

The appellate standard for reviewing the sufficiency of the evidence requires the

court to view the evidence in the light most favorable to the Government. United States

v. Norquay, 987 F.2d 475 (8th Cir. 1993); United States v. Covos, 872 F.2d 805 (8th Cir.

1993). However, even under this deferential standard, the evidence presented at trial was

insufficient to support the jury’s verdict. The Government’s case relied heavily on

speculation and conjecture rather than concrete evidence of the Defendant’s participation

in a conspiracy.

Conclusion

For the reasons stated above, the Government failed to present sufficient evidence

to prove beyond a reasonable doubt that the Defendant conspired to submit false

reimbursement claims for meals that were never served to children. The evidence

presented at trial did not establish the essential elements of conspiracy, and the jury’s

verdict cannot be sustained.

Accordingly, Defendant respectfully requests that the court grant her motion for a

judgment of acquittal or a new trial on Counts 1 and 15 of the indictment.

III. WIRE FRAUD—COUNTS 4, 5, 8, 12

Introduction

The Defendant respectfully asserts that the Government failed to present sufficient

evidence to prove beyond a reasonable doubt that she committed wire fraud, in violation

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of 18 U.S.C. 1343, by submitting reimbursement claims for meals that were never served

to children. The evidence presented at trial was insufficient to establish the essential

elements of wire fraud, and the jury’s verdict cannot be sustained.

Legal Standards

To prove wire fraud under 18 U.S.C. 1343, the Government must establish three

essential elements: (1) intent to defraud, (2) participation in a scheme to defraud, and (3)

the use of a wire in furtherance of the fraudulent scheme. United States v. Garbacz, 33

F.4th 459 (8th Cir. 2022); United States v. Roberts, 881 F.3d 1049 (8th Cir. 2018). The

false or fraudulent representation must also be material to the scheme. Intent to defraud

need not be proven by direct evidence and may be inferred from circumstantial evidence;

however, the evidence must be sufficient to establish the Defendant’s knowledge and

intent to participate in the fraudulent scheme. United States v. Davis, 901 F.3d 1030. The

sufficiency of the evidence is reviewed de novo, and the jury’s verdict will be upheld

unless no reasonable jury could have found the Defendant guilty when viewing the

evidence in the light most favorable to the Government. United States v. Thompson, 686

F.3d 575 (8th Cir. 2012).

Failure to Prove Intent to Defraud

The Government failed to present sufficient evidence to establish that the

Defendant acted with the requisite intent to defraud. While the intent to defraud may be

inferred from circumstantial evidence, the evidence must demonstrate more than mere

speculation or conjecture. The Government did not provide direct evidence of the

Defendant’s intent, nor did it present circumstantial evidence sufficient to infer that she

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knowingly and intentionally participated in a scheme to defraud. United States v. Davis,

901 F.3d 1030. The mere submission of reimbursement claims, without evidence of the

Defendant’s knowledge that the claims were false or her intent to deceive, is insufficient

to establish intent to defraud. MDE approved all the claims submitted by the Defendant.

Insufficient Evidence of Participation in a Scheme to Defraud

The Government also failed to prove that the Defendant participated in a scheme

to defraud. To establish this element, the Government must show that the Defendant

knowingly devised or participated in a scheme with the intent to defraud. The evidence

presented at trial did not demonstrate that the Defendant knowingly engaged in any

fraudulent activity. The Government’s case relied heavily on the assertion that meals were

not served as claimed. Still, it failed to connect the Defendant to any deliberate or

knowing participation in a scheme to submit false claims. Without evidence of the

Defendant’s active and knowing participation, the Government cannot satisfy this

element of wire fraud.

Failure to Prove Use of a Wire in Furtherance of the Fraudulent Scheme

The Government must also prove that wire communication was used in

furtherance of the fraudulent scheme. While the use of a wire may be established through

circumstantial evidence, the Government must demonstrate that the wire communication

was directly connected to the execution of the fraudulent scheme. United States v. Bock,

2025 U.S. Dist. LEXIS 492, 2025 WL 18629 (D. Minn. January 2, 2025); United States v.

Hecker, 2010 U.S. Dist. LEXIS 89740, 2010 WL 3463393 (D. Minn. July 6, 2010). The

evidence presented at trial did not establish that the Defendant used any wire

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communication with the intent to further a fraudulent scheme. United States v. Earles,

955 F.2d 1175. For example, Government Exhibits Z-2, Z-4, Z-5, and Z-12, which were

offered at trial to demonstrate the Defendant’s furtherance of the fraud scheme, were

misleading. Besides the claims being approved by MDE, the Government failed to show

that the Defendant received Government Exhibit Z-12 and acted upon it. Without this

connection, the Government cannot satisfy the third element of wire fraud.

Failure to Prove Materiality of the Alleged Fraudulent Representations

The Government must also prove that the false or fraudulent representations were

material to the scheme. Materiality requires that the misrepresentation had a natural

tendency to influence, or was capable of influencing, the decision of the party to whom it

was addressed. The evidence presented at trial did not establish that the alleged false

claims were material to the reimbursement process. The Defendant did not create the fake

meal counts. She was unaware of the fraudulent meal counts. The parties whom she

knew were engaging in fraudulent conduct in the program were terminated by the

Defendant. Without evidence of materiality, the Government’s case fails as a matter of

law.

Insufficiency of Evidence to Support the Jury's Verdict

The sufficiency of evidence is reviewed de novo, and the jury’s verdict will be

upheld unless no reasonable jury could have found the Defendant guilty when viewing

the evidence in the light most favorable to the government. In this case, the evidence

presented at trial was insufficient to establish the essential elements of wire fraud. The

Government’s case relied on speculation and conjecture rather than concrete evidence of

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the Defendant’s intent, participation, and use of a wire in furtherance of a fraudulent

scheme. No reasonable jury could have found the Defendant guilty based on the evidence

presented.

Conclusion

For the reasons stated above, the Government failed to present sufficient evidence

to prove beyond a reasonable doubt that the Defendant committed wire fraud, in violation

of 18 U.S.C. 1343. The evidence presented at trial did not establish the essential elements

of wire fraud, and the jury’s verdict cannot be sustained.

Accordingly, Defendant respectfully requests that the Court grant her motion for a

judgment of acquittal or a new trial.

IV. FEDERAL PROGRAMS BRIBERY—COUNT 40

Introduction

The Defendant respectfully submits this post-trial brief asserting that the

Government failed to present sufficient evidence to prove beyond a reasonable doubt that

she received or solicited bribes during her participation in the federal nutrition program,

in violation of 18 U.S.C. 666(a)(1)(B) and (a)(2). The evidence presented at trial was

insufficient to establish the essential elements of federal program bribery, and the jury’s

verdict cannot be sustained.

Legal Standards

To prove Federal Programs Bribery under 18 U.S.C. 666(a)(1)(B), the

Government must establish that the Defendant: (1) was an agent of an organization

receiving federal benefits exceeding $10,000 annually; (2) corruptly solicited or accepted

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something of value in connection with a transaction involving $5,000 or more; and (3)

acted with the intent to be influenced in connection with the organizations business or

transactions. United States v. Bock, 2024 U.S. Dist. LEXIS 235370 (D. Minn. Nov. 1,

2024); United States v. Hines, 541 F.3d 833 (8th Cir. 2008). Similarly, under 18 U.S.C.

666(a)(2), the government must prove that the Defendant: (1) corruptly gave, offered, or

agreed to give something of value to an agent of an organization receiving federal

benefits exceeding $10,000 annually; (2) in connection with a transaction involving

$5,000 or more; and (3) acted with the intent to influence the agent in connection with the

organizations business or transactions. United States v. Bock, 2024 U.S. Dist. LEXIS

235370.

The Government must also prove the Defendant’s corrupt intent, which requires

evidence that the Defendant acted knowingly and dishonestly to achieve an unlawful

result or use unlawful means. The sufficiency of the evidence is reviewed de novo, and

the jury’s verdict will be upheld unless no reasonable jury could have found the

Defendant guilty when viewing the evidence in the light most favorable to the

Government. United States v. Thompson, 686 F.3d 575.

Failure to Prove Corrupt Intent

The Government failed to present sufficient evidence to establish that the

Defendant acted with the requisite corrupt intent. Corrupt intent requires proof that the

Defendant acted knowingly and dishonestly to achieve an unlawful result or use unlawful

means. The evidence presented at trial did not demonstrate that the Defendant knowingly

solicited or accepted bribes with the intent of being influenced in connection with the

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federal nutrition program. The evidence presented at trial indicated that the Defendant

owned a childcare business and produced manuals that she made available to the public

for purchase. People who purchased the manuals were not necessarily participants in the

food nutrition program. Those purchases could not be bribes or kickbacks. Defendant

Salim Said, who is alleged to have bribed the Defendant when the childcare business was

purchased, was only a witness to the childcare sale transaction, not the purchaser.

Additionally, the buyer, Cosmopolitan Business Solutions LLC, had been a site or vendor

to Feeding Our Future for 18 months before purchasing the childcare business. It is

grossly illogical to bribe the Defendant 18 months after the purported official act.

The Government’s case relied entirely on speculation and conjecture rather than

concrete evidence of the Defendant’s intent to engage in corrupt conduct. Without proof

of corrupt intent, the Government cannot satisfy the elements of federal programs bribery

under 18 U.S.C. 666(a)(1)(B) or (a)(2).

Insufficient Evidence of Solicitation or Acceptance of Bribes

The Government also failed to prove that the Defendant solicited or accepted

anything of value in connection with a transaction involving $5,000 or more. To meet this

element, the Government must show that the Defendant corruptly solicited or accepted

something of value with the intent to be influenced in connection with the organization’s

business or transactions. The evidence presented at trial did not establish that the

Defendant received or solicited any payments or benefits in exchange for her actions

related to the federal nutrition program. The absence of direct evidence of solicitation or

acceptance of bribes further undermines the Government’s case.

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Failure to Prove Connection to Federal Program Transactions

The Government must also prove that the alleged bribes were connected to

transactions involving the federal nutrition program and that the organization received

federal benefits exceeding $10,000 annually. Although Feeding Our Future’s receipt of

federal benefits was not disputed, the Government failed to establish a direct connection

between the alleged bribes and specific transactions involving the federal program.

Without evidence linking the alleged bribes to the federal program, the Government

cannot satisfy the statutory requirements of 18 U.S.C. 666(a)(1)(B) or (a)(2). United

States v. Sabri, 326 F.3d 937 (8th Cir. 20030; United States v. Baumann, 684 F. Supp. 2d

1146 (D.S.D. January 5, 2010).

Insufficiency of Evidence to Support the Jury’s Verdict

The sufficiency of the evidence is reviewed de novo, and the jury’s verdict will be

upheld unless no reasonable jury could have found the Defendant guilty when viewing

the evidence in the light most favorable to the Government. In this case, the evidence

presented at trial was insufficient to establish the essential elements of federal programs

bribery. The government’s case relied on speculation and failed to provide concrete

evidence of the Defendant’s corrupt intent, solicitation, or acceptance of bribes, or

connection to federal program transactions. No reasonable jury could have found the

Defendant guilty based on the evidence presented.

Conclusion

For the reasons stated above, the Government failed to present sufficient evidence

to prove beyond a reasonable doubt that the Defendant received or solicited bribes during

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her employment with Feeding Our Future and participation in the federal nutrition

program, in violation of 18 U.S.C. 666(a)(1)(B) and (a)(2). The evidence presented at

trial did not establish the essential elements of federal program bribery, and the jury’s

verdict cannot be sustained.

Accordingly, Defendant respectfully requests that the court grant her motion for a

judgment of acquittal or a new trial.

CONCLUSION

The verdict in this case is against the weight of evidence in favor of the Defendant.

The only evidence against the Defendant, other than the disputed testimonies of witnesses

who had pleaded guilty to a myriad of frauds, was the testimony of two Feeding Our

Future’s board members. Those board members did not facilitate the filing of any

reimbursement claims. In sum, the evidence at trial weighed so heavily against the

verdict that a miscarriage of justice would occur if the verdict were not vacated and a new

trial were not set. United States v. McClellon, 578 F.3d 846, 857 (8th Cir. 2009).

When this Court considers whether the Government presented sufficient evidence

to support the jury verdict, it will determine that the Government did not show sufficient

evidence that the Defendant engaged in a material fraudulent act. Because the Defendant

was indicted along with site operators as well as vendors, she was scapegoated and held

responsible for the crimes of other people.

The trial record is clear that the Defendant attempted to terminate or ban sites and

vendors that she could prove were engaged in fraudulent activities. She sought the

assistance of MDE to no avail. To be held responsible for other people’s crimes is unfair.

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To avoid miscarriage of justice, the Defendant requests that the Court enter a judgment of

acquittal for her or order a new trial.

Respectfully Submitted,

KENNETH UBONG UDOIBOK, P.A.

April 2, 2025 /s/Kenneth U. Udoibok
Kenneth U. Udoibok (#0262523)
Flour Exchange Building, Suite
5010 310 Fourth Avenue South
Minneapolis, MN 55415
Phone: (612) 808-6031
k@kenulaw.com

ATTORNEY FOR DEFENDANT
AIMEE MARIE BOCK

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