Court filing — United States v. Bock et al. (Feeding Our Future) (Dkt. 255-1, D. Minn.)

Summary

Government Exhibit A, Doc. 255-1, filed 02/19/24 in Case 0:22-cr-00223-NEB-DTS, 22-cr-223 (NEB/TNL): an Application for a Search Warrant, Case No. 22-MJ-039 TNL, with the Affidavit of Travis Wilmer, a Special Agent with the Federal Bureau of Investigation (FBI), before Magistrate Judge Tony N. Leung in the District of Minnesota. The application seeks warrants for the Feeding Our Future office in Saint Anthony and five other premises, citing mail fraud, wire fraud, conspiracy and money laundering. In the portion of the text available here, the affidavit describes the affiant's experience, says that individuals and companies in Minnesota engaged in a large-scale scheme to fraudulently obtain federally funded child nutrition program money, and sets out facts linking Aimee Bock to the first two premises.

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

Full text

Text recognized from a scanned document; may contain errors. Pages 19, 24–26, 31, and 36 of 99 are not shown because the text could not be recognized reliably.

CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~Filed 02/19/24 Page1of99

JHT:ejn
AO 106 (Rev. 04/10) Application for a Search Warrant 2021R00210

UNITED STATES DISTRICT COURT

for the
District of Minnesota

IN THE MATTER OF THE SEARCH OF THE SEALED BY ORDER OF THE COURT

OFFICE LOCATED AT 3055 OLD HIGHWAY 8,
SUITES 312 AND 229, SAINT ANTHONY,
MINNESOTA 55418, AS FURTHER DESCRIBED
IN ATTACHMENT A-1

Case No, 22-MJ-039 TNL

APPLICATION FOR A SEARCH WARRANT

I, Travis Wilmer, a federal law enforcement officer or an attorney for the government, request a search warrant
and state under penalty of perjury that I have reason to believe that on the following person or property:

See Attachment A-1, incorporated here
located in the State and District of Minnesota, there is now concealed:
See Attachment B-1, incorporated here

The basis for the search under Fed. R, Crim. P. 41(c) is (check one or more):

>. 4 evidence of a crime;
Xx contraband, fruits of crime, or other items illegally possessed;
Xx property designed for use, intended for use, or used in committing a crime;

a person to be arrested or a person who is unlawfully restrained.

The search is related to a violation of:

Code Section

Title 18, United States Code, Section 1341
Title 18, United States Code, Section 1343
Title 18, United States Code, Section 1349
Title 18, United States Code, Section 1956, 1957

The application is based on these facts:

See Affidavit, incorporated here
Xx Continued on the attached sheet.

SUBSCRIBED and SWORN before me by reliable
electronic means (FaceTime, Zoom and/or email)
pursuant to Fed, R. Crim. P. 41(d)(3)

City and State: Minneapolis, MN

Offense Description

Mail Fraud

Wire Fraud

Conspiracy
Money Laundering

Travis Wilmer, Special Agent
Federal Bureau of Investigation

Printed Name and Title

The Honorable Tony N. Leung
United States Magistrate Judge EXHIBIT

GOVERNMENT

Printed Name and Titl
A

22-cr-223 (NEB/TNL)
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 Filed 02/19/24 Page 2 of99

STATE OF MINNESOTA )
) ss. AFFIDAVIT OF TRAVIS WILMER

COUNTY OF HENNEPIN )

Your affiant, Travis Wilmer, being duly sworn, does state the following is true
and correct to the best of his knowledge and belief:

1. I have been employed as a Special Agent with the Federal Bureau of
Investigation (FBI) since November 8, 2021.

2. As a Special Agent, my primary duties and responsibilities consist of
conducting investigations of individuals and businesses for possible violations of
federal laws. I am presently assigned to the FBI’s Minneapolis, Minnesota field office
where I am a member of the Civil Rights and Public Corruption Squad.

8, During my employment as a Special Agent, I have conducted and
participated in investigations of varying degrees involving mail fraud, wire fraud,
fraud against the government, money laundering, and other criminal acts, including
criminal schemes where individuals misappropriate money from the investing public.
Furthermore, in the course of my training and experience, I have become familiar
with the types of records businesses typically maintain in the course of their regular
activity, including ledgers, journals, invoices, receipts, and bank documents.

4, Based upon my work experience and training, as well as discussions
with law enforcement agents, I know that:

a. Businesses generally maintain or keep journals, ledgers, bank

statements and records, receipts, invoices and other documents evidencing the
receipts and disbursements of funds, inventories, assets of the business and
personnel information. These records are usually kept and maintained for extended
periods of time, often several years, at the place of business or residence. I know from
previous investigations that such records are also often maintained at the residence
of subjects.

b. Individuals, including those receiving income from fraud
schemes, often maintain within their residence records of assets and financial
transactions. These items often include financial statements, receipts, invoices, bank
statements and records, bank money order and cashier’s check receipts, property
records, investment records, assets, stock and bond records, tax records,
correspondence, diaries, and handwritten notes. These records are often maintained
for extended periods of time, often several years.

Cc. Due to the increasing prevalence of electronic communications
and storage, paper records can be converted and stored electronically. As a result,
any record or document could be found in either paper or electronic format.

d. Almost all wire transfers, even intrastate wire transfers, cross
state lines.

5. This affidavit is submitted in support of an application for warrants to
search:

a. The office located at 3055 Old Highway 8, Suites 312 and 229,
Saint Anthony, Minnesota 55418, as further described in Attachment A-1 (“Subject

Premises 1”);
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 Filed 02/19/24 Page 4of99

b. The single-family home located at 13299 Bronze Parkway,
Rosemount, Minnesota 55068, as further described in Attachment A-2 (“Subject
Premises 2”);

C. The office suite located at 1506 Southcross Drive West,
Burnsville, Minnesota 55306, as further described in Attachment A-3 (“Subject
Premises 3”);

d. The office located at 3249 Hennepin Avenue South, Unit 75,
Minneapolis, Minnesota 55408, as further described in Attachment A-4 (“Subject
Premises 4”); and

e. The single-family home located at 15101 County Road 5,
Burnsville, Minnesota 55306, as further described in Attachment A-5 (“Subject
Premises 5”);

f. The office located at 2854 Columbus Avenue South, Minneapolis,
Minnesota 55407, as further described in Attachment A-6 (“Subject Premises 6”)
(collectively, the “Subject Premises’);
for evidence, fruits, and instrumentalities of violations of Title 18, United States
Code, Section 1341 (mail fraud), 1343 (wire fraud), 1349 (conspiracy), and 1956/1957
(money laundering).

6. This affidavit is based on my personal knowledge, interviews of
witnesses, physical surveillance, information received from other law enforcement
agents, my experience and training, and the experience of other agents. Because this

affidavit is being submitted for the limited purpose of establishing probable cause in
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 Filed 02/19/24 Page5 of 99

support of a search warrant for the Subject Premises, I have not included each and
every fact known to me concerning this investigation. I have set forth only the facts
that I believe are necessary to establish probable cause to believe that evidence,
instrumentalities, and fruits of violations of Title 18, United States Code, Sections
1341, 1348, 1349, and 1956/1957 are located at the Subject Premises.

I. OVERVIEW

7. In recent years, individuals and companies in Minnesota have engaged
in a large-scale scheme to fraudulently obtain and misappropriate federally funded
child nutrition programs. The scheme was carried out by individuals who owned and
operated companies purportedly in the business of providing federally funded free
meals to underprivileged children and adults, including during the global Covid-19
pandemic. The companies and their owners received tens of millions of dollars in
federal funds for use in providing nutritious meals to underprivileged children and
adults. Almost none of this money was used to feed children. Instead, the participants
in the scheme misappropriated the money and used it to purchase real estate, cars,
and other luxury items. To date, the conspirators have stolen millions of dollars in
federal funds. The scheme is ongoing.

TI. LOCATIONS TO BE SEARCHED
A. Subject Premises 1

8. Subject Premises 1 is the office of Feeding Our Future located at 3055
Old Highway 8, Suites 229 and 312, Saint Anthony, Minnesota 55418.
9: During the investigation, the government obtained a federal search

warrant for the contents of an email account used by Aimee Bock to conduct: business
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 =~ Filed 02/19/24 Page 6 of 99

on behalf of Feeding Our Future. A review of these emails showed that Aimee Bock
sent and received hundreds of documents identifying Subject Premises 1 as the
office location of Feeding Our Future. These documents included correspondence with
the Minnesota Department of Education related to the company’s participation in
federal child nutrition programs.

10. U.S. Postal Service records show that Feeding Our Future regularly
receives mail at Subject Premises 1, including mail from the Minnesota
Department of Education and various banks. On or about January 13, 2022, an FBI
agent conducted surveillance at Subject Premises 1. The agent saw the mailboxes
located in the lobby of the building. The boxes for Suites 312 and 229 were both

labeled “Feeding Our Future.”

11. FBI surveillance agents have regularly observed a Volkswagen Atlas
SUV bearing Minnesota license DVN 744 parked outside of the Subject Premises 1,
including on January 12, 2022. Minnesota Department of Motor Vehicles records
show that this car is registered to Aimee Bock.

12. The door to Suite 312 has signs indicating that the suite is used by

Feeding Our Future.
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 Filed 02/19/24 Page 7 of 99

B. Subject Premises 2

13. Subject Premises 2 is the single-family home located at 13299 Bronze
Parkway, Rosemount, Minnesota 55068. Subject Premises 2 is the residence of
Aimee Bock, the President of Feeding Our Future. It is also a mailing address used
by Feeding Our Future.

14. Dakota County property records show that Aimee Bock owns Subject
Premises 2.

15. According to Minnesota Department of Motor Vehicles, Aimee Bock lives
at Subject Premises 2.

16. FBI surveillance agents have regularly observed the Volkswagen Atlas
SUV registered to Aimee Bock parked in the driveway of Subject Premises 2,
including on January 13, 2022,

17. According to Minnesota Secretary of State records, Feeding Our Future
was incorporated in November 2016. Aimee Marie Bock is listed as the President of
the company. Subject Premises 2 is listed as Feeding Our Future’s address with
the Minnesota Secretary of State.

18. Aimee Bock has a number of bank accounts, including an account at US
Bank. As explained below, Aimee Bock deposited into this account a $310,000
kickback payment from a company that was misappropriating federal child nutrition
program funds. Subject Premises 2 is listed as the address on Aimee Bock’s bank
accounts.

19. Subject Premises 2 is also a mailing address used by Handy Helper’s

[sic] LLC, a company created by Aimee Bock’s partner Empress Malcolm Watson Jr.
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~Filed 02/19/24 Page 8 of 99

As explained below, the company was used to misappropriated approximately
$600,000 in federal child nutrition program funds from Feeding Our Future.

20. U.S. Postal Service records show that Aimee Bock, Empress Watson,
and Handy Helper’s LLC have all received mail at Subject Premises 2 since
December 2021.

C. Subject Premises 3

21. Subject Premises 3 is office suite located at 1506 Southcross Drive
West, Burnsville, Minnesota 55306. Subject Premises 3 is a site location at which
Feeding Our Future purports to serve meals as part of the federal child nutrition
program.

22. Minnesota Department of Education records show that Feeding Our
Future submitted applications and reimbursement claims stating that the company

was serving meals at Subject Premises 3.

Sponsoring Authority Information;
Sponsor 2000010264 - Feeding Our Fulure

Site Information:
Site 9000018726 - Southcross

@ Approve -
Site Application Status Denctiaation

Date
Deactivate (mmiddiyyyy)

Approval effective date Oct 2021 - Sep 2022
range
Site Address 1506 Southcross Dr W, Burnsville, MN 55306; Dakota County
Site Program Name Southcross
Program Year 2021-2022 Stop Payment (_)
Contact Information:
Contact Contact
First Aimee Last Bock
Name Name
Contact : : Phone
‘He Founder/Executive Director Number ©'23454922 ——- Ext
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~=Filed 02/19/24 Page 9 of 99

23. Minnesota Department of Education records show that Feeding Our
Future claimed to be serving tens of thousands a meals a month to children at
Subject Premises 3. For example, Feeding Our Future claimed to have served more
than 50,000 meals at Subject Premises 3 in November 2021.

24. AnFBI agent conducted surveillance at Subject Premises 3 on several
occasions in December 20201. There were signs posted on windows near the entrance
indicating that Feeding Our Future was offering free meals.

D. Subject Premises 4

25. Subject Premises 4 is the office suite located at 3249 Hennepin
Avenue South, Unit 75, Minneapolis, Minnesota 55408. Subject Premises 4 is the
office of Abdikerm Abdelahi Eidleh and various entities controlled by Abdikerm
Abdelahi Hidleh. As explained below, these entities have been used to fraudulently
misappropriate federal child nutrition program funds and to solicit and receive
kickbacks from entities participating in the federal child nutrition program.

26. Minnesota Secretary of State records show that Abdikerm Abdelahi
Bidleh controls several companies that are registered at Subject Premises 4,
including Hope Suppliers LLC, Bridge Logistics LLC, Eidleh Inc., and Charm Home
Care LLC.

27. As explained below, Abdikerm Abdelahi Eidleh opened more than 20
bank accounts in the name of his various corporate entities. Subject Premises 4 is

listed as the address on most or all of the accounts.
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 10 of 99

28. U.S. Postal Service records show that Abdikerm Abdelahi Eidleh, Hope
Suppliers LLC, Bridge Logistics LLC, and Charm Home Care LLC have all received
mail at Subject Premises 4 in December 2021 or January 2022.

29. The building directory at 3249 Hennepin Avenue South indicates that
Eidleh Inc. and Charm Home Care LLC are both located in Unit 75.

E. Subject Premises 5

30. Subject Premises 5 is the single-family home located at 15101 County
Road 5, Burnsville, Minnesota 55306. Subject Premises 5 is the residence of
Abdikerm Abdelahi Eidleh, an employee of Feeding Our Future.

31. Dakota County property records shows that Abdikerm Abdelahi Eidleh
owns Subject Premises 5. U.S. Postal Service records show that Abdikerm Abdelahi
Eidleh currently receives mail at Subject Premises 5.

32. As explained below, Abdikerm Abdelahi Eidleh misappropriated federal
funds from Feeding Our Future and also solicited and received kickbacks from sites
participating in the federal child nutrition program. Abdikerm Abdelahi Eidleh then
used this money to pay personal expenses, Abdikerm Abdelahi Kidleh opened more
than 30 bank accounts in the name of his various corporate entities and then used
the accounts to receive and launder the proceeds of his scheme. Subject Premises 5
is listed as the address on many of these accounts, including accounts held in the
name of Bidleh Inc. and Bridge Logistics LLC.

33. In or about November 2020, Abdikerm Abdelahi Eidleh took out a loan
for approximately $294,000 for use in purchasing Subject Premises 5. Bank records

show that Abdikerm Abdelahi Eidleh later used approximately $212,000 in
fraudulently misappropriated federal child nutrition program to make payments on
that loan. The loan documents all list Subject Premises 5 as Abdikerm Abdelahi
Kidleh’s address.

F. Subject Premises 6

34. Subject Premises 6 is a building located at 2854 Columbus Avenue
South, Minneapolis, Minnesota 55407. Subject Premises 6 is the location of another
site at which Feeding Our Future claimed to be serving federally funded meals to
children. Feeding Our Future referred to this site as “Feeding Our Future Taylor”
(the “Taylor Site”).

35. Minnesota Department of Education records show that Feeding Our
Future submitted an application for the Taylor Site’s participation in the Federal
Child Nutrition Program in or about January or February 2021. The application
stated that the Taylor Site was located at Subject Premises 6.

36. The application indicated that Feeding Our Future would be serving
approximately 2,000 children a day. Aimee Bock was listed as the contact person for
Feeding Our Future. The contract stated that a company called Metro Area Catering
would be the vendor providing the meals for the Taylor Site,

37. Onor about January 4, 2022, an IRS agent conducted surveillance at
Subject Premises 6. The IRS agent observed a sign indicating that I-Care Home
Health Care was located at Subject Premises 6. According to Minnesota Secretary
of State records, I-Care Home Health Care LLC is a Minnesota limited liability
company located at Subject Premises 6. Mohamoud Warsame is identified as the

manager and registered agent for I-Care Home Health Care LLC.

10
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 12 of 99

38. As described below, Mahamoud Warsame also controls Metro Area
Catering, the vendor company that purported to be providing the meals to be served
at the Taylor Site/Subject Premises 6.

Iii, BACKGROUND

A. The Federal Child Nutrition Programs

39. This warrant relates to an ongoing investigation into a scheme to
defraud United States Department of Agriculture (USDA) programs that provide
federal funding to nutrition programs for children and low-income individuals across
the nation. The USDA operates two such programs—the Summer Food Service
Program and the Child and Adult Care Food Program.

40. The Summer Food Service Program (SFSP) is a federal program
designed to ensure that low-income children continue to receive nutritious meals
when school is not in session.

41. The Child and Adult Care Food Program (CACFP) is a federal program
that provides reimbursements for nutritious meals and snacks to eligible children
and adults who are enrolled for care at participating child care centers, day care
homes, and adult day care centers. CACFP also provides reimbursements for meals
served to children participating in afterschool care programs or residing in emergency
shelters and adults over the age of 60 or living with a disability and enrolled in day
care facilities.

42, The Summer Food Service Program and Child and Adult Care Food
Program (together, the “Federal Child Nutrition Programs”) operate throughout the

United States. The USDA’s Food and Nutrition Service administers the programs at

ll
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ‘Filed 02/19/24 Page 13 of 99

the national and regional levels by disbursing federal funds to state governments,
which provide oversight over the Federal Child Nutrition Programs.

43. Within each state, the Federal Child Nutrition Programs are
administered by the state department of education or an alternate state-designated
agency. In Minnesota, the programs are administered by the Minnesota Department
of Education (MDE).

44. Locally, meals funded by the Federal Child Nutrition Program are
served at sites such as schools or daycare centers (“Sites”). Each Site must be
sponsored by a public or private non-profit organization that is authorized to
participate in the Federal Child Nutrition Programs (“Sponsors”). Sponsors seeking
to participate in the Federal Child Nutrition Programs are required to submit an
application to the MDE for approval for each site from which they intend to operate
Federal Child Nutrition Programs. Sponsors are responsible for monitoring each of
their sites and preparing reimbursement claims for their sites.

45. Federal Child Nutrition Program funds are supposed to be used to
provide nutritious meals and food to children and low-income individuals. See 7
C.F.R. § 225.15(a)(4) (“All Program reimbursement funds must be used solely for the
conduct of the nonprofit food service operation.”).

46. Historically, the Federal Child Nutrition Program has generally
functioned through the provision of meals to children involved in educational-based
programs or activities. During the Covid-19 pandemic, however, the USDA waived

some of the standard requirements for participation in the Federal Child Nutrition

12
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 14 of 99

Program. Among other things, USDA allowed for-profit restaurants to participate in
the program, It also allowed for off-site food distribution to children outside of
educational programs. At the same time, the state government’s stay-at-home order
and telework policies interfered with its ability to oversee the program. According to
MDE officials, this left the program vulnerable to fraud and abuse.

B. Feeding Our Future

47. This warrant is an investigation into the widespread diversion and
misuse of Federal Child Nutrition Program funds during the Covid-19 pandemic.
Much of this fraud was committed by sites operated under the sponsorship of Feeding
Our Future, a non-profit organization purportedly in the business of helping
community partners participate in the Federal Child Nutrition Program and related
federal programs. Feeding Our Future sponsors and helps administer sites that
participate in the Federal Child Nutrition Program. According to its website, Feeding
Our Future “utilize[s] the Child and Adult Care Food Program to increase healthy
food access for Minnesota’s youth and seniors.” The website lists Aimee Bock as the
founder and executive director of Feeding Our Future.

48. Records obtained from MDE show that after being formed in 2017,
Feeding Our Future quickly began receiving and distributing millions of dollars in
Federal Child Nutrition Program Funds. The company went from receiving $3.4

million in 2019 to more than $197 million in 2021.

13
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 =‘ Filed 02/19/24 Page 15 of 99

Year Approximate amount of
Federal Child Nutrition
Program funds to
Feeding Our Future

2018 $307,253
2019 $3,487,168
2020 $42,681,790
2021 $197,932,695
Total $244,408,906

49. Feeding Our Future entered into contracts with the sites it sponsored,
Under these contracts, Feeding Our Future deducted 10 percent of all Federal Child
Nutrition Program reimbursements received by the sites under its sponsorship as its

“administrative fee.”

14. Receive payments of CACFP reimbursements from FEEDING OUR FUTURE, after deduction af
administrative fee of 10 percent, within five working days of FEEDING OUR FUTURE’s receipt of
program reimbursement funds from MDE

50. This provided an incentive for Feeding Our Future, and its Executive
Director Aimee Bock, to increase the number of sites under its sponsorship as well as
the amount of Federal Child Nutrition Program reimbursements each site was
receiving.

51. MDE became concerned about the massive increase in Federal Child
Nutrition Program funds going to sites sponsored by Feeding Our Future as well as
the large increase in the number of sites under Feeding Our Future sponsorship.
According to MDE employees, MDE began more carefully scrutinizing new site
applications submitted by Feeding Our Future. Feeding Our Future later sued MDE,

alleging that it unlawfully denied its site applications and withheld reimbursements

14
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 16 of 99

to which Feeding Our Future and sites under its sponsorship were entitled. This
lawsuit is currently pending in Ramsey County District Court.

52. At various times during this litigation, the presiding judge has
concluded that MDE wrongfully withheld funds and violated federal regulations in
its attempts to oversee Feeding Our Future and sites under its sponsorship.

53. In April 2021, MDE provided information to the FBI alleging that
Feeding Our Future and sites under its sponsorship were diverting funds away from
the nutrition program. MDE believed certain sites were submitting fraudulent
documents to support reimbursement of funds in addition to artificially inflating the
number of children and low-income individuals receiving benefits in order to obtain
funds. But MDE did not have access to the participating companies’ bank records so
was unable to conclusively determine whether they were misappropriating Federal
Child Nutrition Program funds.

54. In May 2021, the FBI began investigating the allegations surrounding
the misuse of federal funds intended for feeding children and low-income individuals.
As part of this investigation, the FBI obtained records of hundreds of bank accounts
that received, either directly or indirectly, Federal Child Nutrition Program funds. A
review of these financial records showed a massive fraud scheme involving the misuse
and theft of tens of millions of dollars in Federal Child Nutrition Program funds.

C. Feeding Our Future-Sponsored Sites Fraudulently

Misappropriated Millions of Dollars in Federal Child Nutrition
Program Funds

55. Safari Restaurant and Event Center is one of the sites receiving Federal

Child Nutrition Program money under the sponsorship of Feeding Our Future. A

15
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page17 of 99

group of individuals who own or are associated with Safari Restaurant have
participated in a fraudulent scheme to obtain and misappropriate millions of dollars
in Federal Child Nutrition Program funds. Beginning in 2020, these individuals have
created several companies for use in carrying out these schemes. They enrolled their
companies in the Federal Child Nutrition Program under the sponsorship of Feeding
Our Future. They then claimed to be feeding meals to thousands of children a day,
for which they were reimbursed more than $10 million. But bank records show they
misappropriated most of this money and used it to purchases real estate, cars, and
other luxury items.

56. Safari Restaurant applied to participate in the Federal Child Nutrition
Program under the sponsorship of Feeding Our Future in April 2020. Salim Said
signed the application on behalf of Safari Restaurant and Aimee Bock signed on
behalf of Feeding Our Future.

57. Onor about April 24, 2020, MDE informed Bock that it was denying the
application. In an email to Bock, an MDE employee explained that “[b]ased on
guidance from USDA, we aren’t creating any new CACFP At-Risk site [Ds for
locations not currently providing care.”

58. Bock and Feeding Our Future objected to the denial of the application.
On or about April 24, 2020, Bock claimed that “[t]hese sites are already providing
meals to the states youth with the expectation of the meals being reimbursed” and
asked what “authority . .. allows you to deny site applications to sites that are clearly

eligible.”

16
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 18 of 99

59. Bock and Feeding Our Future subsequently submitted a formal
complaint to MDE about the denial of Safari Restaurant's application. In an email
sent on April 28, 2020, an attorney representing Feeding Our Future told MDE he
was going to be filing a formal complaint about the denial of the application. He
explained that the sites, including Safari Restaurant, were “all minority owned
businesses serving almost exclusively economically disadvantaged children of color.”
In an apparent reference to the Covid-19 pandemic, he cited “the extraordinary times
we are in now” and said it was “critical that we get a speedy decision from MDE on
this” because “[t]hese children, families, and businesses desperately need the federal
help they are entitled to.”

60. Later that day, Bock sent a follow-up email to an MDE employee. Bock
said she “was extremely disappointed that MDE would deny these sites the
opportunity to feed youth culturally relevant foods during this national emergency. It
was even more shocking considering the great work these sites do.”

61. Two days later, on or about April 30, 2020, MDE approved Safari
Restaurant’s application and authorized its participation in the Federal Child
Nutrition Program.

D. Safari Restaurant Almost Immediately Claimed it was Entitled

to Hundreds of Thousands of Dollars in Federal Child Nutrition
Program Funds

62. ByJuly 2020, Safari Restaurant claimed that it was serving or providing
meals to 5,000 children a day. That month, MDE conducted an administrative review

and audit of Safari Restaurant’s participation in the Summer Food Service Program

17
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 20 of 99

received approximately $702,000 in Federal Child Nutrition Program funds in

August 2020.
E. Individuals Involved in Safari Restaurant Applied to Open

Additional Sites in Fall 2020 Under the Sponsorship of Feeding
Our Future

66. In the fall of 2020, individuals associated with Safari Restaurant
enrolled additional sites in the Federal Child Nutrition Program under the
sponsorship of Feeding Our Future. These sites were run by new companies created
for use in participating in the Federal Child Nutrition Program, including ASA
Limited LLC and Olive Management Inc. These sites quickly began reporting that
they were serving meals to large numbers of children on a daily basis.

i, ASA Limited LLC

67. According to Minnesota Secretary of State records, Abdihakim Ali
Ahmed created ASA Limited LLC on or about September 4, 2020. That same day,
ASA Limited LLC completed an application to enroll in the Federal Child Nutrition
Program under the sponsorship of Feeding Our Future. The application and
accompanying “New Site Intake” form stated that ASA Limited LLC would be serving
both breakfast and lunch to 3,000 children on Saturday and Sundays. Abdihakim
Ahmed signed the application on behalf of ASA Limited LLC. Aimee Bock signed the
application on behalf of Feeding Our Future. In correspondence with MDE, Bock
explained that ASA Limited would be “serving youth living in St, Paul” and “in an
area that does not have other culturally appropriate food sites.”

68. ASA Limited immediately began claiming that it was entitled to large

amounts of Federal Child Nutrition Program funds. For example, ASA Limited

19
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 21 of 99

claimed that it was entitled to more than $700,000 in Federal Child Nutrition
Program funds for meals served in September and October 2020.

69. Inall, MDE records show that ASA Limited has received more than $5.3
million in Federal Child Nutrition Program funds since its creation in September
2020.

2. Olive Management

70. Minnesota Secretary of State records show that Olive Management was
created by Ahmed Omar-Hashim in September 2020. That same month, the company
submitted an application to participate in the Federal Child Nutrition Program under
the sponsorship of Feeding Our Future. The application stated that Olive
Management would be serving both breakfast and lunch, totaling 2,500 meals a day.
Ahmed Omar-Hashim signed the application on behalf of Olive Management and
Aimee Bock signed on behalf of Feeding Our Future. The application included an
agreement between Feeding Our Future and Olive Management authorizing Feeding
Our Future to charge administration fees “not to exceed 10 percent” of the Federal
Child Nutrition Program reimbursements received by Olive Management.

71. Olive Management immediately began claiming that it was entitled to
large amounts of Federal Child Nutrition Program funds. For example, the company
claimed that it was entitled to more than $1.2 million in Federal Child Nutrition
Program funds for meals served from September to November 2020.

72. In all, MDE records show that Olive Management has received more
than $5.2 million in Federal Child Nutrition Program funds since its creation in

September 2020.

20
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 22 of 99

F. Feeding Our Future Filed a Lawsuit After MDE Terminated
Safari Restaurant from the Federal Child Nutrition Program

73. In the fall of 2020, MDE raised concerns about the number of new sites
being sponsored by Feeding Our Future. MDE also questioned the size of the
reimbursements being claimed by these sites. For example, in a September 2020
letter to Feeding Our Future, an MDE employee noted that Safari Restaurant “is
projected to serve a comparable number of meals” to “the entire St. Paul Public School
District.” MDE asked Feeding Our Future to “[p]lease explain how Safari Restaurant
has this capacity to serve this number of meals, the need for these meals, and how
the site is promoted.”

74. In October 2020, MDE terminated Safari Restaurant’s participation in
the Federal Child Nutrition Program effective October 31, 2020. During this same
time frame, MDE utilized a multi-step review process for approving new sites to
ensure that Federal Child Nutrition Program funds were being used properly.

75. In November 2020, Feeding Our Future sued MDE for failing to process
its site applications. In the complaint, Feeding Our Future claimed that MDE was
unlawfully refusing to approve their site applications and unlawfully withholding
payments of Federal Child Nutrition Programs funds to sites under Feeding Our
Future’s sponsorship. Feeding Our Future alleged that, as a result, “[t]housands of
qualified children in low-income and minority communities are going without
desperately needed federal food programs because MDE refuses to process Feeding
Our Future’s applications.” Feeding Our Future further alleged that MDE had

violated the Minnesota Human Rights Act by “discriminating” against Feeding Our

21
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ‘Filed 02/19/24 Page 23 of 99

Future due to its “cater[ing] to members of a protected class of racial minorities and
foreign nationals.”

76. As this litigation has proceeded, Safari Restaurant and related entities
have continued to receive millions of dollars from the Federal Child Nutrition
Program. As explained below, a review of bank records shows that this money was
not used to feed children. Instead, the bulk of the money was stolen and used to,
among other things, purchase expensive cars and real estate.

G. Feeding Our Future and Safari Restaurant Provided Fake
Documentation to MDE

77. InJanuary 2021, MDE conducted an audit of Feeding Our Future. This
audit was triggered, in part, by suspicions about the large amount of Federal Child
Nutrition Program money being received by Feeding Our Future and sites under its
sponsorship. In responding to that audit, Feeding Our Future provided claim detail
reports and summer meal counts that purport to document the meals served by Safari
Restaurant in March 2021.

78, Feeding Our Future also submitted weekly meal count forms for certain
days in March 2021 as part of its response to MDF ’s audit. These weekly meal count
forms stated that Safari Restaurant prepared both breakfast and lunch for 6,000
children a day, seven days a week, in March 2021. The meal count forms indicate that
for each of these days, Safari Restaurant actually served between 5,991 and 5,999

children.

22
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 =‘ Filed 02/19/24 Page 27 of 99

from related corporate entities). The account did not show any significant deposits
from the operation of the restaurant or event center.

86. Bank records show that almost none of the Federal Child Nutrition
Program funds deposited into this account were used to purchase food to prepare and
feed to children. Instead, the majority of the money deposited into the account was
transferred to limited liability companies owned or controlled by owners of Safari
Restaurant. In all, bank records show that approximately $5.3 million was

transferred to LLCs controlled by owners or associates of Safari Restaurant.

Entity Entity owner/account | Amount Transferred

Bank Account(s) holder (approximate)

3017 LLC Abdulkadiy Nur Salah $1.9 million

Salim Limited LLC Salim Said $1.4 million

Afra Grill LLC Abdirahman Ahmed $1.35 million
Sagal Aden

AG Limited LLC Ahmed Ghedi $694,000
Total $5.3 million

87. Safari Restaurant also has accounts at Bell Bank. Abdulkadir Nur Salah

is the signatory on the accounts. Approximately $6.5 million was deposited into the
account between approximately July 15 and November 30, 2021. More than $6.2
million (or 92 percent) were Federal Child Nutrition Program funds received from
Feeding Our Future.

88. Again, bank records show that almost none of this money was used to
purchase food. Instead, a large portion of this money was transferred to limited

liability companies owned or controlled by owners of associates of Safari Restaurant.

26
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1

Filed 02/19/24

Page 28 of 99

In all, bank records show that approximately $1.1 million was transferred to

companies owned or controlled by the owners of Safari Restaurant.

Entity Entity owner/account | Amount
holder Transferred
(approximate)
ASA Limited LLC | Abdihakim Ahmed $859,000
Salim Said
Ahmed Ghedi
3017 LLC Abdulkadir Nur Salah $138,000
Salim Limited LLC | Salim Said $35,000
1130 Holdings Inc. | Abdihakim Ahmed $82,000
Total $1,114,000

89. Another $1,909,100 was transferred to bank accounts held by two other

entities—Tunyar Trading LLC and Horseed Management LLC.

Entity Entity owner/account | Amount Received from
holder Safari Restaurant
(approximate)
Tunyar Trading LLC Abdikadir Mohamud $956,400
Horseed Management LLC | Abdinasir Abshir $952,700
Total $1,909,100

90. Both Tunyar Trading LLC and Horseed Management LLC were set up

in September-October 2020. According to Minnesota Secretary of State records,

Tunyar Trading LLC was formed on or about September 28, 2020, and Horseed

Management LLC was formed on October 9, 2020. Both Tunyar Trading and Horseed

Management had vendor contracts to provide food or meals to sites sponsored by

Feeding Our Future. According to these contracts, Feeding Our Future would pay the

companies $2.13 per breakfast and $3.67 per lunch.

27
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 29 of 99

91. Both companies opened bank accounts into which millions of dollars in
fraudulently obtained Federal Child Nutrition Program funds flowed. But bank
records show that these companies did not use these funds to buy food or prepare
meals. Instead, the companies appear to function essentially as shell companies
designed to help launder misappropriated and fraudulently obtained Federal Child
Nutrition Program funds.

92. Tunyar Trading had accounts at US Bank, JP Morgan Chase, and
TruStone Financial Credit Union. More than $4 million was deposited into these
accounts in 2021, Almost all of this money came from Safari Restaurant or other
entities whose owners appear to be fraudulently obtaining Federal Child Nutrition

Program funds, including Safari Restaurant and Stigma-Free International Inc.

Entity Owner Amount Transferred
to Tunyar Trading
LLC in 2021
(approximate)
Stigma-Free International | Ahmed Artan $3,154,216
Inc.
Cosmopolitan Business Salim Said $594,859
Solutions dba Safari Ahmed Ghedi
Restaurant Abdihakim Ahmed
Abdulkadir Nur Salah
Salim Limited LLC Salim Said $65,000
Horseed Management LLC | Abdinasir Abshir $56,701
AG Limited LLC Ahmed Ghedi $30,000
Total $3,900,776

93. Stigma-Free International Inc. is another company that appears to be
fraudulently receiving Federal Child Nutrition Program funds under the sponsorship
of Feeding Our Future. Records obtained from U.S. Bank and Bank of America show

that Stigma-Free International Inc. received more than $6.5 million from Feeding

28
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 30 of 99

Our Future since January 2021. Bank records show that none of this money was used
to purchase food or meals for underprivileged children, Instead, the bulk of the money
was transferred to entities controlled by individuals associated with Safari
Restaurant.

94, Although bank records show that Stigma-Free did not use the Federal
Child Nutrition Program funds to purchase food or prepare meals, the company
claimed to be serving meals to thousands of children a day. For example, in
September 2021, the owner of Stigma Free, Abdikadir Mohamud, sent an email to
Aimee Bock with the subject line “Willmar Meal Count/Invoice for September.”
Attached to the email were “Summer Meal Counts” claiming that Stigma Free served

2,000 meals a day, seven days a week during August 2021 in Willmar, Minnesota.

29
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 32 of 99

98. At first glance, this money appears as though it could have been used to
purchase food or meals to serve to children as part of the Federal Child Nutrition
Program. But a review of these accounts show that was not the case. Instead, this
money passed through these accounts and was quickly transferred to accounts held
by owners of associates of Safari Restaurant. These accounts appear to be in the name
of shell companies used to launder misappropriated and fraudulently obtained
Federal Child Nutrition Program funds.

99. Safari Restaurant also had accounts at Associated Bank. In total,
approximately $3.3 million was deposited into the account. between May 15 and
October 29, 2020. Of this, approximately $2.6 million was Federal Child Nutrition
Program funds received from Feeding Our Future (the bulk of the remaining money
came from an intercompany transfer for $637,000). The account showed no significant
yevenue from the operation of Safari Restaurant outside of the Federal Child
Nutrition Program.

100. Again, a review of the company’s bank records shows that little of this
money was used to purchase food to serve to underprivileged children. Instead, more
than $1.5 million was transferred to owners of Safari Restaurant directly or via

entities they controlled.?

Entity Entity owner/account | Amount Transferred
holder (approximate)
3017 LLC Abdulkadir Nur Salah $562,000
Salim Limited LLC | Salim Said $520,000
2 Some of this money was first transferred to a second Safari Restaurant account at

Associated Bank before being ultimate distributed to the Safari Restaurant owners or
associates, or their entities.

31
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 33 of 99

Abdirahman Ahmed | N/A $304,000
Afra Grill LLC Abdirahman Ahmed $220,000
Sagal Aden
Total $1,606,000

101. During the investigation, the government subpoenaed records related to
the accounts into which these funds were deposited. They, too, show that little of the
money was used to buy food. Instead, bank records show that the owners of Safari
Restaurant transferred most of the money to and from numerous bank accounts held
in the name of an array of entities they controlled. Based on my training and
experience, and conversations with FBI forensic accountants, this activity appears to
have been designed to launder the money fraudulently obtained from the Federal
Child Nutrition Program. The banks appear have taken the same view, as several of
these accounts were closed by the banks for violating anti-money laundering policies.

102, Along the way, the owners of Safari Restaurant misappropriated the
money and used much of it to purchase real estate, cars, and other luxury items.

103. For example, approximately $1.9 million was transferred from the
Safari Restaurant accounts to accounts held by Salim Limited, LLC, a limited
liability company created by Salim Said in July 2020. Minnesota Secretary of State
records list Safari Restaurant as the company’s registered office address.

104. Bank records show that Salim Said did not use this money to purchase

food to serve to underprivileged children. Instead, he used it to fund his own lifestyle.

32
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 34 of 99

A, Salim Said used Federal Child Nutrition Program funds to
purchase a Pickup Truck for $87,000 in February 2021

105. Bank records show that Salim Said also used Federal Child Nutrition
Program funds to purchase a 2021 Chevrolet Silverado 3500 pickup truck for $87,000.

106. On or about January 19, 2021, Feeding Our Future sent approximately
$549,950 in Federal Child Nutrition Program funds to a Wells Fargo account in the
name of Olive Management Inc.

107. Approximately three days later, on or about January 22, 2021, Ahmed
Omar-Hashim, wrote a $70,000 check from the Olive Management Wells Fargo
account to Salim Limited LLC, a company controlled by Salim Said.

108. This check was deposited into an account held by another Said-
controlled company, Salim Limited LLC, at Bridgewater Bank. Salim Said was the
signatory on the account.

109. Onor about February 24, 2021, Said obtained a $47,000 cashier’s check
payable to Lupient Chevrolet from the Salim Limited LLC account at Bridgewater
Bank. At the time, the account had a balance of approximately $1,045,310, all of

which was derived from Federal Child Nutrition Program funds.

041915
Februaey 24, 2021
PURCHASER SALIM A SAID
Tether & 2

33
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ‘Filed 02/19/24 Page 35 of 99

110. Said used this check to purchase a 2021 Chevrolet Silverado 3500 pickup
truck with the VIN number 1GC4YUEY4MF160143 and Minnesota license plate
YNF8701. The sales contract lists Said as the buyer of the truck. The purchase price

was approximately $87,201.

B. Salim Said used $950,000 in Federal Child Nutrition Program
Funds to Purchase a House in Plymouth, Minnesota in July 2021

111. A review of bank records shows that in July 2021 one the Safari
Restaurant owners, Salim Said, purchased the single-family home located at 5150
Alvarado Lane in Plymouth, Minnesota using more than $950,000 in Federal Child
Nutrition Program funds.

112. Bank records show that Said purchased the house using Federal Child
Nutrition Program funds. These funds were originally received from Feeding Our
Future and deposited into accounts held by three companies owned or controlled by
Said or other associates of the Safari Restaurant group—Stigma Free International,
ASA Limited LLC, and Cosmopolitan Business Solutions d/b/a Safari Restaurant.
Ultimately, funds from these accounts went into Salim Limited LLC’s account at

Wells Fargo Bank.
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~~‘ Filed 02/19/24 Page 37 of 99

to an online realty website, 5150 Alvarado Lane is a 5-bedroom, 5-bathroom, 5,962-

square foot house with an indoor basketball court.

C, Salim Said and Abdulkadir Nur Salah Used $2.8 Million in
Federal Child Nutrition Program Funds to Purchase an Office
Building in August 2021

115. A review of bank records show that the Salim A. Said, Abdulkadir Nur
Salah, and Ahmed Omar-Hashim used $2.8 million in federal child nutrition program
funds to purchase a commercial office building located at 2722 and 2742 Park Avenue
South, Minneapolis, Minnesota (the “Park Avenue Property”).

116. The money used to purchase the Park Avenue Property was the proceeds
of fraudulently received/misappropriated Federal Child Nutrition Program funds.
These funds came from Feeding Our Future and were deposited into bank accounts

held by several companies owned and controlled by owners or associates of Safari

Restaurant:
Entity Entity Amount Received | Date Range
(Bank Account) Owner/Account | into Account from
Holder Feeding Our
Future
(Approximate)
Cosmopolitan Abdulkadir Nur _ | $5,533,739 2/19/2021 to
Business Solutions Salah 5/14/2021
d/b/a Safari
Restaurant Salim A, Said
ASA Limited LLC Abdihakim A. | $2,211,460 2/16/2021 to
Ahmed 5/20/2021
Salim A, Said
Stigma Free Ahmed M. Artan | $779,666 1/15/2021 to
International Inc. 1/25/2021
Olive Management | Ahmed S. | $1,124,485 5/20/2021
Inc. Hashim

36
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~~‘ Filed 02/19/24 Page 38 of 99

117. This money was intended for use in providing nutritious meals to
underprivileged children. But that did not happen. Instead, the owners of the entities
then sent the Federal Child Nutrition Program funds through one or more bank
accounts held in the name of entities they controlled. As explained above, these
entities were nothing more than shell companies with bank accounts used to launder

money and disguise the source of the funds.

—— DING OUR FUTUR

Tunyar Trading
$239,000
ASA Limited LLC Olive Management, Inc.
4s80,.000 510,000 Girecdy to title company
$979,000 $480,000
3017, LLC
san Salim Limited LLC
AG Limited LLC —_

Salim Limited LLC
$890,000

|

Cosmopolitan Business Properties, LLC

2722 Park Ave South

118. After being laundered through various other bank accounts, a total of

$2,750,000 was deposited into an account in the name of Cosmopolitan Business

o7
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 39 of 99

Properties LLC at Bridgewater Bank. All of this money was deposited into the
account on July 2, 2021. The money was transferred from bank accounts held by four

entities owned or controlled by owners or associates of Safari Restaurant.

Entity Entity Amount Deposited Date of
Owner/Account | into the Cosmopolitan | Deposit
Holder Business Properties
LLC account
Salim Limited LLC | Salim Said $890,000 | July 2, 2021
3017 LLC Abdulkadir Nur $840,000 | July 2, 2021
Salah
AG Limited LLC Ahmed Ghedi $560,000 | July 2, 2021
Olive Management | Ahmed Omar- $460,000 | July 2, 2021
Inc. Hashim
Total $2,750,000

119. The Cosmopolitan Business Properties bank account was created and
used solely for this transaction. On or about July 15, 2021, less than two weeks after
these funds had been transferred into the account, Cosmopolitan Business Properties
LLC used the money to purchase the Park Avenue Property for $2,780,000. 2722 Park
Avenue is one of the large historic mansions on Park Avenue in south Minneapolis.

The property has been converted into office space.

38
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 40 of 99

120. Bank records show that $2,735,000 was transferred from the
Cosmopolitan Business Properties LLC account at Bridgewater Bank to First
American Title Insurance Company on July 15, 2021. The memo line indicated that
the money was being used for the purchase of the Park Avenue Property. Title
company records show that Cosmopolitan Business Properties LLC had previously
made a $50,000 payment towards the purchase of the Park Avenue Property on June
24, 2021,

121. Records obtained from First American Title Company show that the
buyer of the Park Avenue Property was Cosmopolitan Business Properties LLC, an
entity created in June 2021.

D. Aimee Bock Received a $310,000 Kickback from Safari
Restaurant

122. The investigation revealed evidence that one of the owners of Safari
Restaurant, Abdulkadix Nur Salah, appears to have paid a $310,000 kickback to
Aimee Bock.

123. Bank records show that Abdulkadir Nur Salah obtained a $310,000
cashier’s check from a Safari Restaurant account on or about August 13, 2021. This
check was made out to Aimee Bock. Bank records show that the $310,000 was derived

directly from Federal Child Nutrition Program funds.

39
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘Filed 02/19/24 Page 41 of 99

REMITTE COSMOPOLITAN BUSINESS SOLUTIONS LLC DATE 68/13/2021

Ww

a PAYTO THE Aimee MARIE BOCK

ey as 5 BELLBANK ~ j
CASHIER'S CHECK.
i a \ 83
i! pa if Hi #

124. Aimee Bock deposited this $310,000 check into a personal account held
by her and ex-husband at US Bank on or about August 13, 2021. Bank records show
that this money was used on personal expenses. Within the next five days, this
account was used to make a $4,743 purchase at HOM Furniture and more than
$1,400 in purchases at the outlet mall in Eagan, Minnesota.

125. Bock also purchased two large cashier’s check: (1) a $70,000 cashier's
check made out to her ex-husband on or about August 28, 2021; and (2) a $15,095
cashier’s check made out to Walser, a local car dealership, on or about October 1,
2021.

126. As of October 18, 2021, the account had a balance of approximately

$209,000. The bulk of this money was from the kickback payment from Safari

Restaurant.

40
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘Filed 02/19/24 Page 42 of 99

Vie FEEDING OUR FUTURE RAN ITS OWN FRAUDULENT SITES

127. Feeding Our Future also had its own sites that participated in the
Federal Child Nutrition Program. As explained below, the investigation has revealed
that Feeding Our Future submitted fraudulent claims for reimbursements of Federal
Child Nutrition Program funds for meals purportedly served at nonexistent sites.

A. The Southcross Site

128. Feeding Our Future operated a site located at 1506 Southcross Drive
West in Burnsville, Minnesota 55306 (a/k/a Subject Premises 3 or the “Southcross
Site”). Feeding Our Future submitted a site application for the Southcross Site to
MDE in 2020.

129. Feeding Our Future reported to MDE that Empire Market and Cuisine
would be the vendor providing food for the site. Feeding Our Future entered into a
“Summer Food Service Program Contract for Vended Meals” with Empire Cuisine
and Market. The contract provided that Empire Cuisine and Market would be
reimbursed $2.34 for each breakfast provided and $4.01 for each lunch provided.
Aimee Bock signed the contract on behalf of Feeding Our Future. Abdiaziz S. Farah
signed on behalf of Empire Cuisine and Market.

130. The investigation has revealed that Empire Cuisine and Market did not
use the Federal Child Nutrition Program funds it received to purchase food or provide
meals. Instead, Abdiaziz S. Farah and the other owners of Empire Cuisine and
Market and related entities fraudulently misappropriated the reimbursements they

received and used much of the money to purchase real estate and cars. For example,

41
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 43 of 99

on or about July 31, 2021, Abdiaziz S. Farah used $29,000 in Federal Child Nutrition

Program funds received by Empire Cuisine & Market to buy a Porsche.

131. On January 11, 2021, Magistrate Judge Tony N. Leung signed four
federal search warrants authorizing the search of Empire Cuisine and Market and
related entities based on the companies’ involvement in the fraudulent
misappropriation of Federal Child Nutrition Program funds.

132. Feeding Our Future claimed to be serving tens of thousands of meals a
month to children at the Southcross Site. For example, MDE records show that
Feeding Our Future claimed to have served more than 50,000 meals at the Southcross
Site in November 2021.

133. On or about November 24, 2021, at approximately 4:00 p.m., an FBI
agent conducted surveillance at the Southcross Site. The agent saw no activity at the
site.

134. The agent has since returned to the Southcross Site on several occasion
in December 20201. There were signs posted on windows near the entrance indicating

that Feeding Our Future was offering free meals. However, the agent saw no activity

42
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 44 of 99

or evidence that meals were actually being served at the Southcross Site. Each time
the parking lot was empty.

135. MDE records show that Feeding Our Future received more than $2
million in Federal Child Nutrition Program reimbursements in 2020 and 2021.

B. The Taylor Site

136. Feeding Our Future also operated a site located at 2854 Columbus
Avenue South, Minneapolis, Minnesota 55407 (a/k/a Subject Premises 6). Feeding
Our Future referred to this site as “Feeding Our Future Taylor” (hereinafter, the
“Taylor Site”).

137. MDE records show that Feeding Our Future submitted an application
for the Taylor Site’s participation in the Federal Child Nutrition Program in or about
January or February 2021. The application indicated that Feeding Our Future would
be serving approximately 2,000 children a day. Aimee Bock was listed as the contact
person for Feeding Our Future. The contract stated that a company called Metro Area
Catering would be the vendor providing the meals for the Taylor Site.

138. In or about October 2021, an MDE employee sent an email to Aimee
Bock asking about the Taylor Site. The MDE employee noted that there appeared to
be two sites located at 2854 Columbus Avenue—Feeding Our Future Taylor and
another newly created site called “Southside Youth.” The MDE employee asked
Aimee Bock to “please double check.” Aimee Bock responded to the email on or about
October 4, 2021. Aimee Bock explained, “This is correct, we have verified that it is

different. youth being served at each of the locations in the building.”

A3
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 45 of 99

139. Southside Youth is another Federal Child Nutrition Program site under
the sponsorship of Feeding Our Future. MDE records show that Southside Youth
received approximately $501,598 in Federal Child Nutrition Program
reimbursements for September and October 2021. According to MDE records,
Feeding Our Future claimed that Southside Youth served more than 50,000 meals in
October 2021.

140. The location at which Aimee Bock claimed these two Feeding Our
Future-sponsored sites were serving meals—2854 Columbus Avenue South—is a

small, one-story building in south Minneapolis.

141. In November and December 2021, the FBI had a surveillance camera

outside of the 2854 Columbus Avenue South. A review of the video showed minimal
activity at the building. There was nothing suggesting that food was being prepared,
served, or delivered at the site. For example, there were no deliveries of food or lines

of children entering or leaving the building.

44
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24

Page 46 of 99

142. MDE record show that Feeding Our Future claimed to have served or

provided after-school snacks and suppers to 59,541 children

at 2854 Columbus

Avenue South in November 2021. Feeding Our Future reported that it served meals

all 31 days of November to an average of 1,921 children a day.

.
” weer Feeding Our Future
Create New View or Interface Claim
Claims Modify Claims | Claim File Summary
Claims > CACFP Claim Maintenance
os ed cl Child and Adult Care Food Program (CACFP) Claim Information
: Sponsor 2000010264 - Feeding Our Future
System Admint P iis
Site 9000019273 - Feeding Our Future Taylor
Program Admint
Calendar Year 2021 Month November
peeked | Clai inal Claim Statu: ed
Uixer information aim Type Orig aim Status Approv
Payment Reason for Adjustment:
Reports l iil
Verification Reporting Other (DescribeyName of Reviewer.
Direct Certification
Regular CACFP Meal Service Information
Number of
Average Number Number of Partici Number of For-Profit Center
Participants sere Participants Only - Claiming
Daily of Days Approved for
Attendance Served Approved for Reduced Price or Approvedfor Percentage for
Free or A Meals Paid or C Meals Eligibility"
B Meals
0 0 0 0 0 0
Total Reimbursable Meals Served
Breakfast Lunch Supper Morning Snack oo Evening Snack
0 0 0 0 0 0
At-Risk Afterschool Care Meal Service Information
Average Daily Number of Days At-Risk At-Risk At-Risk At-Risk
Attendance Served Afterschool Snack Breakfast Lunch Supper
1921 3 69541 0 0 59541

143. Based on these reported totals,

Feeding Our Future

received

approximately $292,941 in Federal Child Nutrition Program reimbursements for

meals purportedly served at 2854 Columbus Avenue South in November 2021.

45
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 47 of 99

DEPARTMENT C LiC S 2 Sponsor: 2000010264
OF EDUCATION :
Feeding Our Future
Payment > Payment Detail Search > View Payment Detail > View Detail
Applications General payment data:
Sponsor 2000010264 - Feeding Our Future
Payment Date 12/17/2021 Payment Number 2706
Site 9000019273 - Feeding Our Future Taylor Total Amount $292,941.72
Line Items included:
Claim Claim Rate Meals View claim
Month Year “eal Type Type inciDec «= Rt@ Amount oy ite
Direct Certification November 2021 verlag ae Free 59541 $1.00 $59,541.00 9000019273
Cash in
November 2021 Supper jos 59541 $0.26 $15,480.66 9000019273
November 2021 Supper, At Risk Free 59541 $3.66 $217,920.06 9000019273

144. On or about January 4, 2022, an IRS agent conducted surveillance at
2854 Columbus Avenue South. The IRS agent observed a sign indicating that I-Care

Home Health Care was located at 2854 Columbus Avenue South.

oN q Office Hy

r
e Home Health Office: 612.353.4984.

145. According to Minnesota Secretary of State records, I-Care Home Health

Care LLC is a Minnesota limited liability company located at 2854 Columbus Avenue

South. Mohamoud Warsame is identified as the manager and registered agent for I-

Care Home Health Care LLC.

46
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 48 of 99

146. A review of Aimee Bock’s email shows that Mahamoud Warsame is
involved in both Southside Youth and the Taylor Site. In August 2021, Mahamoud
Warsame sent an email to Aimee Bock containing two MDE site transfer request
forms for Southside Youth and another site called “Southside Child Development
Center.” The forms requested that both sites be transferred to Feeding Our Future
from another site sponsor.

147. Onor about October 1, 2021, Mahamoud Warsame sent another email
to Aimee Bock. Attached to the email was an invoice from Metro Area Catering, the
vendor for the Taylor Site. The invoice claimed that Metro Area Catering had both
breakfast and lunch to 1,500 children a day for 8 days in September 2021 and that
the company was entitled to a $74,250 in Federal Child Nutrition Program
reimbursements from Feeding Our Future. The address listed for Metro Area
Catering was 2501 Taylor Street NE, Minneapolis, Minnesota, which was the former

location of the Taylor Site.

a Feeding Our Future referred to the Taylor Site as “Feeding Our Future Taylor”
because it used to be located at 2510 Taylor Street NE before “transferring” to 2854 Columbus
Avenue South.

47
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~~‘ Filed 02/19/24 Page 49 of 99

From = INVOICE
Metro Are Catering
2501 Taylor Street NE
Minneapolis MN 55418

TO
Feeding Our Future MN OR Joseph's Poir
3055 Old Hwy 8 Suite#312, St Invoice #| 10056
Anthony, MN 55418 ae aap oes
Invoice Date | 10/01/2021 ("
Due Date | 10/01/2021}
item Description Unit Price Quantity Amount
vy BREAKFAST AT 1500 PER DAY FOR 2.00 13500.00 27000,00
8 DAYS SEPTEMBER
~ LUNCH AT 1500 PER DAY FOR 8 3.50 13500.00 47250.00
DAYS SEPTEMBER
New Line
Notes
Subtotal 74250.00
Total 74250.00
Amount Paid 0,00
Balance Due $74250.00

148. In all, MDE records show that Feeding Our Future received more than

$2.5 million in Federal Child Nutrition Program reimbursements for meals

purportedly served at the Taylor Site in 2021. Southside Youth, the other location

that Aimee Bock claimed was serving children from 2854 Columbus Avenue South,

received more than $500,000 in Federal Child Nutrition Program funds in 2021.

48
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~~‘ Filed 02/19/24 Page 50 of 99

VI. AIMEE BOCK AND OTHER FEEDING OUR FUTURE EMPLOYEES USED SHELL
COMPANIES TO FRAUDULENT MISAPPROPRIATR FEDERAL CHILD NUTRITION
PROGRAM FUNDS

149. The investigation has revealed that several Feeding Our Future
employees set up shell companies that they used to fraudulently misappropriate
Federal Child Nutrition Program funds from Feeding Our Future. These employees
include Feeding Our Future’s Executive Director, Aimee Bock. In addition, at least
two other Feeding Our Future employees appear to have fraudulently
misappropriated federal funds from Feeding Our Future: (1) Abdikerm Abdelahi
Eidleh, a “Program Support Manager” at Feeding Our Future; and (2) Hadith Yusuf
Ahmed, the “Director of Growth and Development.”

A. Aimee Bock Stole More than $600,000 in Federal Child Nutrition
Program Funds Through a Shell Company

150. The investigation has revealed that Aimee Bock misappropriated
approximately $600,000 in Federal Child Nutrition Program funds through a shell
company owned by her live-in boyfriend.

151. Bank records show that approximately $600,000 in Federal Child
Nutrition Program funds were sent to a Wells Fargo account in the name of Handy
Helper’s [sic] LLC between March 2020 and July 2021. Empress Malcolm Watson Jr.,
who lives with Aimee Bock and is believed to be her boyfriend, is the sole signatory
on the account. Aimee Bock is not listed as a signatory on the account but bank
records show that she signed checks drawn on the account. Aimee Bock’s home
address is listed on both the bank account and incorporation documents for Handy

Helper’s LLC.

49
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 51 of 99

152. Essentially all of the money deposited into this account were Federal
Child Nutrition Program funds obtained from Feeding Our Future. Bank records
show that this money was not used to purchase food or otherwise participate in the
Federal Child Nutrition Program. Instead, the money was converted to personal use,
with approximately $184,000 being withdrawn in cash and another approximately
$118,000 transferred to a personal account held by Empress Malcolm Watson Jr.

153. A significant amount of money from the Handy Helper’s LLC account
was used to fund an extravagant trip to Las Vegas, including more than $21,000 at
Royalty Exotic, a luxury car rental agency, $9,000 at Caesar’s Palace, $6,700 at Gucci,
and $3,500 at Louis Vuitton.

154. The Federal Child Nutrition Program funds deposited into the Handy
Helper’s LLC account were also used to make more mundane purchases, including
more than $14,000 at both Dick’s Sporting Goods and Home Depot.

B. Hadith Yusuf Ahmed Stole More than $1.1 Million in Federal
Child Nutrition Program Funds Through a Shell Company

155. The investigation has shown that Hadith Yusuf Ahmed also
misappropriated Federal Child Nutrition Program funds from Feeding Our Future
through the use of a shell company. According to MDE records, Hadith Yusuf Ahmed
is the “Director of Growth and Development” for Feeding Our Future.

156. Minnesota Secretary of State records show that. Hadith Yusuf Ahmed
created a company called Southwest Metro Youth in or about October 2020. Hadith
Yusuf Ahmed submitted the company’s articles of incorporation when he opened the

company. The articles of incorporation explained the purpose of Southwest Metro

50
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 52 of 99

Youth, which included to provide “educational after-school programs” and “to combat

youth crime.”

The purpose of this corporation is:
* to provide social and educational after-school programs
* to provide social, indoor and outdoor activities

¢ to help bring families and youth together through sports and other indoor
and outdoor social activities

* to combat youth crime within the neighborhoods; and

* to prevent community deterioration.

157. Shortly after incorporating Southwest Metro Youth, Hadith Yusuf
Ahmed opened an account for his new company at Wells Fargo. A review of bank
records show that Hadith Yusuf Ahmed did not use Southwest Metro Youth to
provide after-school programs for children. Instead, he used the account to
misappropriate Federal Child Nutrition Program funds. In January 2021, Hadith
Yusuf Ahmed began depositing large checks from Feeding Our Future into the
account. For example, on or May 5, 2021, Hadith Yusuf Ahmed deposited a check for

$305,819 from Feeding Our Future to Southwest Metro Youth.

51
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 53 of 99

3055 OLD HWY 8, SUITE 312
MINNEAPOLIS, MN 55416 —_O5/N52024
SOUTHWEST METRO YOUTH CED

158. In all, Hadith Yusuf Ahmed deposited a total of $1.1 million in checks
from Feeding Our Future between January and May 2021. This represented nearly

99 percent of the funds deposited into the account.

Date Amount

January 20, 2021 $100,000
February 1, 2021 $13,708
February 12, 2021 $230,417
March 8, 2021 $188,628
May 5, 2021 $305,819
May 19, 2021 $295,389
Total $1,135,963

159. Bank records show that Hadith Yusuf Ahmed did not use this money to
provide after-school programs or combat youth crime, Nor did he use the money to
purchase food or serve meals to underprivileged children. Instead, he transferred
about 80 percent of this money to entities controlled by Abdikerm Abdelahi Eidleh,
including Hope Suppliers LLC and Bridge Logistics LLC. In all, bank records show
that Hadith Yusuf Ahmed transferred approximately $843,000 to accounts held by

Abdikerm Abdelahi Eidleh in the name of Hope Suppliers LLC or Bridge Logistics

52
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 54 of 99

LLC. As described below, these accounts and entities were used by Abdikerm
Abdelahi Eidleh to misappropriate Federal Child Nutrition Program funds.

OF Abdikerm Abdelahi Eidleh Stole More than $300,000 in Federal
Child Nutrition Program Funds Through a Shell Company

160. Abdikerm Abdelahi Eidleh also fraudulent misappropriated Federal
Child Nutrition Program funds from Feeding Our Future through the use of a shell
company called Hope Suppliers LLC. Abdikerm Abdelahi Eidleh worked as the
“Program Support Manager” at Feeding Our Future.

161. The investigation has shown that Abdikerm Abdelahi Eidleh used a
shell company called Hope Suppliers LLC to misappropriate Federal Child Nutrition
Program funds from Feeding Our Future. Minnesota Secretary of State records show
that Abdikerm Abdelahi Eidleh created Hope Suppliers LLC in December 2020. He
then opened several bank accounts in the name of his new company.

162. Bank records show that on or about October 8, 2021, Abdikerm Abdelahi

Eidleh deposited a $343,064 check into the Hope Suppliers LLC account at JP Morgan

Chase Bank. This check was written from Feeding Our Future.

MINNEAPOLIS, MN 55418 3

PAY TO THE Hope Suppilers **343,064.12 j

ORDER OF. $
Three hundred forly-three thousand sixty-four and 12/100 n'y Aa
DOLLARS

Hope Suppliers j

i

53
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 55 of 99

163. Bank records show that this money was not used to purchase food or
meals. As explained below, Abdikerm Abdelahi Ejidleh used this and the other money
received into the Hope Suppliers LLC bank accounts for personal spending.

D. Abdikerm Abdelahi Eidleh and Hadith Yusuf Ahmed Solicited

and Received Kickbacks from Federal Child Nutrition Program
Sites

164. During the investigation, an FBI forensic accountant reviewed bank
records for accounts held by Feeding Our Future and Feeding Our Future employees.
During her review, the forensic accountant noticed Abdikerm Abdelahi Eidleh had
opened a large number of bank accounts. These accounts were held at a number of
banks and in the name of a number of corporate entities. After reviewing these
accounts, the forensic accountant. concluded that Abdikerm Abdelahi Eidleh was
using these entities to solicit and receive kickbacks from Feeding Our Future-
sponsored sites that were fraudulently receiving Federal Child Nutrition Program
funds.

165. Abdikerm Abdelahi Eidleh appears to have created several limited
liability companies for use in soliciting and receiving kickbacks, including Hope
Suppliers LLC, Eidleh Inc., Bridge Logistics LLC, Bridge Consulting and Logistics
LLG, Delta Food Services LLC, Math Tech Tutoring LLG, and Ideal Takeout LLC.
Minnesota Secretary of State records show that Abdikerm Abdelahi Eidleh created
most of these companies between November 2020 and February 2021.

166. Bank records show that Abdikerm Abdelahi Eidleh deposited more than
$4.4 million into bank accounts held by these companies in 2020 and 2021. Most of

these deposits came from entities that fraudulently misappropriated Federal Child

54
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 56 of 99

Nutrition Program funds. For example, Abdikerm Abdelahi Eidleh received more
than $500,000 from entities created and used to launder the proceeds of Safari
Restaurant’s scheme to fraudulently obtain and misappropriate Federal Child

Nutrition Program funds.

Entity Amount
Tunyar Trading LLC $225,999
Horseed Management LLC $112,000
Salim Limited LLC $49,000
Cosmopolitan Business $42,000
Solutions LLC

Olive Management Inc. $38,000
ASA Limited LLC $35,000
AG Limited LLC $5,000
Total $506,999

167. Abdikerm Abdelahi Bidleh also deposited approximately $843,000 from
Southwest Metro Youth, the company created by Hadith Yusuf Ahmed and used to
misappropriate $1.1 million in Federal Child Nutrition Program funds from Feeding
Our Future.

168. Bank records show that Abdikerm Abdelahi Eidleh did not use this
money to provide food or meals to underprivileged children. Instead, he appears to
have used much of the funds in the accounts of his various shell companies to fund
his lifestyle and enrich himself. For example, he paid approximately $212,000
towards the mortgage on his home (a/k/a Subject Premises 5). He also sent
approximately $88,000 to Coinbase.com, an online cryptocurrency exchange, and
$73,000 to an online currency trading brokerage. Bank records show that he spent

$50,000 at a jewelry store in Dubai.

55
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 57 of 99

169. Hadith Yusuf Ahmed also appears to have solicited and received
kickbacks from sites under the sponsorship of Feeding Our Future. Hadith Yusuf
Ahmed solicited and receiving these kickbacks through a shell company called Mizal
Consulting LLC. According to Minnesota Secretary of State records, Hadith Yusuf
Ahmed created Mizal Consulting LLC in or about December 2020. Mizal Consulting
had an account at Wells Fargo Bank. Bank records show that Hadith Yusuf Ahmed
also used this account to fraudulently receive, launder, and misappropriate Federal
Child Nutrition Program funds.

170. Bank records show that approximately $875,000 was deposited into the
Mizal Consulting LLC account between December 2020 and December 2021. Nearly
all of this money was Federal Child Nutrition Program funds received from entities
involved in the program under the sponsorship of Feeding Our Future. This included
approximately $65,000 from Bushra Wholesalers LLC. On or about January 12, 2022,
Magistrate Judge Tony N. Leung signed a federal search warrant for the office
Bushra Wholesalers LLC based on the company’s involvement in fraudulently
receiving, laundering, and misappropriating Federal Child Nutrition Program funds.
VII. COMPUTERS, ELECTRONIC STORAGE, AND FORENSIC ANALYSIS

171. Based upon my knowledge, training, experience, and the experience of
other law enforcement personnel, I know that computer hardware and computer
software may be utilized to store records which include, but are not limited to: those
relating to business activities, criminal activities, associate names and addresses,
victims’ names, addresses, and images, the identity and location of assets illegally

gained through criminal activity, and other information related to criminal activity.

56
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 58 of 99

172. As described above and in Attachment B, this application seeks
permission to search for records that might be found at the Subject Premises, in
whatever form they are found. One form in which the records might be found is data
stored on a computer’s hard drive, cellular telephone, or other storage media. Thus,
the warrant applied for would authorize the seizure of electronic storage media or,
potentially, the copying of electronically stored information, all under Rule
41(e)(2)(B).

Probable Cause to Seize Electronic Devices at Subject Premises

173. Isubmit that if a computer, cellular telephone, or other storage medium
is found on the Subject Premises, there is probable cause to believe those records will
be stored on that computer or storage medium, for at least the following reasons:

a. Based on my knowledge, training, and experience, I know that
computer files or remnants of such files can be recovered months or even years after
they have been downloaded onto a storage medium, deleted, or viewed via the
Internet. Electronic files downloaded to a storage medium can be stored for years at
little or no cost. Even when files have been deleted, they can be recovered months or
years later using forensic tools. This is so because when a person “deletes” a file on a
computer, the data contained in the file does not actually disappear; rather, that data
remains on the storage medium until it is overwritten by new data.

b. Therefore, deleted files, or remnants of deleted files, may reside
in free space or slack space—that is, in space on the storage medium that is not

currently being used by an active file—for long periods of time before they are

57
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 =‘ Filed 02/19/24 Page 59 of 99

overwritten. In addition, a computer’s operating system may also keep a record of
deleted data in a “swap” or “recovery” file.

c. Wholly apart from user-generated files, computer storage
media—in particular, computers’ internal hard drives—contain electronic evidence of
how a computer has been used, what it has been used for, and who has used it. To
give a few examples, this forensic evidence can take the form of operating system
configurations, artifacts from operating system or application operation, file system
data structures, and virtual memory “swap” or paging files. Computer users typically
do not erase or delete this evidence, because special software is typically required for
that task. However, it is technically possible to delete this information.

d. Similarly, files that have been viewed via the Internet are
sometimes automatically downloaded into a temporary Internet directory or “cache.”

e. Based on actual inspection of other evidence related to this
investigation, including emails obtained through search warrants, I am aware that
computer equipment was used to carry out this fraud scheme. There is reason to
believe that there is a computer system currently located on the Subject Premises.

174. Forensic evidence. As further described in Attachment B, this
application seeks permission to locate not only computer files that might serve as
direct evidence of the crimes described on the warrant, but also for forensic electronic
evidence that establishes how computers were used, the purpose of their use, who
used them, and when. There is probable cause to believe that this forensic electronic

evidence will be on any storage medium in the Subject Premises because:

58
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 60 of 99

a. Data on the storage medium can provide evidence of a file that
was once on the storage medium but has since been deleted or edited, or of a deleted
portion of a file (such as a paragraph that has been deleted from a word processing
file). Virtual memory paging systems can leave traces of information on the storage
medium that show what tasks and processes were recently active. Web browsers, e-
mail programs, and chat programs store configuration information on the storage
medium that can reveal information such as online nicknames and passwords.
Operating systems can record additional information, such as the attachment of
peripherals, the attachment of USB flash storage devices or other external storage
media, and the times the computer was in use. Computer file systems can record
information about the dates files were created and the sequence in which they were
created, although this information can later be falsified.

b. As explained herein, information stored within a computer and
other electronic storage media may provide crucial evidence of the “who, what, why,
when, where, and how” of the criminal conduct under investigation, thus enabling
the United States to establish and prove each element or alternatively, to exclude the
innocent from further suspicion. In my training and experience, information stored
within a computer or storage media (e.g., registry information, communications,
images and movies, transactional information, records of session times and
durations, internet history, and anti-virus, spyware, and malware detection
programs) can indicate who has used or controlled the computer or storage media.

This “user attribution” evidence is analogous to the search for “indicia of occupancy”

59
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘Filed 02/19/24 Page 61 of 99

while executing a search warrant at a residence. The existence or absence of anti-
virus, spyware, and malware detection programs may indicate whether the computer
was remotely accessed, thus inculpating or exculpating the computer owner. Further,
computer and storage media activity can indicate how and when the computer or
storage media was accessed or used. For example, as described herein, computers
typically contain information that log: computer user account session times and
durations, computer activity associated with user accounts, electronic storage media
that connected with the computer, and the IP addresses through which the computer
accessed networks and the internet. Such information allows investigators to
understand the chronological context of computer or electronic storage media access,
use, and events relating to the crime under investigation. Additionally, some
information stored within a computer or electronic storage media may provide crucial
evidence relating to the physical location of other evidence and the suspect. For
example, images stored on a computer may both show a particular location and have
geolocation information incorporated into its file data. Such file data typically also
contains information indicating when the file or image was created. The existence of
such image files, along with external device connection logs, may also indicate the
presence of additional electronic storage media (e.g., a digital camera or cellular
phone with an incorporated camera). The geographic and timeline information
described herein may either inculpate or exculpate the computer user. Last,
information stored within a computer may provide relevant insight into the computer

user’s state of mind as it relates to the offense under investigation. For example,

60
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 =‘ Filed 02/19/24 Page 62 of 99

information within the computer may indicate the owner's motive and intent to
commit a crime (e.g., internet searches indicating criminal planning), or
consciousness of guilt (e.g., running a “wiping” program to destroy evidence on the
computer or password protecting/encrypting such evidence in an effort to conceal it
from law enforcement).

c. A person with appropriate familiarity with how a computer works
can, after examining this forensic evidence in its proper context, draw conclusions
about how computers were used, the purpose of their use, who used them, and when.

d. The process of identifying the exact files, blocks, registry entries,
logs, or other forms of forensic evidence on a storage medium that are necessary to
draw an accurate conclusion is a dynamic process. While it is possible to specify in
advance the records to be sought, computer evidence is not always data that can be
merely reviewed by a review team and passed along to investigators. Whether data
stored on a computer is evidence may depend on other information stored on the
computer and the application of knowledge about how a computer behaves. Therefore,
contextual information necessary to understand other evidence also falls within the
scope of the warrant.

175. I know that when an individual uses a computer to commit a crime the
individual’s computer will generally serve both as an instrumentality for committing
the crime, and also as a storage medium for evidence of the crime. The computer is
an instrumentality of the crime because it is used as a means of committing the

criminal offense. The computer is also likely to be a storage medium for evidence of

61
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 =‘ Filed 02/19/24 Page 63 of 99

crime. From my training and experience, I believe that a computer used to commit a
crime of this type may contain: data that is evidence of how the computer was used;
data that was sent or received; notes as to how the criminal conduct was achieved;
records of Internet discussions about the crime; and other records that indicate the
nature of the offense.

176. Necessity of seizing or copying entire computers or storage media, Based
upon my knowledge, training and experience, and the experience of other law
enforcement personnel, I know that in order to completely and accurately retrieve
data maintained in computer hardware or on computer software, all computer
equipment, should be processed by a qualified computer specialist in a laboratory or
other competent setting. This is due to:

a. The volume of evidence. Computer storage devices (like hard
disks, removable media, optical media, diskettes, tapes, laser disks, Bernoulli drives)
can store the equivalent of millions of pages of information. Additionally, a suspect
may try to conceal criminal evidence; he or she might store it in random order with
deceptive file names, or use encryption or steganography software. This may require
searching authorities to examine all the stored data to determine which particular
files are evidence or instrumentalities of crime. This sorting process can take weeks
or months, depending on the volume of data stored, and it would be impractical to
attempt this kind of data search on site;

b. The technical requirements. Searching computer systems for

criminal evidence is a highly technical process requiring expert skill and a properly
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~~‘ Filed 02/19/24 Page 64 of 99

controlled environment, The vast array of computer hardware and software available
requires even computer experts to specialize in some systems and applications, so it
is difficult to know before a search which expert is qualified to analyze a system and
its data. In any event, however, data search protocols are exacting scientific
procedures designed to protect the integrity of the evidence and to recover even
hidden, erased, compressed, password-protected, or encrypted files. Since computer
evidence is extremely vulnerable to inadvertent or intentional modification or
destruction (from external sources or destructive code imbedded in the system as a
booby trap), a controlled environment is essential to its complete and accurate
analysis. Further, when a user deletes a file on a computer, only the pointer (a tool
that tells the operating system where the file is located on the media) to the file is
deleted. The actual file may remain on the media for a long period of time, possibly
years. Forensics examiners can use software tools that can locate and partially and/or
fully recover deleted files;

C. System functionality. Computer systems are very complicated
and the proper operation of the system may be dependent upon the hardware that is
connected to it. For this reason, it is usually necessary to seize all hardware connected
to the equipment in order to ensure the proper operation of the system during the
analysis process.

d. Nature of examination. Based on the foregoing, and consistent
with Rule 41(e)(2)(B), the warrant I am applying for would permit the examination

of the device consistent with the warrant. The examination may require authorities

63
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 =‘ Filed 02/19/24 Page 65 of 99

to employ techniques, including, but not limited to computer-assisted scans of the
entire medium, that might expose many parts of the device to human inspection in
order to determine whether it is evidence described by the warrant.

177. The search warrant requests authorization to use the biometric unlock
features of a device, based on the following, which I know from my training,
experience, and review of publicly available materials:

a. Users may enable a biometric unlock function on some digital
devices. To use this function, a user generally displays a physical feature, such as a
fingerprint, face, or eye, and the device will automatically unlock if that physical
feature matches one the user has stored on the device. To unlock a device enabled
with a fingerprint unlock function, a user places one or more of the user’s fingers on
a device’s fingerprint scanner for approximately one second. To unlock a device
enabled with a facial, retina, or iris recognition function, the user holds the device in
front of the user’s face with the user’s eyes open for approximately one second,

b. In some circumstances, a biometric unlock function will not
unlock a device even if enabled, such as when a device has been restarted or inactive,
has not been unlocked for a certain period of time (often 48 hours or less), or after a
certain number of unsuccessful unlock attempts. Thus, the opportunity to use a
biometric unlock function even on an enabled device may exist for only a short time.
I do not know the passcodes of the devices likely to be found in the search.

178. Thus, the warrant I am applying for would permit law enforcement

personnel to, with respect to any device that appears to have a biometric sensor and

64
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~~‘ Filed 02/19/24 Page 66 of 99

falls within the scope of the warrant. As set forth above, the Subject Premises are
locations from which fraudulent companies are being run and where multiple
individuals who, together, commit fraud together may be found. In my training and
experience, I know that business locations often contain a variety of electronics, to
include computers and cellular telephones. I further know that in this case, such
electronic are being actively used to carry out the fraud scheme. Digital devices found
at the Subject Premises may or may not have a clearly identifiable user based on the
exterior of the device and/or may have multiple users whose biometric features may
unlock the devices. Thus, if while executing the warrant, law enforcement personnel
encounter a digital device within the scope of the warrant that may be unlocked using
one of the aforementioned biometric features, the warrant I am applying for would
permit law enforcement personnel to, with respect to every person who is located at
the Subject Premises during the execution of the search: (1) depress the person's
thumb- and/or fingers on the device(s); and (2) hold the device(s) in front of the face
of the person with his or her eyes open to activate the facial-, iris-, and/or retina-

recognition feature.

65
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 67 of 99

VIII. CONCLUSION

179. Based on the facts set forth above, and based on my training, experience,
knowledge, and the aforementioned facts of this investigation, there is probable cause
to believe that evidence and instrumentalities of mail fraud, wire fraud, conspiracy,
and money laundering, in violation of 18 U.S.C. §§ 1341, 1348, 1349, 1956 and 1957,
as described in Attachment B, can be found at the Subject Premises, as further

described in Attachment A-1 to A-6.

Respectfully submitted,

FBI Special Agent Travis Wilmer

SUBSCRIBED and SWORN before me by reliable
electronic means (FaceTime, Zoom and/or email)
pursuant to Fed. R. Crim. P. 41(d)(8)

The Honorable Tbhy N. Leung
United States Magistrate Judge

66
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘Filed 02/19/24 Page 68 of 99

Attachment A-1

Subject Premises 1 is the business located at 3055 Old Highway 8, Suites 312
and 229, Saint Anthony, Minnesota 55418. 3055 Old Highway 8 is a four-story tan
office building located on the east side of Old Highway 8 at the intersection with 31st

Avenue NE.

The Front main entrance is located on the west side of the building. The numbers

“3055” appear above the door.

Subject Premises 1 consists of Suites 312 and 229, which are the officer of
Feeding Our Future. Suite 312 is located on the third floor of the building. The door

to Suite 312 has a sign that reads “Feeding Our Future.”
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 69 of 99

Suite 229 is located on the second floor of the building. The entrance to Suite

229 is a brown wood door. The numbers “229” appear on the top of the door frame.
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 70 of 99

ATTACHMENT B
(List of Items to be Seized)

Items to be seized include all evidence of violations of Title 18, United States
Code, Sections 1341 (mail fraud), 1343 (wire fraud), 1349 (conspiracy), 1956 and 1957
(money laundering), for the period of January 1, 2017 through the present, related to
a scheme to fraudulently obtain and misappropriate federal child nutrition program
funds, including the following:

1. All documents, correspondence, or information related to Feeding Our
Future’s participation in Summer Food Service Program, Child and Adult Care Food
Program, and other federal child nutrition programs (“federal child nutrition
programs”), including applications, site contracts, vendor contracts, reimbursement
claims, invoices, receipts, payments records of meals served, employee rosters, site
rosters and tallies of children served, menus, advertising, policies and procedures,
emails and communications with staff, and leases.

2. All correspondence or communication with the Minnesota Department
of Education, U.S. Department of Agriculture, or companies and entities
participating in the federal child nutrition programs, including sites, vendors, and
sponsoring agencies, related to participation in federal child nutrition programs.

3. All personal financial documents, records and information for Aimee
Marie Bock, Empress Malcolm Watson Jr., Abdikerm Abdelahi Eidleh, and Hadith
Yusuf Ahmed, including but not limited to the following:

a. Financial records including bank statements, deposit tickets,

canceled checks, credit and debit memos, wire transfers, bank money orders, cashier's
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 71 of 99

checks, investment records, stock and bond records, loan records, safety deposit box
records, financial statements, tax returns, and records utilized in the preparation of
tax returns;

b. Retained copies of personal and business tax returns;

C. Receipts and other documents showing disbursement of funds
and ownership of assets, including purchases of real estate and other assets, home
improvement, and casino player cards; and

d. Documents showing the location of other records including
receipts and contracts for rental units, and change of address or post office box
records.

4, All documents, records and information pertaining to Feeding Our
Future, Handy Helper’s [sic] LLC, Hope Suppliers LLC, Bridge Logistics LLC, Bridge
Consulting and Logistics LL, Eidleh Inc., Delta Food Services LLC, Math Tech
Tutoring LLC, Ideal Takeout LLC, Southwest Metro Youth, Mizal Consulting, and
any associated entities or companies, including the following:

a. Accounting records including financial statements, chart of
accounts, account ledgers, general ledgers, cash receipt journals, cash disbursement
journals, payroll registers, check registers, accounts payable ledgers, accounts
receivable ledgers, general journal and overhead rates and calculations;

b. Records that show ownership, control, affiliation, and operation
of Feeding Our Future, Handy Helper’s [sic] LLC, Hope Suppliers LLC, Bridge

Logistics LLC, Bridge Consulting and Logistics LL, Eidleh Inc., Delta Food Services
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 =‘ Filed 02/19/24 Page 72 of 99

LLG, Math Tech Tutoring LLC, Ideal Takeout LLC, Southwest Metro Youth, Mizal
Consulting, or any other associated companies, entities, investments, or assets,
including but not limited to articles of incorporation, corporate resolutions or
minutes, other business or corporate records, memoranda, by-laws, shareholder
information, donor information, service agreements, partnership agreements,
memoranda of understanding, and other documents evincing ownership, control,
affiliation, and operation.

c. Financial records including bank statements, deposit tickets,
canceled checks, credit and debit memos, wire transfers, bank money orders, cashier’s
checks, investment records, stock and bond records, safety deposit box records, tax
returns, and records utilized in the preparation of tax returns;

d. Personnel files and employee information for all employees,
volunteers, and/or independent contractors, including, but not limited to, payroll
records, time sheets and other records of work performed, applications for
employment, background checks, Forms 1099, Forms W-2, and Forms W-4; and

e. Business records including invoices, statements, contracts and
agreements, purchase and sale records, records of donations, and correspondence.

5. All documents, records, and information pertaining to sites, vendors,
companies or entities participating in the Summer Food Service Program, Child and
Adult Care Food Program, and other federal child nutrition programs including the

following:
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 73 of 99

a. Any and all records and evidence related to participation in
federal child nutrition programs, including applications, site contracts, vendor
contracts, reimbursement claims, invoices, receipts, payments records of meals
served, employee rosters, site rosters and tallies of children served, menus,
advertising, policies and procedures, emails and communications with staff, and
leases.

b. Accounting records including financial statements, chart of
accounts, account ledgers, general ledgers, cash receipt journals, cash disbursement
journals, payroll registers, check registers, accounts payable ledgers, accounts
receivable ledgers, general journal and overhead rates and calculations;

C. Records that show ownership, control, affiliation, and operation
of companies and entities participating in federal child nutrition program, including
but not limited to articles of incorporation, corporate resolutions or minutes, other
business or corporate records, memoranda, by-laws, shareholder information, donor
information, service agreements, partnership agreements, memoranda of
understanding, and other documents evincing ownership, control, affiliation, and
operation.

d. Financial records including bank statements, deposit tickets,
canceled checks, credit and debit memos, wire transfers, bank money orders, cashier's
checks, investment records, stock and bond records, safety deposit box records, tax

returns, and records utilized in the preparation of tax returns;
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 74 of 99

e. Personnel files and employee information for all employees,
volunteers, and/or independent contractors, including, but not limited to, payroll
records, time sheets and other records of work performed, applications for
employment, background checks, Forms 1099, Forms W-2, and Forms W-4; and

f. Business records including invoices, statements, contracts and
agreements, purchase and sale records, records of donations, and correspondence.

6. Property records, receipts, investment records, stock and bond records,
mortgages, rental or lease agreements, promissory notes, handwritten notes,
calendars, day planners, logs, records related to wire transfers or reflecting financial
transactions, and records related to or tending to identify the source, accumulation,
disposition, location or ownership of assets, money, wealth, property, safe deposit
records, and safe deposit keys.

ie Records reflecting business or personal travel, including passports;

8. Information that constitutes evidence of meals served to
underprivileged children.

9. Cash or cash equivalent, coins, stocks, bonds, gold, jewelry, watches or
other proceeds of the fraud offense.

10. Correspondence, memos, reports, notes, and e-mails pertaining to the
business and personal financial affairs described above.

11. All documents and records tending to show the identities of associates

or co-conspirators, or tending to show the location of assets including notes, telephone
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 75 of 99

messages, telephone numbers, email addresses, address books, and appointment
books.

12. Smartphones or cellular telephones, computers, tablet computers, and
other digital storage media that may contain any of the records or information
described above.

13. Any computer software (and related instructions or manuals) that was
used or may have been used to operate the computer hardware listed above, access
remote computers, communicate with others, or to manage and record financial
transactions, including but not limited to Internet browsers, Internet access software,
word processing programs, email software, banking software, business management
tools, and accounting software.

14. Any access devices, records, or information needed to open or fully
operate the computer hardware or software listed above, including but not limited to
physical keys, account numbers, screen names, passwords, personal identification
numbers (PINs), or digital certificates.

15. The terms “records” and “information” include all of the foregoing items
of evidence in whatever form and by whatever means they may have been created or
stored, including any electrical, electronic, or magnetic form (such as any information
on an electronic or magnetic storage device, including hard disks, ZIPdisks, optical
discs, backup tapes, smart cards, memory calculators, personal digital assistants, as
well as printouts or readouts from any magnetic storage device); any handmade form

(such as writing, drawing, painting); any mechanical form (such as printing or
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘Filed 02/19/24 Page 76 of 99

typing); and any photographic form (such as prints, negatives, videotapes, motion
pictures, photocopies).

16. Any and all records related to the use of post office boxes, virtual offices,
or mail service providers.

17. Items needed to access the information listed above, such as:

a. Cabinet and desk keys;

b. Documents and items regarding the rental or use or a storage
unit, including contracts, rental agreements, and keys; and

c. Safe and lock combination and keys.

18. Any digital device capable of storing information related to the
commission or attempted commission of the above listed violations, or used to
facilitate the above-listed violations, and forensic copies thereof.

19. With respect to any digital-device containing evidence falling within the
scope of the foregoing categories of items to be seized:

a, evidence of who used, owned, or controlled the device at the time
the things described in this warrant were created, edited, or deleted, such as logs,
registry entries, configuration files, saved usernames and passwords, documents,
browsing history, user profiles, e-mail, e-mail contacts, chat and instant messaging
logs, photographs, and correspondence;

b. evidence of the presence or absence of software that would allow

others to control the device, such as viruses, Trojan horses, and other forms of
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 77 of 99

malicious software, as well as evidence of the presence or absence of security software
designed to detect malicious software;

e. evidence of the attachment of other devices;

d. evidence of counter-forensic programs (and associated data) that
are designed to eliminate data from the device;

e. evidence of the times the device was used;

f. passwords, encryption keys, and other access devices that may be
necessary to access the device;

g. applications, utility programs, compilers, interpreters, or other
software, as well as documentation and manuals, that may be necessary to access the
device or to conduct a forensic examination of it;

h. records of or information about Internet Protocol addresses used
by the device;

i. records of or information about the device’s Internet activity,
including firewall logs, caches, browser history and cookies, “bookmarked” or
“favorite” web pages, search terms that the user entered into any Internet search
engine, and records of user-typed web addresses.

20. As used herein, the terms “records,” “documents,” “programs,”
“applications,” and “materials” includes records, documents, programs, applications,
and materials created, modified, or stored in any form, including in digital form on

any digital device and any forensic copies thereof.
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~~‘ Filed 02/19/24 Page 78 of 99

21. As used herein, the term “digital device” includes any electronic system
or device capable of storing or processing data in digital form, including central
processing units, desktops, laptops, notebooks, and tablet computers; personal digital
assistants; wireless communication devices, such as telephone paging devices,
beepers, mobile telephones, and smart phones; digital cameras; peripheral
input/output devices, such as keyboards, printers, scanners, plotters, monitors, and
drives intended for removable media; related communications devices, such as
modems, routers, cables, and connections; storage media, such as hard disk drives,
floppy disks, memory cards, optical disks, and magnetic tapes used to store digital

data (excluding analog tapes such as VHS); and security devices,
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~~‘ Filed 02/19/24 Page 79 of 99

SEARCH WARRANT ADDENDUM

In conducting the search authorized by this warrant, the government shall
make reasonable efforts to utilize search methodology that avoids searching
files, documents or other electronically stored information which is not
identified in the warrant.

If electronically stored data, information, documents or other records have
been identified and seized by the government pursuant to this warrant, the
government may retain the electronic storage device (e.g., computer, hard
drive, mobile device, smartphone, cell phone). The person from whom the
electronic storage device was seized may request that the government provide
him or her with electronic copies of the data, information, documents or other
records by making a written request to the United States Attorney’s Office,
identifying with specificity the data, information, documents or other records
sought to be copied. The government must respond to all such requests within
a reasonable amount of time, and must provide a copy of the electronically
stored data, information, documents or other records requested unless the
copies requested constitute contraband, instrumentalities, or property subject
to forfeiture.

Nothing in this warrant shall limit or prevent the government from seizing the
electronic storage device as contraband or an instrumentality of a crime or
commencing forfeiture proceedings against the electronic storage device and
the data contained in the device. Nothing in this warrant shall limit or prevent
the owner of the electronic storage device, files, software, hardware, data,
information, documents or other records from (a) filing a motion with the Court
pursuant to Rule 41(g) of the Federal Rules of Criminal Procedure for the
Return of Property, or (b) making a request of the government to return certain
specified electronic storage devices, files, software, hardware, data,
information, documents or other records.

The government shall establish a search methodology governing the review of
seized data to ensure that no attorney-client privileged communications will
be inadvertently reviewed by the prosecution team. In the event that data
seized pursuant to this warrant are identified by the government as possibly
containing attorney-client privileged communications, an Assistant United
States Attorney, who is not a member of the prosecution team and who is not
participating in the search, shall act as a "taint team" to set up an ethical wall
between the evidence and the prosecution team that will prevent any
privileged material from getting through to the prosecution team.
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘-Filed 02/19/24 Page 80 of 99

JHT-cjn
AO 93 (Rev_ 12/09) Search and Seizure Warrant 2021R00210

UNITED STATES DISTRICT COURT

for the
District of Minnesota

IN THE MATTER OF THE SEARCH OF THE SEALED BY ORDER OF THE COURT
OFFICE LOCATED AT 3055 OLD HIGHWAY 8,

SUITES 312 AND 229, SAINT ANTHONY, Case No. 22-MJ-039 TNL

MINNESOTA 55418, AS FURTHER DESCRIBED

IN ATTACHMENT A-1

SEARCH AND SEIZURE WARRANT

To: Any authorized law enforcement officer

An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the State and District of Minnesota:

See Attachment A-1, incorporated here.

The person or property to be searched, described above, is believed to conceal:

See Attachment B-1, incorporated here.

| find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
property.

YOU ARE COMMANDED to execute this warrant on or before January 28, 2022

(not to exceed 14 days)
xX in the daytime 6:00 a.m, to 10 p.m. _ at any time in the day or night as I find reasonable
cause has been established.

The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to the current United States Magistrate
Judge on duty.

Date and Time issued: ¢/7 @. iy, WZ Z 12: 72 m~ La WV L—

City and State: Minneapolis, MN The Honorable Tony N. Leung
United States Magistrate Judge _

Printed Name and Title
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 81 of 99

AO 93 (Rev. 12/09) Search and Seizure Warrant (Page 2)

Return

Case No.: Date and time warrant executed: Copy of warrant and inventory left with:

Inventory made in the presence of :

Inventory of the property taken and name of any person(s) seized:

Certification

I declare under penalty of perjury that this inventory is correct and was returned along with the original
warrant to the designated judge.

Date:

Executing officer’s signature

Printed Name and Title

SUBSCRIBED and SWORN before me by reliable
electronic means (FaceTime, Zoom and/or email)
pursuant to Fed. R. Crim. P. 41(d)(3)

United States Magistrate Judge Date
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 82 of 99

Attachment A-1
Subject Premises 1 is the business located at 3055 Old Highway 8, Suites 312
and 229, Saint Anthony, Minnesota 55418. 3055 Old Highway 8 is a four-story tan

office building located on the east side of Old Highway 8 at the intersection with 31st

Avenue NE.

The Front main entrance is located on the west side of the building. The numbers

“3055” appear above the door.

Subject Premises 1 consists of Suites 312 and 229, which are the officer of
Feeding Our Future. Suite 312 is located on the third floor of the building. The door

to Suite 312 has a sign that reads “Feeding Our Future.”
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 =‘ Filed 02/19/24 Page 83 of 99

ey FEEDING OUR FUTURE

Suite 229 is located on the second floor of the building. The entrance to Suite

229 is a brown wood door. The numbers “229” appear on the top of the door frame.
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~~‘ Filed 02/19/24 Page 84 of 99

ATTACHMENT B
(List of Items to be Seized)

Items to be seized include all evidence of violations of Title 18, United States
Code, Sections 1341 (mail fraud), 1343 (wire fraud), 13849 (conspiracy), 1956 and 1957
(money laundering), for the period of January 1, 2017 through the present, related to
a scheme to fraudulently obtain and misappropriate federal child nutrition program
funds, including the following:

1, All documents, correspondence, or information related to Feeding Our
Future’s participation in Summer Food Service Program, Child and Adult Care Food
Program, and other federal child nutrition programs (“federal child nutrition
programs”), including applications, site contracts, vendor contracts, reimbursement
claims, invoices, receipts, payments records of meals served, employee rosters, site
rosters and tallies of children served, menus, advertising, policies and procedures,
emails and communications with staff, and leases.

2. All correspondence or communication with the Minnesota Department
of Education, U.S. Department of Agriculture, or companies and entities
participating in the federal child nutrition programs, including sites, vendors, and
sponsoring agencies, related to participation in federal child nutrition programs.

3. All personal financial documents, records and information for Aimee
Marie Bock, Empress Malcolm Watson Jr., Abdikerm Abdelahi Eidleh, and Hadith
Yusuf Ahmed, including but not limited to the following:

a. Financial records including bank statements, deposit tickets,

canceled checks, credit and debit memos, wire transfers, bank money orders, cashier’s
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 =‘ Filed 02/19/24 Page 85 of 99

checks, investment records, stock and bond records, loan records, safety deposit box
records, financial statements, tax returns, and records utilized in the preparation of
tax returns;

b. Retained copies of personal and business tax returns;

c. Receipts and other documents showing disbursement of funds
and ownership of assets, including purchases of real estate and other assets, home
improvement, and casino player cards; and

d. Documents showing the location of other records including
receipts and contracts for rental units, and change of address or post office box
records,

4, All documents, records and information pertaining to Feeding Our
Future, Handy Helper’s [sic] LLC, Hope Suppliers LLC, Bridge Logistics LLC, Bridge
Consulting and Logistics LL, Eidleh Inc., Delta Food Services LLC, Math Tech
Tutoring LLC, Ideal Takeout LLC, Southwest Metro Youth, Mizal Consulting, and
any associated entities or companies, including the following:

a. Accounting records including financial statements, chart of
accounts, account ledgers, general ledgers, cash receipt journals, cash disbursement
journals, payroll registers, check registers, accounts payable ledgers, accounts
receivable ledgers, general journal and overhead rates and calculations;

b. Records that show ownership, control, affiliation, and operation
of Feeding Our Future, Handy Helpeyr’s [sic] LLC, Hope Suppliers LLC, Bridge

Logistics LLC, Bridge Consulting and Logistics LL, Hidleh Inc., Delta Food Services
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 86 of 99

LLC, Math Tech Tutoring LLC, Ideal Takeout LLC, Southwest Metro Youth, Mizal
Consulting, or any other associated companies, entities, investments, or assets,
including but not limited to articles of incorporation, corporate resolutions or
minutes, other business or corporate records, memoranda, by-laws, shareholder
information, donor information, service agreements, partnership agreements,
memoranda of understanding, and other documents evincing ownership, control,
affiliation, and operation.

C. Financial records including bank statements, deposit tickets,
canceled checks, credit and debit memos, wire transfers, bank money orders, cashier’s
checks, investment records, stock and bond records, safety deposit box records, tax
returns, and records utilized in the preparation of tax returns;

d. Personnel files and employee information for all employees,
volunteers, and/or independent contractors, including, but not limited to, payroll
records, time sheets and other records of work performed, applications for
employment, background checks, Forms 1099, Forms W-2, and Forms W-4; and

e. Business records including invoices, statements, contracts and
agreements, purchase and sale records, records of donations, and correspondence.

5, All documents, records, and information pertaining to sites, vendors,
companies or entities participating in the Summer Food Service Program, Child and
Adult Care Food Program, and other federal child nutrition programs including the

following:
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 87 of 99

a. Any and all records and evidence related to participation in
federal child nutrition programs, including applications, site contracts, vendor
contracts, reimbursement claims, invoices, receipts, payments records of meals
served, employee rosters, site rosters and tallies of children served, menus,
advertising, policies and procedures, emails and communications with staff, and
leases.

b. Accounting records including financial statements, chart of
accounts, account ledgers, general ledgers, cash receipt journals, cash disbursement
journals, payroll registers, check registers, accounts payable ledgers, accounts
receivable ledgers, general journal and overhead rates and calculations;

G Records that show ownership, control, affiliation, and operation
of companies and entities participating in federal child nutrition program, including
but not limited to articles of incorporation, corporate resolutions or minutes, other
business or corporate records, memoranda, by-laws, shareholder information, donor
information, service agreements, partnership agreements, memoranda of
understanding, and other documents evincing ownership, control, affiliation, and
operation.

d. Financial records including bank statements, deposit tickets,
canceled checks, credit and debit memos, wire transfers, bank money orders, cashier's
checks, investment records, stock and bond records, safety deposit box records, tax

returns, and records utilized in the preparation of tax returns;
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 88 of 99

e, Personnel files and employee information for all employees,
volunteers, and/or independent contractors, including, but not limited to, payroll
records, time sheets and other records of work performed, applications for
employment, background checks, Forms 1099, Forms W-2, and Forms W-4; and

f. Business records including invoices, statements, contracts and
agreements, purchase and sale records, records of donations, and correspondence.

6. Property records, receipts, investment records, stock and bond records,
mortgages, rental or lease agreements, promissory notes, handwritten notes,
calendars, day planners, logs, records related to wire transfers or reflecting financial
transactions, and records related to or tending to identify the source, accumulation,
disposition, location or ownership of assets, money, wealth, property, safe deposit
records, and safe deposit keys.

7. Records reflecting business or personal travel, including passports;

8. Information that constitutes evidence of meals served to
underprivileged children.

9. Cash or cash equivalent, coins, stocks, bonds, gold, jewelry, watches or
other proceeds of the fraud offense.

10. Correspondence, memos, reports, notes, and e-mails pertaining to the
business and personal financial affairs described above.

11. All documents and records tending to show the identities of associates

or co-conspirators, or tending to show the location of assets including notes, telephone
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 89 of 99

messages, telephone numbers, email addresses, address books, and appointment
books.

12. Smartphones or cellular telephones, computers, tablet computers, and
other digital storage media that may contain any of the records or information
described above.

13. Any computer software (and related instructions or manuals) that was
used or may have been used to operate the computer hardware listed above, access
remote computers, communicate with others, or to manage and record financial
transactions, including but not limited to Internet browsers, Internet access software,
word processing programs, email software, banking software, business management
tools, and accounting software.

14. Any access devices, records, or information needed to open or fully
operate the computer hardware or software listed above, including but not limited to
physical keys, account numbers, screen names, passwords, personal identification
numbers (PINs), or digital certificates.

15, The terms “records” and “information” include all of the foregoing items
of evidence in whatever form and by whatever means they may have been created or
stored, including any electrical, electronic, or magnetic form (such as any information
on an electronic or magnetic storage device, including hard disks, ZIPdisks, optical
dises, backup tapes, smart cards, memory calculators, personal digital assistants, as
well as printouts or readouts from any magnetic storage device); any handmade form

(such as writing, drawing, painting); any mechanical form (such as printing or
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 90 of 99

typing); and any photographic form (such as prints, negatives, videotapes, motion
pictures, photocopies).

16. Any and all records related to the use of post office boxes, virtual offices,
or mail service providers,

17. Items needed to access the information listed above, such as:

a. Cabinet and desk keys;

b. Documents and items regarding the rental or use or a storage
unit, including contracts, rental agreements, and keys; and

c. Safe and lock combination and keys.

18. Any digital device capable of storing information related to the
commission or attempted commission of the above listed violations, or used to
facilitate the above-listed violations, and forensic copies thereof.

19. With respect to any digital-device containing evidence falling within the
scope of the foregoing categories of items to be seized:

a. evidence of who used, owned, or controlled the device at the time
the things described in this warrant were created, edited, or deleted, such as logs,
registry entries, configuration files, saved usernames and passwords, documents,
browsing history, user profiles, e-mail, e-mail contacts, chat and instant messaging
logs, photographs, and correspondence;

b. evidence of the presence or absence of software that would allow

others to control the device, such as viruses, Trojan horses, and other forms of
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘Filed 02/19/24 Page 91 of 99

malicious software, as well as evidence of the presence or absence of security software
designed to detect malicious software;

c. evidence of the attachment of other devices;

d. evidence of counter-forensic programs (and associated data) that
are designed to eliminate data from the device;

e. evidence of the times the device was used;

f. passwords, encryption keys, and other access devices that may be
necessary to access the device;

g. applications, utility programs, compilers, interpreters, or other
software, as well as documentation and manuals, that may be necessary to access the
device or to conduct a forensic examination of it;

h. records of or information about Internet Protocol addresses used
by the device;

T, records of or information about the device’s Internet activity,
including firewall logs, caches, browser history and cookies, “bookmarked” or
“favorite” web pages, search terms that the user entered into any Internet search
engine, and records of user-typed web addresses.

20. As used herein, the terms “records,” “documents,” “programs,”
“applications,” and “materials” includes records, documents, programs, applications,
and materials created, modified, or stored in any form, including in digital form on

any digital device and any forensic copies thereof.
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘Filed 02/19/24 Page 92 of 99

21. As used herein, the term “digital device” includes any electronic system
or device capable of storing or processing data in digital form, including central
processing units, desktops, laptops, notebooks, and tablet computers; personal digital
assistants; wireless communication devices, such as telephone paging devices,
beepers, mobile telephones, and smart phones; digital cameras; peripheral
input/output devices, such as keyboards, printers, scanners, plotters, monitors, and
drives intended for removable media; related communications devices, such as
modems, routers, cables, and connections; storage media, such as hard disk drives,
floppy disks, memory cards, optical disks, and magnetic tapes used to store digital

data (excluding analog tapes such as VHS); and security devices.
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 _ ~—‘ Filed 02/19/24 Page 93 of 99

SEARCH WARRANT ADDENDUM

In conducting the search authorized by this warrant, the government shall
make reasonable efforts to utilize search methodology that avoids searching
files, documents or other electronically stored information which is not
identified in the warrant.

If electronically stored data, information, documents or other records have
been identified and seized by the government pursuant to this warrant, the
government may retain the electronic storage device (e.g., computer, hard
drive, mobile device, smartphone, cell phone). The person from whom the
electronic storage device was seized may request that the government provide
him or her with electronic copies of the data, information, documents or other
records by making a written request to the United States Attorney’s Office,
identifying with specificity the data, information, documents or other records
sought to be copied. The government must respond to all such requests within
a reasonable amount of time, and must provide a copy of the electronically
stored data, information, documents or other records requested unless the
copies requested constitute contraband, instrumentalities, or property subject
to forfeiture.

Nothing in this warrant shall limit or prevent the government from seizing the
electronic storage device as contraband or an instrumentality of a crime or
commencing forfeiture proceedings against the electronic storage device and
the data contained in the device. Nothing in this warrant shall limit or prevent
the owner of the electronic storage device, files, software, hardware, data,
information, documents or other records from (a) filing a motion with the Court
pursuant to Rule 41(g) of the Federal Rules of Criminal Procedure for the
Return of Property, or (b) making a request of the government to return certain
specified electronic storage devices, files, software, hardware, data,
information, documents or other records.

The government shall establish a search methodology governing the review of
seized data to ensure that no attorney-client privileged communications will
be inadvertently reviewed by the prosecution team. In the event that data
seized pursuant to this warrant are identified by the government as possibly
containing attorney-client privileged communications, an Assistant United
States Attorney, who is not a member of the prosecution team and who is not
participating in the search, shall act as a “taint team" to set up an ethical wall
between the evidence and the prosecution team that will prevent any
privileged material from getting through to the prosecution team.
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 94 of 99

2021R00210

UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
Case No. 22-MJ-039 TNL

IN THE MATTER OF THE SEARCH OF SEALED BY ORDER OF THE
THE OFFICE LOCATED AT 3055 OLD COURT

ST g a ee ie eae PETITION OF THE UNITED

NT ANT , MINNESOT

55418, AS FURTHER DESCRIBED IN Searnis on itor WAP RAM

ATTACHMENT A-1 ,
AFFIDAVIT, RETURN, PETITION
AND ORDER
FOR SEALING

COMES NOW the United States of America by its undersigned attorneys and
in support of its Petition for an Order Sealing Search Warrant, Affidavit, Return, and
Petition in the above-captioned matter, states as follows:

he On January 13, 2022, The Honorable Tony N. Leung issued a warrant
authorizing the search of the office located at 3055 Old Highway 8, Suites 312 and
229, Saint Anthony, Minnesota 55418, as further described in Attachment A-1,

2. The Affidavit of Special Agent Travis Wilmer submitted in support of
the search warrant, sets forth facts regarding an ongoing investigation into violations
of Title 18, United States Code, Sections 1341 (mail fraud), 1343 (wire fraud), 1349
(conspiracy), and 1956/1957 (money laundering).

3. The search warrant documents presented to this Court for in camera
review include detailed and highly sensitive investigative information. Disclosure of
the information would jeopardize an ongoing investigation into alleged criminal
offenses and the privacy of individuals unlikely to be, and/or who may ultimately not

be, indicted.
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 95 of 99

4. Nondisclosure of the search warrant documents is necessary to prevent
the ongoing investigation from being compromised. Immediate public filing of the
search warrant documents would, inter alia, compromise details about the nature,
extent, and scope of the investigation.

5. The search warrant documents contain identifying information of and
circumstances relating to an individual involved in criminal activity in some way who
may not be indicted in this case. Nondisclosure of the search warrant documents at
this stage is necessary to protect the person’s identity and/or to minimize the
substantial risk that revelation of details set forth in the search warrant documents
could cause to the person’s reputation.

6. The Court’s power to prevent disclosure of its files, especially for a
limited period of time, is well established. This general power has been recognized
by the United States Supreme Court.

It is uncontested, however, that the right to inspect and copy judicial

records is not absolute. Every court has supervisory power over some

records and files and access has been denied where court files might

have become a vehicle for improper purposes.

Nixon v. Warner Communications, Inc., 435 U.S. 589, 598 (1978).

7. The Eighth Circuit has recognized the Court’s specific power to restrict
access to search warrant documents like those at issue here:

We hold that the qualified first amendment right of public access

extends to the documents filed in support of search warrants and that

the documents may be sealed if the district court specifically finds that

sealing is necessary to protect a compelling government interest and
that less restrictive alternatives are impracticable.
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 _ ~—‘Filed 02/19/24 Page 96 of 99

In re Search Warrant for Secretarial Area Outside Office of Gunn, 855 F.2d 569, 574
(8th Cir. 1988).

8. The Eighth Circuit and district courts within the Circuit have
recognized that the circumstances surrounding ongoing investigations constitute
compelling government interests warranting the sealing of search warrant
documents. For example, the Eighth Circuit has approved sealing search warrant
documents that “describe[d] in detail the nature, scope and direction of the
government’s investigation and the individuals and specific projects involved,”
resulting in “substantial probability that the government's on-going investigation
would be severely compromised if the sealed documents were released.” Gunn. at 574.
Other compelling interests have similarly been recognized as justifying sealing.
Certain. Interested Individuals, John Does I-V, Who Are Employees of McDonnell
Douglas Corporation v. Pulitzer Publishing Co., 895 F.2d 460, 466 (8th Cir. 1990)
(“{w]here no indictments have issued against persons allegedly involved in criminal
activity, there is a clear suggestion that whatever their truth, the Government cannot
prove these allegations. ... All citizens, whatever their real or imagined past history,
are entitled to the protection of a grand jury proceeding.”).

9, Moreover, the Eighth Circuit has recognized that search warrant
affidavits permeated with references to individuals other than the subjects of the
search warrant and/or with information revealing the nature, scope and direction of
the government’s ongoing investigation may be sealed not only because they present

compelling government interests justifying sealing, but also because less restrictive
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 =‘ Filed 02/19/24 Page 97 of 99

alternatives to sealing are in such circumstances impracticable. Gunn, 855 F.2d at
574,

10. Based upon the foregoing and all the files and proceedings to date, the
United States respectfully requests that this Court issue an Order Sealing the
Warrant, Application, Affidavit of Special Agent Travis Wilmer, Return, this Petition,
and the Sealing Order until the close of business on July 14, 2022, unless a compelling

interest is shown by the United States for a continuation of the sealing.

Dated: January 14, 2022 Respectfully submitted,

CHARLES J. KOVATS, JR.
Acting United States Attorney

/s/ Joseph H. Thompson
BY: JOSEPH H. THOMPSON
Assistant U.S. Attorney
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 98 of 99

2021R00210
UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA

Case No. 22-MJ-039 TNL
IN THE MATTER OF THE SEARCH SEALED BY ORDER OF THE
OF THE OFFICE LOCATED AT 3055 COURT
OLD HIGHWAY 8, SUITES 312 AND
229, SAINT ANTHONY, MINNESOTA ORDER FOR SEALING

55418, AS FURTHER DESCRIBED IN
ATTACHMENT A-1

This Court, having reviewed the Petition of the United States herein, finds
that the United States has shown a compelling interest in the sealing of documents
in the above-captioned matter because:

a. Nondisclosure of the search warrant documents is necessary to prevent

the ongoing investigation from being compromised.

b. Nondisclosure of the search warrant documents is necessary to protect

the privacy of an individual who may ultimately remain unindicted.

This Court also finds that less restrictive alternatives to sealing are
impracticable or not appropriate.

It is therefore:

ORDERED that all documents filed in the above-captioned matter are hereby

sealed until the close of business on July 14, 2022.
CASE 0:22-cr-00223-NEB-DTS Doc. 255-1 ~—‘ Filed 02/19/24 Page 99 of 99

IT IS FURTHER ORDERED that these documents will be unsealed at the
above time unless further compelling interest is shown by the United States for
continuing this Order for an additional period of time.

Date The HonoraVle Tony N. Leung
United States Magistrate Judge


File and source

File

255-att1.pdf

Size

7,114,184 bytes

SHA-256

8b8ad1cf25ed2c372aba7268c4bd37cada3af48a30ef85eda46b2896b5702a00

Our copy

255-att1.pdf

Original

archive.org