Court filing — United States v. Bock et al. (Feeding Our Future) (Dkt. 409, D. Minn.)

Summary

The Government's Proposed Voir Dire Questions, Doc. 409, filed 01/10/25 in Case 0:22-cr-00223-NEB-DTS, United States of America v. Aimee Marie Bock, Salim Said, Abdulkadir Nur Salah and Abdi Nur Salah, Criminal No. 22-223 (NEB/DTS), in the U.S. District Court for the District of Minnesota. The United States submits a list of proposed questions for prospective jurors, numbered 1 through 49 and grouped under Basic Background, Knowledge of the Case and Case Participants, Previous Jury Service, Previous Contact with the Legal System or Criminal Justice System, Case Specific, and Following Instructions and Service as a Juror. The Case Specific group asks whether jurors have worked for or heard of Feeding Our Future, Safari Restaurant and other named entities, and about the Summer Food Service Program. The filing is dated January 10, 2025.

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      CASE 0:22-cr-00223-NEB-DTS       Doc. 409    Filed 01/10/25   Page 1 of 7




                       UNITED STATES DISTRICT COURT
                          DISTRICT OF MINNESOTA
                         Criminal No. 22-223 (NEB/DTS)

UNITED STATES OF AMERICA,

                     Plaintiff,

      v.
                                                  GOVERNMENT’S PROPOSED
1. AIMEE MARIE BOCK,                              VOIR DIRE QUESTIONS
3. SALIM SAID,
4. ABDULKADIR NUR SALAH,
   AND
6. ABDI NUR SALAH,

                    Defendants.



      The United States of America, by and through its attorneys, Andrew M.

Luger, United States Attorney for the District of Minnesota, and Joseph H. Thompson,

Matthew S. Ebert, Harry M. Jacobs, and Daniel W. Bobier, Assistant United States

Attorneys, respectfully submits the attached list of proposed voir dire questions to be

presented to the prospective jurors to be examined in this case, under the procedures

set forth in Federal Rule of Criminal Procedure 24(a).

Dated: January 10, 2025                       Respectfully Submitted,

                                              ANDREW M. LUGER
                                              United States Attorney

                                       BY:    /s/Joseph H. Thompson
                                              JOSEPH H. THOMPSON
                                              MATTHEW S. EBERT
                                              HARRY M. JACOBS
                                              DANIEL W. BOBIER
                                              Assistant United States Attorneys
      CASE 0:22-cr-00223-NEB-DTS         Doc. 409   Filed 01/10/25   Page 2 of 7




                                 Basic Background

      1.     Please state your name, where you live, and your occupation. Have you

had any other occupations during the past 5 years? If so, what are they? If retired,

what was your occupation before retiring?

      2.     Please provide the same information as to your spouse/partner and adult

children.

      3.     If you have children or grandchildren, what are their ages and genders?

      4.     Where were you born and raised?

      5.     What is your educational background?

      6.     Have you ever served in the military? If so, please describe where, when,

and in what branch you serve(d).

      7.     What are your favorite hobbies or favorite activities? Do you belong to

any organizations, groups, or churches/synagogues/mosques/temples? If so, which

ones and what is the extent of your involvement?

      8.     What are your main sources of news?

      9.     Are there any magazines, newspapers, blogs, or Internet sites that you

read on a regular basis? If so, please describe.

      10.    What radio, television, or Internet programs, if any, do you listen to or

watch on a regular basis?

      11.    What podcasts, if any, do you listen to on a regular basis?

      12.    Do you regularly watch any law-related programs (factual or fictional

programs, such as Law & Order)? Which ones? Based on the programs you watch,

have you formed an opinion regarding the type of evidence necessary for the

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         CASE 0:22-cr-00223-NEB-DTS     Doc. 409    Filed 01/10/25     Page 3 of 7




government to satisfy its burden of proof? If so, can you put those opinions aside and

decide the case based only on the evidence presented in the courtroom during the

course of this trial?

                  Knowledge of the Case and Case Participants

         13.   Have you heard of this case before today? Is so, when and how? Have

you developed an opinion on the guilt or innocence of the defendants? If selected as a

juror in this case, will you be able to set aside what you may have learned through

other sources and decide the case based only on the evidence presented during the

trial?

         14.   Are you acquainted with the defendants Aimee Marie Bock, Abdikerm

Eidleh, Salim Said, Abdulkadir Nur Salah, Ahmed Omar-Hashim, Abdi Nur Salah,

Abdihakim Ali Ahmed, Ahmed Artan, Abdikadir Abshir, Abdinadir Abshir, Asad

Abshir, Hamdi Hussein Omar, Ahmed Ghedi, and Abdirahman Ahmed, or their

lawyers, Kenneth Udoibok, Surya Saxena, Michael Colich, Adrian Scott LaFavor-

Montez, and Brian Toder?

         15.   Are you acquainted with the lawyers for the United States,

Joseph Thompson, Matthew Ebert, Harry Jacobs, and Daniel Bobier, or the case

agents, Special Agents Jared Kary and Travis Wilmer, or Forensic Accountant

Pauline Roase, with the Federal Bureau of Investigation (FBI)?

         16.   Do you know any of the other prospective jurors?

         17.   Do you know any of the prospective witnesses? [Read witness list]

         18.   Are you acquainted with the Judge or her court staff?



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      CASE 0:22-cr-00223-NEB-DTS        Doc. 409    Filed 01/10/25    Page 4 of 7




                                Previous Jury Service

       19.    Have you previously served as a juror on a case? How many cases?

       20.    Was the prior case(s) a criminal or civil matter? What was the nature of

the case(s)? When did you serve? Was the prior case in federal or state court?

       21.    In the prior case, did you reach a verdict? What was the verdict? Were

you the foreperson?

       22.    Was there anything about your previous jury experience that would lead

you to feel that you may have some prejudices either for or against the United States

or the defendants in this case? Is there anything about that experience that would

affect your approach to this case?

    Previous Contact with the Legal System or Criminal Justice System

       23.    Have you, your relatives, close friends, or neighbors ever worked in law

enforcement, such as a police officer, deputy sheriff, or federal agent?

       24.    If so, is there anything about your experience or relationship with these

individuals that would affect your approach to this case?

       25.    Do you have any legal training? Have you taken any law-related courses

in school? If so, please describe.

       26.    Do you have any law enforcement training? If so, please describe.

       27.    Do you have any relatives, close friends, or neighbors who are lawyers,

judges, or are employed in another job within the legal profession?

       28.    Have you ever testified in court? Is there anything about that experience

that would affect your approach to this case?



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      CASE 0:22-cr-00223-NEB-DTS        Doc. 409    Filed 01/10/25   Page 5 of 7




      29.    Have you, your relatives, close friends, or neighbors had any type of

encounter with any law enforcement agency, including as the victim of a crime

(reported or unreported) or a witness to a crime? What was the nature of the

encounter? Were you satisfied with the manner in which the matter was resolved?

Why or why not?

      30.    Have you, your relatives, close friends, or neighbors ever been accused,

investigated, charged with, or convicted of a crime? What was the nature of the crime?

Do you believe that law enforcement officials and the court properly handled the

matter? Why or why not?

      31.    Have you, your relatives, close friends, or neighbors had any type of

encounter with the FBI? What was the nature of the encounter? Were you satisfied

with the manner in which the matter was resolved? Why or why not?

      32.    Some of the witnesses in this trial are likely to be law enforcement

officers. Do you have any prejudices either against or in favor of law enforcement

officers? If so, what are they?

      33.    Do you have any strong feelings, positive or negative, regarding the

United States Department of Justice or the United States Attorney’s Office?

                                   Case Specific

      34.    Have you, your relatives, or close friends ever worked for or heard of any

of the following entities: Feeding Our Future, Safari Restaurant, Cosmopolitan

Business Solutions, ASA Limited, Olive Management, Stigma-Free International,

Bet on Better Future, Horseed Management, or Tunyar Trading?



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      CASE 0:22-cr-00223-NEB-DTS        Doc. 409    Filed 01/10/25   Page 6 of 7




      35.    Have you ever heard of the Summer Food Service Program or the Child

and Adult Care Food Program? If so, what does that mean to you? Have you or anyone

you know participated in that program?

      36.    Did you, your relatives, or close friends receive meals from childcare

centers, daycare homes, schools, or after-school programs during the COVID-19

pandemic?

      37.    Have you, your relatives, or close friends ever owned a business?

      38.    Have you, your relatives, or close friends ever owned a restaurant?

      39.    Have you, your relatives, or close friends ever provided meals to children

enrolled in school?

      40.    Have you or any of your close friends or relatives ever participated in,

belonged to, or otherwise supported any organization that advocates for the

liberalization of laws prohibiting defrauding government-sponsored public federal

programs, including food subsidies? If not, do you agree with the beliefs of any such

organizations?

      41.    Have you, your relatives, close friends, or neighbors ever been a victim

of a wire fraud, money laundering, federal programs bribery, or passport

fraud-related crimes? Was the matter reported to law enforcement? Do you believe

that you were treated fairly by the criminal justice system? Is there anything about

your situation that would affect your approach to this case?

      42.    Have you, your relatives, close friends, or neighbors ever been accused,

investigated, charged with, or convicted of a wire fraud, money laundering, federal

programs bribery, or passport fraud-related crime? Was the matter reported to law

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      CASE 0:22-cr-00223-NEB-DTS          Doc. 409     Filed 01/10/25   Page 7 of 7




enforcement? Do you believe that you were treated fairly by the criminal justice

system? Is there anything about your situation that would affect your approach to

this case?

                 Following Instructions and Service as a Juror

       43.    If selected as a juror in this case, will you apply the law as given by the

Court, regardless of whether you agree or disagree with it?

       44.    Do you generally approve or disapprove of the operation of the criminal

justice system in the United States?

       45.    Do you believe that there are certain crimes that should be legalized? If

so, please explain your answer.

       46.    Do you have any moral, religious, or personal beliefs which would make

it difficult for you to be a fair and neutral juror in this case?

       47.    Do you have any difficulties understanding or communicating in the

English language?

       48.    Do you have any mental or physical conditions which would make it

difficult for you sit as a juror? Do you have a problem with your hearing, your

eyesight, with having to sit for most of the day, or any disability which would in any

manner prevent you from either hearing, seeing, or concentrating on the evidence

presented at trial?

       49.    Based upon the discussions you have heard during voir dire, is there any

reason why you feel you cannot be a fair and impartial juror in this case?




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