Court filing — United States v. Bock et al. (Feeding Our Future) (Dkt. 442, D. Minn.)

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Defendant Aimee Bock's Motion in Limine No. 2, Doc. 442, filed 01/13/25 in Case 0:22-cr-00223-NEB-DTS, United States of America v. Aimee Marie Bock (1), Criminal No: 22-CR-223 (NEB/DTS), in the U.S. District Court for the District of Minnesota. Through counsel, Bock asks the Court to preclude the government from introducing evidence or argument relating to alleged bribery. She argues that the bribery count failed to allege an agreement, a payment as a quid pro quo, or a payment made as part of an agreement to influence a corrupt official act, and states that the evidence shows she sold an asset for fair market value more than a year after Safari's participation in the food program. She asks for an order barring any evidence or argument that she agreed to receive a payment to influence an official act before it was taken, and the motion is dated January 13, 2025.

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      CASE 0:22-cr-00223-NEB-DTS            Doc. 442    Filed 01/13/25   Page 1 of 2




                           UNITED STATES DISTRICT COURT
                              DISTRICT OF MINNESOTA
                           CRIMINAL NO: 22-CR-223 (NEB/DTS)




United States of America,
              Plaintiff,                            DEFENDANT AIMEE BOCK’S
                                                     MOTION IN LIMINE NO. 2
vs.
Aimee Marie Bock (1),
              Defendant.




                                     INTRODUCTION

       Defendant Aimee Marie Bock (hereinafter “Defendant”), through her counsel,

Kenneth Udoibok, respectfully moves this Court to preclude the Government from

introducing certain evidence and making certain arguments. Bock reserves the right to

file additional motions in limini once she has reviewed the Government’s recently

produced witnesses and exhibits list.

                                MOTION IN LIMINE NO. 2
                           (No evidence relating to alleged bribery)

       As discussed in the motions to dismiss the bribery indictments under Snyder and

the related briefing (e.g. ECF Nos. 327, 331, 348, 367, 368), the Government’s bribery

count is fatally flawed because it failed to allege: (i) Bock reached an agreement with

anyone to corruptly influence an official act; (ii) that Bock receive a payment as a quid

pro quo for the commission of a corrupt official act; and (iii) that a payment was made as

part of an agreement to influence a corrupt official act. Instead, the undisputed evidence
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      CASE 0:22-cr-00223-NEB-DTS             Doc. 442   Filed 01/13/25   Page 2 of 2




shows that Bock sold an asset for the fair market value more than a year after Safari’s

participation in the food program.

       Because the Government’s indictment failed to allege any agreement,

understanding, promise, or arrangement involving Bock to receive a payment to corruptly

influence a decision on an official act before it was taken, the Government should be

precluded from presenting any such evidence at trial. For all the reasons discussed in

Motion in Limine No. 1, the presentation of such evidence or argument for the first time

at trial would be a fatal variance from the indictment, would be unfair surprise, and

would violate Bock’s right to fair notice.

       Bock seeks an order precluding the Government from introducing any evidence or

making any argument that she reached an agreement, understanding, promise, or

arrangement to receive a payment to corruptly influence a decision on an official act

before it was taken.

                                                   Respectfully Submitted

                                                   KENNETH UBONG UDOIBOK, P.A.

January 13, 2025                                   /s/Kenneth U. Udoibok
                                                    Kenneth U. Udoibok (#0262523)
                                                    Flour Exchange Building, Suite
                                                    5010 310 Fourth Avenue South
                                                    Minneapolis, MN 55415
                                                    Phone: (612) 808-6031
                                                    k@kenulaw.com

                                                   ATTORNEY FOR DEFENDANT
                                                   AIMEE MARIE BOCK




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