Defendant Aimee Bock's Motion in Limine No. 7 — United States v. Bock (D. Minn., Doc. 447)

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Defendant Aimee Bock's Motion in Limine No. 7, filed 01/13/25 as Doc. 447 in United States v. Aimee Marie Bock (1), Criminal No. 22-CR-223 (NEB/DTS), in the U.S. District Court for the District of Minnesota. Through counsel Kenneth Udoibok, Bock asks the court to bar the government from offering undisclosed expert opinions. She lists topics on which she says no expert was disclosed, including vendor profit and food costs under the food program, how many meals or children a site could serve, sponsors' legal obligations and the adequacy of Feeding Our Future's policies and procedures. She argues that these are matters of expert opinion that require disclosure before trial. She also reserves the right to file more motions in limine. The motion is dated January 13, 2025.

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      CASE 0:22-cr-00223-NEB-DTS          Doc. 447     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. 7
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. 7
                               (undisclosed expert testimony)

       The Government should be precluded from offering any undisclosed expert

opinions. For example, the Government did not disclose any experts or analysis about: (i)

how much profit vendors and distributors could reasonably anticipate making on the food

program; (ii) how much vendors and distributors can reasonably expect to pay for the

food that qualifies for reimbursable meals under the food program; (iii) how much

vendors and distributors can reasonably expect to incur in overhead costs to participate in
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      CASE 0:22-cr-00223-NEB-DTS          Doc. 447     Filed 01/13/25    Page 2 of 2




the food program; (iv) how many meals a site could reasonably expect to serve in a given

day; (v) how many children a site could reasonably expect to serve; (vi) the legal

responsibilities and obligations of sponsors; or (vii) the adequacy of Feeding Our Future’s

policies and procedures. Those are matters of expert opinion and beyond the common

experience of lay people and require disclosure before they can be admitted at trial.

The Government should be precluded from offering any opinion testimony not timely

disclosed.

                                                 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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