Court filing — United States v. Bock et al. (Feeding Our Future) (Dkt. 712, D. Minn.)

Summary

The Government's Trial Brief, Doc. 712, filed 07/14/25 in Case 0:22-cr-00223-NEB-DTS, United States of America v. Asad Mohamed Abshir (11) and Hamdi Hussein Omar (12), Criminal No. 22-223 (NEB/DTS), in the U.S. District Court for the District of Minnesota. The United States states that a grand jury returned a 61-count indictment against 14 defendants on September 13, 2022, and that Abshir and Omar are charged with conspiracy to commit wire fraud, wire fraud and conspiracy to commit money laundering. It describes the Federal Child Nutrition Program and the role of sponsors, and states that after the Covid-19 waivers Feeding Our Future grew from approximately $3.4 million in federal funds in 2019 to nearly $200 million in 2021. It alleges that the conspirators fraudulently misappropriated more than $45 million in program funds.

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     CASE 0:22-cr-00223-NEB-DTS         Doc. 712    Filed 07/14/25   Page 1 of 17




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

UNITED STATES OF AMERICA,

                     Plaintiff,

      v.                                         GOVERNMENT’S TRIAL BRIEF

 11. ASAD MOHAMED ABSHIR, and
 12. HAMDI HUSSEIN OMAR,

           Defendants.


      The United States of America, by and through its attorneys, Joseph H.

Thompson, Acting United States Attorney for the District of Minnesota, Matthew S.

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

respectfully submits the following trial brief in this matter.

I.    OVERVIEW

      On September 13, 2022, a grand jury returned a 61-count indictment charging

14 defendants—Aimee Bock, Abdikerm Eidleh, Salim Said, Abdulkadir Salah,

Ahmed Omar-Hashim, Abdi Salah, Abdihakim Ahmed, Ahmed Artan, Abdikadir

Mohamud, Abdinasir Abshir, Asad Mohamed Abshir, Hamdi Omar, Ahmed Ghedi,

and Abdirahman Ahmed—with a number of crimes, including: conspiracy to commit

wire fraud, in violation of 18 U.S.C. §§ 371 and 1343; wire fraud, in violation of 18

U.S.C. § 1343; conspiracy to commit federal programs bribery, in violation of 18

U.S.C. §§ 371 and 666; federal programs bribery, in violation of 18 U.S.C. § 666;

conspiracy to commit concealment money laundering, in violation of 18 U.S.C.

§ 1956(a) and (h); and money laundering, in violation of 18 U.S.C. § 1957.

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       In this trial, defendants Asad Abshir and Hamdi Omar are charged with

conspiracy to commit wire fraud, wire fraud, and conspiracy to commit money

laundering. Asad Abshir is additionally charged with money laundering.

       The indictment alleges that Asad Abshir, Hamdi Omar, and their co-

conspirators orchestrated and carried out a scheme that defrauded the Federal Child

Nutrition Program, a government aid program designed to provide free meals to

children in need. Asad Abshir, Hamdi Omar, and their co-conspirators exploited the

Covid-19 pandemic to obtain, misappropriate, and launder tens of millions of dollars

in program funds that were intended as reimbursements for the cost of serving meals

and food to children. In all, the conspirators fraudulently misappropriated more than

$45 million in Federal Child Nutrition Program funds.

II.    BACKGROUND

       A.    The Federal Child Nutrition Program

       The Federal Child Nutrition Program is a government program that ensures

children receive nutritious meals and snacks that adequately promote healthy

physical and education development. The program is run through the Food and

Nutrition Service, an agency of the United States Department of Agriculture

(“USDA”). That agency administers Federal Child Nutrition Programs, which

includes the Summer Food Service Program and Child and Adult Care Food Program

(together, the “Federal Child Nutrition Program”).

       The Summer Food Service Program (“SFSP”) is a federal program established

to ensure that children continue to receive nutritious meals when school is not in

session. The Summer Food Service Program reimburses non-profit organizations and

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other participating entities that serve free healthy meals and snacks to children and

teens in low-income areas. The Child and Adult Care Food Program (“CACFP”) is a

federal program that reimburses non-profit organizations and other participating

entities that serve healthy meals and snacks to children and adults at participating

childcare centers, daycare homes, and after-school programs.

      The Federal Child Nutrition Program operates throughout the United States.

The USDA’s Food and Nutrition Service administers the programs at the national

and regional levels by distributing federal funds to state governments, which provide

oversight for the Federal Child Nutrition Program. In Minnesota, the Minnesota

Department of Education (“MDE”) administers the Federal Child Nutrition Program.

      The Federal Child Nutrition Program operated through sponsors, which

oversaw the sites. Sponsors, like Feeding Our Future and Partners In Nutrition, are

responsible for monitoring the operation of the programs and submitting

reimbursement claims.

      Feeding Our Future and Partners In Nutrition were non-profit organizations

purportedly in the business of helping community partners participate in the Federal

Child Nutrition Program. Both were approved sponsors of the Federal Child

Nutrition Program, and prior to the onset of the Covid-19 pandemic, each operated

as a small non-profit that sponsored the participation of Minnesota daycares and

after school programs in the Federal Child Nutrition Program.

      Meals funded by the Federal Child Nutrition Program in Minnesota are served

at “sites.” Each site participating in the Federal Child Nutrition Program must be



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sponsored by an organization authorized to participate in the Federal Child Nutrition

Program. Sponsors are required to submit an application to MDE for each site.

Sponsors are responsible for monitoring each of their sites and preparing

reimbursement claims for their sites.

         Sponsors submit reimbursement claims to MDE on behalf of sites under their

sponsorship. The USDA provides federal reimbursement funds to MDE on a per-meal

basis. MDE provides the federal funds to the sponsoring agency, which in turn pays

the reimbursement funds to the sites under its sponsorship. The sponsoring agency

retains ten to fifteen percent of the funds as an administrative fee in exchange for

sponsoring the sites, submitting reimbursement claims, and disbursing the federal

funds.

         In exchange for sponsoring the sites’ fraudulent participation in the program,

sponsors received Federal Child Nutrition Program funds as administrative fees. In

2020 and 2021, Feeding Our Future and Partners In Nutrition received tens of

millions of dollars in Federal Child Nutrition Program funds in administrative fees.

Because the amount of administrative fees the sponsors received was based on the

amount of federal funds received by sites under its sponsorship, Feeding Our Future

and Partners In Nutrition received tens of millions of dollars in administrative fees

to which they were not entitled, due to its sponsorship and facilitation of fraudulent

sites participating in the program.




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      B.     The Covid-19 Waivers and Fraud

      The Covid-19 pandemic, including various stay-at-home orders and distance

learning, disrupted the operation of the Federal Child Nutrition Program. As a result,

the USDA issued waivers to the program requirements, allowing additional flexibility

for implementing the program and expanding the scope of the program. Following

the start of the Covid-19 pandemic and the resulting waivers, Feeding Our Future

and Partners In Nutrition sponsored an exponential number of new sites—more than

200 new Federal Child Nutrition Program sites.

      Historically, the Federal Child Nutrition Program provided meals to children

involved in education-based programs or activities. During the Covid-19 pandemic,

the USDA waived several of the standard requirements for participation in the

Federal Child Nutrition Program. Among other things, the USDA allowed for-profit

restaurants to participate in the program. It also allowed for food distribution to

children outside of educational programs. At the same time, the state government’s

stay-at-home order and telework policies made it more difficult to oversee the

program. These changes left the program vulnerable to fraud and abuse.

      Beginning in approximately April 2020—with the onset of the Covid-19

pandemic—Feeding Our Future and Partners In Nutrition dramatically increased

the number of sites under their sponsorship as well as the amount of Federal Child

Nutrition Program funds received by those sites.

      Feeding Our Future went from receiving and disbursing approximately $3.4

million in federal funds to sites under its sponsorship in 2019 to nearly $200 million



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in 2021. Partners In Nutrition went from receiving and disbursing approximately

$5.6 million in federal funds to sites under its sponsorship in 2019 to more than $200

million in 2021. In 2021, sites under the sponsorship of Partners In Nutrition claimed

to have served more than 80 million meals to children in Minnesota.

III.    SCHEME TO DEFRAUD THE FEDERAL CHILD NUTRITION PROGRAM

        A.    Feeding Our Future

        Co-conspirator Aimee Bock was the founder and executive director of Feeding

Our Future, a non-profit organization in the business of helping community partners

participate in the Federal Child Nutrition Program and related federal programs.

Feeding Our Future was an approved sponsor of the Federal Child Nutrition

Program. As a sponsor, Feeding Our Future was responsible for submitting site

applications to MDE for approval, monitoring active sites, submitting claims for

reimbursement from MDE, and disbursing federal funds to sites under its

sponsorship. Feeding Our Future received payment from MDE and kept an

administrative fee—typically 10 to 15 percent. Feeding Our Future provided the

remaining funds directly to sites.

        During the Covid-19 pandemic, Bock and her company recruited individuals

and entities to open more than 200 Federal Child Nutrition Program sites throughout

the state of Minnesota. The sites fraudulently claimed to be serving meals to

thousands of children a day within just days or weeks of being formed and despite

having few, if any, staff and little to no experience serving this volume of meals.

        The conspirators, including defendants Asad Abshir and Hamdi Omar,

collectively claimed to be serving meals to tens of thousands of children each day

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throughout the State of Minnesota, for which they fraudulently claimed and received

millions of dollars in Federal Child Nutrition Program funds. For example, co-

conspirators Salim Said and Abdulkadir Salah owned and operated Safari

Restaurant. In April 2020, during the early days of the Covid-19 pandemic, Safari

Restaurant enrolled in the Federal Child Nutrition Program under the sponsorship

of Feeding Our Future. In all, the owners of Safari Restaurant claimed to have served

more than 3.9 million meals to children between April 2020 and November 2021.

      Safari Restaurant also operated as a vendor purporting to deliver food and

meals to be served at other Federal Child Nutrition Program sites created by co-

conspirators throughout the state of Minnesota. Safari Restaurant claimed to have

provided more than 2.2 million meals to other Federal Child Nutrition Program sites

involved in the scheme. In all, as part of the scheme to defraud, Safari Restaurant

received more than $16 million in Federal Child Nutrition Program funds in 2020

and 2021. Said and Abdulkadir Salah sent much of this money to their co-conspirators

via shell companies created and used to receive and launder the proceeds of the

fraudulent scheme.

      Co-conspirator Salim Said operated another site under the sponsorship of

Feeding Our Future. Said was one of the creators of ASA Limited LLC in

September 2020. Said, along with two partners (co-conspirators Abdihakim Ahmed

and Ahmed Ghedi), was an equal one-third owner in the company. ASA Limited

opened a federal child nutrition program site in St. Paul, Minnesota, under the

sponsorship of Feeding Our Future at the Gurey Deli, a small market located in a



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strip mall in St. Paul. Within just three weeks of creating the ASA Limited site, the

co-conspirators fraudulently claimed to be serving meals to 2,000 or 3,000 children

each day, seven days a week. Defendant Hamdi Omar was the owner of the Gurey

Deli (where her co-conspirators had the fraudulent ASA Limited food site):




      B.     Stigma-Free International

      By October 2020, MDE became concerned about the drastic increase in meal

claims by sites under the sponsorship of Feeding Our Future. In response to MDE’s

well-founded concerns, Bock tried to cover up the fraud by diverting attention away

from Feeding Our Future and the scheme by blaming MDE when it attempted to

perform legitimate oversight. MDE regularly raised questions about the number of

sites and amount of meal claims being submitted by Feeding Our Future on behalf of



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sites under its sponsorship. Bock knew that MDE’s concerns were valid, and that

little of the Federal Child Nutrition Program funds disbursed by Feeding Our Future

were used to feed children. Bock also knew that if MDE discovered the true nature of

the fraud, the flow of federal funds to Feeding Our Future and sites under its

sponsorship would stop.

      Due to these concerns, MDE announced that the Federal Child Nutrition

Program no longer allowed restaurants and other for-profit companies to enroll as

sites. MDE explained that restaurants would only be allowed to participate as meal

vendors providing food. MDE further announced that any restaurants enrolled as

distribution sites would be closed as of October 31, 2020.

      Shortly after MDE disallowed for-profit restaurants, some of the conspirators

of Hamdi Omar and Asad Abshir, including Ahmed Artan, obtained a non-profit

entity, Stigma-Free International, for use in carrying out the fraud. They

immediately used their new non-profit to open a number of new Federal Child

Nutrition Program sites. Other co-conspirators created additional shell companies to

serve as for-profit meal vendor companies purporting to provide the meals to be

served to children at these sites. Together, the defendants claimed to be serving meals

to tens of thousands of children each day throughout the state of Minnesota, for which

they fraudulently claimed and received millions of dollars in Federal Child Nutrition

Program funds.




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         C.    Mankato and Waite Park:        Asad Abshir and Hamdi Omar’s
               Fraudulent Sites

         In October 2020, Asad Abshir opened up one of these fraudulent Stigma-Free

sites in Mankato along with one of his co-conspirators, his brother Abdinasir Abshir.

Their Stigma-Free Mankato site purported to serve meals to 3,000 children a day,

seven days a week. Asad Abshir claimed to be operating the Stigma-Free Mankato

site out of J’s Sambusa, a small restaurant in North Mankato.




         The Abshirs also created a shell company called Horseed Management that

purported to serve as a meal vendor providing meals to be served at the site. During

the one-year period from November 2020 to November 2021, Asad Abshir and his co-

conspirators claimed to have served more than 1.6 million meals at the Stigma-Free

Mankato site, claims which were based upon fraudulent meal count sheets,

attendance rosters, and invoices.      Based on these fraudulent claims, the co-

conspirators received approximately $5 million in Federal Child Nutrition Program

funds.


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      Like her co-defendant, Asad Abshir, Hamdi Omar also opened up one of these

Stigma-Free sites. Hamdi Omar’s site—which operated out of the Green Market, a

small market and grocery store located in a strip mall in Waite Park, Minnesota—

fraudulently claimed to serve 2,000 children a day, seven days a week.




      Hamdi Omar signed and submitted many of the fraudulent meal counts for the

Stigma Free Waite Park site.




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      Similar to the Abshirs’ company, “Horseed Management,” the conspirators

created a company called “Feeding Our Youth” that purported to serve as a meal

vendor for Hamdi Omar’s fraudulent Stigma-Free Waite Park site. Between April

and November 2021, Hamdi Omar and her co-conspirators claimed to have served

more than 500,000 meals at the Stigma-Free Waite Park site with Feeding Our Youth

as the fraudulent vendor. Based on these claims, the co-conspirators received more

than $1 million in Federal Child Nutrition Program reimbursements.

             1.     Fake Meal Counts and Rosters

      The trial evidence will reveal that Asad Abshir, Hamdi Omar, and their

conspirators used and submitted sham meal count sheets and phony attendance

rosters purporting to list the names of children who received meals at their sites. But

these lists did not contain the names of real children. Indeed, school district records


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and trial testimony will establish that the vast majority of the falsified names on

these rosters appear nowhere in the official school district enrollment records of

multiple school districts where the defendants professed to serve millions of meals.

Some of the roster spreadsheets submitted for the defendants’ sites sent even

contained an imbedded formula that inserted a random number between 7 and 17 in

the age column of the spreadsheet.




      One of the fake rosters submitted in support of a fraudulent claim for Asad

Abshir’s Stigma-Free Mankato site purported to list the names and ages of

approximately 2,032 children who attended and received meals at their “after school




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program” in Mankato. However, almost none of the names on the roster matched the

names of students who attended school in the Mankato Area Public School district.

      In support of their fraudulent claims, Asad Abshir, Hamdi Omar, and their co-

conspirators also used and submitted fraudulent invoices purporting to show their

purchase of food to feed children.

      D.     The Money Laundering

      In all, the defendants received more than $47 million in Federal Child

Nutrition Program funds between April 2020 through January 2022. These federal

funds were received by the defendants’ companies from Feeding Our Future.

      Asad Abshir, Hamdi Omar, and their co-conspirators created and used an

array of entities and shell companies to receive, launder, and distribute their

fraudulent proceeds. Some of these companies purported to be meal vendors

providing meals and food to program sites, but in reality, the companies were shells

created to disguise the source and ownership of the fraud proceeds. The defendants

transferred millions of dollars between their shell companies to conceal the source of

the funds, and then used the shell companies to purchase millions of dollars’ worth of

real estate, cars, and fund their lifestyles and personal spending.

             1.     The “Vendor” Companies

      Asad Abshir, Hamdi Omar, and their co-conspirators used “vendor”

companies—ostensibly in the business of providing food for distribution—to launder

their fraudulent proceeds. In reality, the vendor companies provided only a fraction

of the food that their sites claimed to be serving and acted a source to conceal the

source of the fraud proceeds.

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      As the financial records will establish, Stigma-Free and its various related

entities, in turn, paid the bulk of these funds over to the vendor companies,

purportedly to pay for food distribution at its various sites. Instead, the defendants

used the vendor companies to receive and launder the Federal Child Nutrition

Program funds while concealing the money as payments for the purchase of food.

      Hamdi Omar created a company called Feeding Our Youth LLC, ostensibly to

run the Stigma-Free Waite Park site. Feeding Our Youth purported to be a food

vendor company that provided food and meals to be served at the Stigma-Free Waite

Park site. In reality, she used Feeding Our Youth as a shell company designed to

obtain and launder fraud proceeds. In all, she deposited more than $1 million in

Federal Child Nutrition Program funds into Feeding Our Youth bank accounts.

      Similarly, Asad Abshir, together with his brother and co-conspirator,

Abdinasir Abshir, created Horseed Management LLC to carry out the fraudulent

scheme. Horseed Management purported to be a food vendor company that provided

food and meals to be served at the Stigma-Free Mankato site. In reality, the Abshirs

used Horseed Management as a shell company to obtain and launder fraud proceeds.

In all, Asad Abshir and his brother deposited more than $5 million in Federal Child

Nutrition Program funds into Horseed Management bank accounts.

             2.    The Shell Companies

      The defendants also created and used an array of other companies to conceal

and launder their fraud proceeds. For her part, in September 2020, Hamdi Omar

registered Omar Management Corporation, which she used as a shell company to

receive and launder her cut of the fraud proceeds. For his part, in January 2021,

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Asad Abshir registered Santana LLC, a shell company he similarly used to receive

and launder fraud proceeds. In 2021, Asad Abshir deposited more than $750,000 in

Federal Child Nutrition Program funds into Santana LLC bank accounts. He used

this money to, among other things, pay for personal spending, international travel,

and to purchase a 2022 GMC Sierra 1500 pickup truck for approximately $78,000.

IV.    POTENTIAL LEGAL AND EVIDENTIARY ISSUES

       A.    Summary Testimony and Charts

       The United States intends to call law enforcement agents to testify as

summary witnesses in its case-in-chief. “The testimony of a summary witness may be

received so long as she bases her summary on evidence received in the case and is

available for cross-examination.” United States v. Ellefsen, 655 F.3d 769, 780

(8th Cir. 2011) (quoting United States v. King, 616 F.2d 1034, 1041 (8th Cir. 1980)).

       In addition, because this case involves voluminous documentary evidence,

including school enrollment records, bank records, and other financial documents, the

government intends to offer summary charts into evidence in order to assist the jury.

Summary charts are properly admitted when (1) the charts fairly summarize

voluminous trial evidence, (2) they assist the jury in understanding testimony

already introduced, and (3) the witness who prepared the charts is subject to cross-

examination with all documents used to prepare the summary. United States v.

Spires, 628 F.3d 1049, 1052-53 (8th Cir. 2011) (citing Fed. R. Evid. 1006). “Also,

summaries may include assumptions and conclusions so long as they are ‘based upon

evidence in the record.’” Id. at 1053.




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      B.     Stipulations    and    Self-Authentication               Pursuant        to
             Federal Rule of Evidence 902

      The parties have discussed foundational stipulations with respect to certain

business records that will obviate the need to call custodians of records as witnesses

at trial. While the parties are still working through the details of these stipulations,

the government is hopeful that the parties will be able to put this stipulation on the

record at the pretrial conference.

      With respect to any business records for which the defendants are unwilling to

stipulate with respect to foundation, the government has and will be providing notice

to defense counsel of its intent to offer these business records pursuant to the

self-authentication provisions of Federal Rules of Evidence 803(6) and 902(11). The

records have and will be identified with particularity to the defense in the

government’s Federal Rule of Evidence 902 notices, and they have all previously been

provided to the defense in the government’s Rule 16 disclosures. Certifications for

these records have also been made available for the defendant’s review. The

government will also seek to admit certain public records pursuant to the self-

authentication provisions of Federal Rules of Evidence 803(8) and 902(1), (2), and (4).

Dated: July 14, 2025                           Respectfully Submitted,

                                               JOSEPH H. THOMPSON
                                               Acting United States Attorney

                                               /s/ Matthew S. Ebert
                                        BY:
                                               MATTHEW S. EBERT
                                               HARRY M. JACOBS
                                               DANIEL W. BOBIER
                                               Assistant United States Attorneys


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