Plea Agreement as to Ahmed Abdullahi Ghedi — USA v. Bock et al (Dkt. 689, D. Minn.)

Summary

The Plea Agreement and Sentencing Stipulations of Ahmed Abdullahi Ghedi in United States v. Ghedi, Criminal No. 22-223(13) (NEB/DTS), in the U.S. District Court for the District of Minnesota, filed June 26, 2025 as Doc. 689. The defendant agrees to plead guilty to Count 12 of the Indictment, charging wire fraud under Title 18, United States Code, Section 1343, and to a count charging money laundering under Section 1957. In the factual basis the defendant admits participating, from in or about September 2020 through in or about January 2022, in a scheme to defraud the federal child nutrition program through the ASA Limited site sponsored by Feeding Our Future. It states that the defendant deposited more than $2 million in program funds into AG Limited LLC accounts and that the conspirators caused a loss of approximately $7.2 million.

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CASE 0:22-cr-00223-NEB-DTS Doc. 689 _ Filed 06/26/25 Page1of15

UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
Criminal No. 22-223(13) (NEB/DTS)

UNITED STATES OF AMERICA,

Plaintiff, PLEA AGREEMENT AND
SENTENCING STIPULATIONS

Vv.
AHMED ABDULLAHI GHEDI,
Defendant.

The United States of America and the defendant Ahmed Abdullahi Ghedi agree
to resolve this case on the terms and conditions that follow. This plea agreement binds
only the defendant and the United States Attorney's Office for the District of
Minnesota. This agreement does not bind any other United States Attorney’s Office
or any other federal or state agency.

1. Charges. The defendant agrees to plead guilty to Count 12 of the
Indictment, which charges the defendant with wire fraud, in violation of Title 18,
United States Code, Section 1343, and Count 48, which charges the defendant with
money laundering, in violation of Title 18, United States Code, Section 1957. The
defendant fully understands the nature and elements of the crimes with which he has
been charged. At the time of sentencing, the United States agrees to move to dismiss
the remaining charges against him in the Indictment.

2. Factual Basis. The defendant is pleading guilty because he is in fact

guilty of Count 12 and Count 43 of the Indictment. In pleading guilty, the defendant

admits the following facts and that those facts establish his guilt beyond a reasonable

SCANNED
JUN 27 2025
US. DISTRICT COURT MPLS
CASE 0:22-cr-00223-NEB-DTS Doc. 689 _ Filed 06/26/25 Page 2 of 15

doubt and constitute relevant conduct pursuant to the United States Sentencing |
Guidelines:

From in or about September 2020 through in or about January 2022, the
defendant knowingly participated in a scheme to defraud the federal child nutrition
program, a program designed to provide free meals to children in need. The defendant
and his co-conspirators obtained, misappropriated, and laundered millions of dollars
in program funds that were intended as reimbursements for the cost of serving meals
to children. The defendants exploited changes in the program intended to ensure
underserved children received adequate nutrition during the Covid-19 pandemic.
Rather than feed children, the defendants took advantage of the Covid-19 pandemic—
and the resulting program changes—to enrich themselves by fraudulently
misappropriating millions of dollars in federal child nutrition program funds.

As part of the scheme, on or about September 4, 2020, a co-conspirator
registered ASA Limited LLC with the Minnesota Secretary of State. Four days later,
a co-conspirator applied for ASA Limited to operate a purported food site in the
Federal Children Nutrition Program under the sponsorship of Feeding Our Future at
the Gurey Deli, a small market located in a strip mall in St. Paul (the “ASA Limited
site”). Within just three weeks of creating the ASA Limited site, the defendant and
his co-conspirators fraudulently claimed to be serving meals to 2,000 or 3,000 children
each day, seven days a week.

During the one-year period from September 2020 to September 2021, the

defendant and his co-conspirators claimed to have served more than 1.6 million meals
CASE 0:22-cr-00223-NEB-DTS Doc. 689 _ Filed 06/26/25 Page 3of15

at the ASA Limited site. In support of these claims, the defendant and his co-
conspirators prepared and submitted inflated meal counts, fabricated invoices, and
fake attendance rosters of purported children. For example, as alleged in Count 12
of the indictment, on November 4, 2021, one of the defendant’s co-conspirators (and
co-owner of ASA Limited) emailed Aimee Bock—the Executive Director of Feeding
Our Future— fraudulent meal counts and a fake attendance roster, which traveled
interstate.

The defendant also paid approximately $5,000 in kickbacks from ASA Limited
LLC to Abdikerm Eidleh, the Feeding Our Future employee who served as the site
support manager for the ASA Limited site. ASA Limited, of which the defendant was
a co-owner, paid Eidleh an additional $49,000. These payments were made to entities
controlled by Eidleh, in order to disguise the nature of the kickback payments and to
make them appear legitimate. Feeding Our Future received more than $400,000 in
administrative fees for sponsoring the ASA Limited site’s fraudulent participation in
the program.

Rather than use fraudulently obtained money to serve meals or feed children,
the defendant and his conspirators fraudulently misappropriated much of it. On or
about December 14, 2020, the defendant created AG Limited LLC. The defendant
used AG Limited as a shell company to hide and disguise the source and ownership
of his portion of the fraud proceeds. Between December 2020 and November 2021, the
defendant deposited more than $2 million in Federal Child Nutrition Program funds

into AG Limited LLC bank accounts. The defendant used this money to purchase
CASE 0:22-cr-00223-NEB-DTS Doc. 689 _ Filed 06/26/25 Page 4of15

more than $245,000 in motor vehicles and to fund more than $200,000 in credit card
spending. The defendant also transferred approximately $560,000 in Federal Child
Nutrition Program funds to Cosmopolitan Business Properties LLC—a shell he co-
owned with other co-conspirators—toward the purchase of a mansion and adjoining
property located at 2722 and 2742 Park Avenue South in Minneapolis.

In addition, as alleged in Count 43 of the indictment, on or about March 3,
2021, in the State and District of Minnesota and elsewhere, the defendant knowingly
engaged in a monetary transaction by, through, or to a financial institution, affecting
interstate or foreign commerce, in criminally derived property of a value greater than
$10,000, in violation of Title 18, United States Code, Section 1957, namely, the
payment of $114,887 in Federal Child Nutrition Program funds to Gretna Auto Outlet
for the purchase of a 2021 Cadillac Escalade.

Ultimately, based on fraudulent claims throughout the conspiracy, the
defendant and his co-conspirators caused a loss of approximately $7.2 million to the
Federal Child Nutrition Program reimbursements for meals purportedly served to

children.

3. Waiver of Pretrial Motions. The defendant understands and agrees

that he has certain rights to file pre-trial motions in this case. As part of the plea
agreement, and based upon concessions of the United States within this plea
agreement, the defendant knowingly, willingly, and voluntarily gives up the right to
file any pre-trial motions in this case. The defendant agrees that, by pleading guilty,

he is withdrawing any motions previously filed.
CASE 0:22-cr-00223-NEB-DTS Doc. 689 _ Filed 06/26/25 Page5of15

4. Waiver of Constitutional Trial Rights. The defendant understands

that he has the right to go to trial. At trial, the defendant would be presumed
innocent, have the right to trial by jury or, with the consent of the United States and
of the Court, to trial by the Court, the right to the assistance of counsel, the right to
confront and cross-examine adverse witnesses, the right to subpoena witnesses to
testify for the defense, the right to testify and present evidence, and the right to be
protected from compelled self-incrimination. The defendant understands that he has
the right to an attorney at every stage of these proceedings and, if necessary, one will
be appointed to represent him. The defendant understands that he has the right to
persist in a plea of not guilty and, if he does so, he would have the right to a public
and speedy trial. By pleading guilty, the defendant knowingly, willingly, and
voluntarily waives each of these trial rights, except the right to counsel. The
defendant understands that a guilty plea is a complete and final admission of guilt
and, if the Court accepts the guilty plea, the Court will adjudge the defendant guilty
without a trial.

5. Additional Consequences. The defendant understands that as a

result of his conviction, he could experience additional consequences, such as the loss
of the right to carry firearms, the right to vote, and the right to hold public office. If
the defendant is not a United States citizen, as a result of a plea of guilty, the
defendant may be removed from the United States, denied citizenship, and/or denied
admission to the United States in the future. The defendant has discussed with his

attorney the punishments and consequences of pleading guilty, understands that not
CASE 0:22-cr-00223-NEB-DTS Doc. 689 _ Filed 06/26/25 Page 6of15

all of the consequences can be predicted or foreseen, and still wants to plead guilty in

this case.

6. Statutory Penalties. The defendant understands that Count 12 of the

Indictment, charging wire fraud in violation of 18 U.S.C. § 1348, is a felony offense
that carries the following statutory penalties:

a. a maximum term of imprisonment of 20 years in prison;

b. a supervised release term of up to three years;

C. a fine of up to $250,000, or twice the gross gain or loss from the
offense, whichever is greater;

d. assessment to the defendant of the costs of prosecution as
authorized by 28 U.S.C. §§ 1918(b) and 1920; and

e. a mandatory special assessment of $100 under 18 U.S.C.
§ 3013(a)(2)(A).

The defendant understands that Count 43 of the Indictment, charging money
laundering in violation of 18 U.S.C. § 1957, is a felony offense that carries the
following statutory penalties:

a. a maximum of 10 years in prison;

b. a supervised release term up to a maximum
supervised release term of 3 years;

c. a maximum fine of $250,000, or twice amount of the criminally
derived property, whichever is greatest;

d. restitution to victims as agreed to by the parties in this
agreement;
e. a mandatory special assessment of $100 under 18 U.S.C.

§ 3013(a)(2)(A);
CASE 0:22-cr-00223-NEB-DTS Doc. 689 _ Filed 06/26/25 Page 7 of 15

7. Revocation of Supervised Release. The defendant understands that

if he were to violate any supervised release condition while on supervised release, the
Court could revoke his supervised release, and the defendant could be sentenced to
an additional term of imprisonment up to the statutory maximum set forth in 18
U.S.C. § 3583(e)(3). See U.S.S.G. §§ 7B1.4, 7B1.5. The defendant also understands
that as part of any revocation, the Court may include a requirement that he be placed |
on an additional term of supervised release after imprisonment, as set forth in 18
U.S.C. § 3583(h).

8. Guidelines Calculations. The parties acknowledge that the defendant

will be sentenced in accordance with 18 U.S.C. § 3551, et seq. Nothing in this plea
agreement should be construed to limit the parties from presenting any and all
relevant evidence to the Court at sentencing. The parties also acknowledge that the
Court will consider the United States Sentencing Guidelines in determining the
appropriate sentence and stipulate to the following guideline calculations:

a. Base Offense Level. The parties agree that for Count 12 the base
offense level is 7. U.S.S.G. § 2B1.1(a)(1).

The parties agree that for Count 43 the base offense level is the
offense level for the underlying offense from which the laundered
funds were derived, pursuant to U.S.S.G. § 2S1.1(a)(1). Therefore,
the base offense level for Count 43 is 7 as calculated under Count
12.

b. Specific Offense Characteristics. The parties agree that for Count
12 an 18-level enhancement applies pursuant to Guidelines
§ 2B1.1(b)(1)(J) because the loss was more than $3.5 million but
not more than $9.5 million. The parties agree that the offense
level should be increased by 2 levels because the offense involved
conduct described in 18 U.S.C. § 1040 (Fraud in Connection with
a Major Disaster or Emergency Benefits). The parties agree that
no other specific offense adjustments apply.

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CASE 0:22-cr-00223-NEB-DTS Doc. 689 _ Filed 06/26/25 Page 8of15

The parties agree that for Count 43 a one-level enhancement
applies pursuant to U.S.S.G. § 2S1.1(b)(2)(A) because defendant
was convicted under 18 U.S.C. § 1957.

C. Chapter 3 Adjustments. The defendant reserves the right to
argue that he is eligible for a two-level reduction because he was
a minor participant in any criminal activity pursuant to U.S.S.G.
§ 3B1.2(b). The government disagrees that the defendant is
eligible for this two-level reduction.

The parties agree that Count 12 and Count 43 of the Indictment
are grouped together into a single group because both counts
embody conduct that is treated as a specific offense characteristic
in the guideline applicable to the other count. U.S.S.G. § 3D1.2(c).
Therefore, the offense level applicable to the group will be the
highest offense level of the counts in the group, which would be
28 (as the government believes) or 26 (as the defendant reserves
the right to argue). The parties agree that no Chapter 3
adjustments apply.

d. Acceptance of Responsibility. The government agrees to
recommend that the defendant receive a 2-level reduction for
acceptance of responsibility pursuant to U.S.S.G. § 3E1.1(a). As
the defendant has timely notified the government of his intention
to enter a plea of guilty, the government agrees to recommend
that the defendant receive an additional 1-level reduction
pursuant to U.S.S.G. § 3E1.1(b). Whether these reductions will be
imposed shall be determined by the Court in its discretion.
However, the defendant understands and agrees that the
government’s recommendations are conditioned upon the
following: (1) the defendant testifies truthfully during the change
of plea and sentencing hearings; (2) the defendant provides full,
complete and truthful information to the United States Probation
Office in the pre-sentence investigation; and (3) the defendant
engages in no conduct inconsistent with acceptance of
responsibility before the time of sentencing, including frivolously
denying facts in the Presentence Report. Nothing in this
agreement limits the right of the government, pursuant to
U.S.S.G. § 3E1.1 and/or § 3C1.1 to seek denial of a reduction for
acceptance of responsibility or an enhancement for obstruction of
justice should the defendant engage in any conduct inconsistent
with acceptance of responsibility, including moving to withdraw
his guilty plea after it is entered.
CASE 0:22-cr-00223-NEB-DTS Doc. 689 _ Filed 06/26/25 Page 9of15

e. Criminal History Category. The parties believe that, at the time
of sentencing, the defendant will fall into Criminal History
Category I. U.S.S.G. § .4A1.1. This does not constitute a
stipulation, but a belief based on an assessment of the
information currently known. The defendant’s actual criminal
history and related status will be determined by the Court based
on the information presented in the Presentence Report and by
the parties at the time of sentencing. The defendant understands
that if the presentence investigation reveals any prior adult or
juvenile sentence which should be included within his criminal
history under the U.S. Sentencing Guidelines, the defendant will
be sentenced based on his true criminal history category, and he
will not be permitted to withdraw from this Plea Agreement.
U.S.S.G. § 4A1.1.

f. Zero-Point Offender Adjustment. The parties believe that the
defendant has zero criminal-history points and no disqualifying
conduct, and as such, the parties believe that, at the time of
sentencing, the defendant will defendant qualify for a 2-level
adjustment under U.S.S.G. § 4C1.1. This does not constitute a
stipulation, but a belief based on an assessment of the
information currently known. The defendant’s actual criminal
history and related status will be determined by the Court based
on the information presented in the Presentence Report and by
the parties at the time of sentencing. The defendant understands
that if the presentence investigation reveals any conduct in is
criminal history under the U.S. Sentencing Guidelines renders
him ineligible for a 2-level adjustment under U.S.S.G. § 4C1.1,
the defendant will be sentenced based on his true criminal history
category, and he will not be permitted to withdraw from this Plea
Agreement. U.S.S.G. § 4A1.1.

ge, Guidelines Range. If the adjusted offense level is 28, and the
criminal history category is I, the Sentencing Guidelines range is
46 -57 months of imprisonment. If, as the defendant reserves the
right to argue, the adjusted offense level is 21, and the criminal
history category is I, the Sentencing Guidelines range is 37 - 46
months of imprisonment.

h. Fine Range. If the adjusted offense level is 23, the Sentencing
Guidelines fine range is $20,000 to $200,000. U.S.S.G.
§ 5E1.2(c)(3). If the adjusted offense level is 21, the Sentencing
Guidelines fine range is $15,000 to $150,000. U.S.S.G.
§ 5E1.2(c)(8).
CASE 0:22-cr-00223-NEB-DTS Doc. 689 _ Filed 06/26/25 Page 10 of 15

9. Discretion of the Court. The foregoing stipulations are binding on

the parties, but do not bind the Court. The parties understand that the Sentencing
Guidelines are advisory and their application is a matter that falls solely within the
Court’s discretion. The Court may make its own determination regarding the
applicable guideline factors and the applicable criminal history category. The Court
may also depart from the applicable Guidelines. If the Court determines that the
applicable guideline calculations or the defendant’s criminal history category are
different from that stated above, such a determination shall not provide a basis for
the parties to withdraw from this agreement, and the defendant will be sentenced
pursuant to the Court’s determinations.

10. Agreements as to Sentencing Recommendation. The parties are

free to recommend whatever sentence they deem appropriate. The parties reserve the
right to make a motion for departures from the applicable Guidelines range pursuant
to 18 U.S.C. § 3553(a), to oppose any such motion made by the opposing party, and to
argue for a sentence outside the applicable Guidelines range. If the Court does not
accept the sentencing recommendation of the parties, the defendant will have no right

to withdraw his guilty plea.

11. Special Assessment. The Sentencing Guidelines require payment of a

special assessment in the amount of $100 for each felony count of which the defendant
is convicted. U.S.S.G. § 5E1.3. The defendant agrees that the special assessment is

due and payable at the time of sentencing.

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CASE 0:22-cr-00223-NEB-DTS Doc. 689 _ Filed 06/26/25 Page11of15

12. Restitution Agreement. The defendant understands and agrees that

the Mandatory Victim Restitution Act, 18 U.S.C. § 836638A, applies and that the Court
is required to order the defendant to make restitution to the victims of his crime. The
defendant understands and agrees the Court may order the defendant to make
restitution to any victim of the scheme regardless of whether the victim was named
in the Indictment. The defendant agrees that he owes restitution in the amount of
$2,862,451.

13. Disclosure of Assets. The defendant will fully and completely disclose

to the United States Attorney’s Office the existence and location of any assets in
which the Defendant has any right, title, or interest, or over which the defendant
exercises control, directly or indirectly, including those assets held by a spouse,
nominee or other third party, or any business owned or controlled by the defendant.
The defendant agrees to assist the United States in identifying, locating, returning,
and transferring assets for use in payment of fines and/or forfeiture ordered by the
Court. The Defendant agrees to complete a financial statement within two weeks of
the entry of his guilty plea. The defendant further agrees to execute any releases that
may be necessary for the United States to obtain information concerning the
defendant’s assets and expressly authorizes the United States to obtain a credit
report on the defendant to evaluate his ability to satisfy financial obligations imposed
by the Court. If requested by the United States, the defendant agrees to submit to

one or more asset interviews or depositions under oath.

11
CASE 0:22-cr-00223-NEB-DTS Doc. 689 _ Filed 06/26/25 Page 12 of15

14. Forfeiture. The defendant agrees to forfeit to the United States,
pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c), all property, real or
personal, which constitutes or is derived from proceeds traceable to wire fraud, as
charged in Count 12 of the Indictment, including but not limited to:

(1) a 2021 Jeep Grand Cherokee, VIN: 1C4RJFN96MC659204;

(2) The real property located at 2722 Park Avenue South, Minneapolis,
Minnesota;

(3) The real property located at 2742 Park Avenue South, Minneapolis,
Minnesota;

(4) A Palmetto State Armory PA-15 multi caliber rifle, serial number
SCB003791, and ammunition and accessories seized therewith, seized
from 2722 Park Avenue, Minneapolis, Minnesota on January 20, 2022;
(5) An Anderson Manufacturing AM-15 multi caliber rifle, serial number
20113938, and ammunition and accessories seized therewith, seized
from 2722 Park Avenue, Minneapolis, Minnesota on January 20, 2022;

and

(6) $1,231.07 seized from Bell Bank, account No. 6521110434, in the name
of ASA Limited LLC.

The Defendant agrees that the United States may, at its option, forfeit the
property through civil, criminal or administrative proceedings, waives any deadline
or statute of limitations for the initiation of any such proceedings, and abandons any
interest he may have in the property. The Defendant waives all statutory and
constitutional defenses to the forfeiture and waives any right to contest or challenge
(including direct appeal, habeas corpus, or any other means) such forfeiture, directly
or through any company he owns or controls, on any grounds. To the extent the

Defendant has requested remission or mediation of the forfeiture of the property, he

12
CASE 0:22-cr-00223-NEB-DTS Doc. 689 _ Filed 06/26/25 Page 13 of 15

withdraws any such requests. The Defendant agrees not to assist any third party in|
challenging the forfeiture of the property.

The Defendant consents to the entry of a money judgment forfeiture in the
amount of $2,862,451, which represents the amount of proceeds he obtained from the
wire fraud scheme alleged in Count 12 of the Indictment. The defendant will receive
a credit against the money judgment forfeiture for the net value of all property that
is forfeited from him in this matter. The United States reserves the right to seek
forfeiture of substitute assets and any additional directly forfeitable property.

15. Waivers of Appeal and Collateral Attack. The parties hereby waive

the right to appeal any non-jurisdictional issues. This appeal waiver includes, but is
not limited to: the defendant’s waiver of the right to appeal guilt or innocence, any
issues relating to the negotiation, taking or acceptance of the guilty plea, the sentence
imposed or any issues that relate to the calculation of the Guidelines range, the
supervised-release term and conditions imposed, any restitution obligations, and the
constitutionality of the statutes to which the defendant is pleading guilty. The
parties agree, however, that excluded from this waiver is an appeal by defendant of
the substantive reasonableness of a term of imprisonment above the top of the
Guidelines range, and an appeal by the government of the substantive
reasonableness of a term of imprisonment below the bottom of the Guidelines range.

The defendant also waives the right to collaterally attack his conviction and
sentence under 28 U.S.C. § 2255 except based upon a claim of ineffective assistance

of counsel. This collateral-review waiver does not operate to waive a collateral

13
CASE 0:22-cr-00223-NEB-DTS Doc. 689 Filed 06/26/25 Page 14 of 15

challenge under 28 U.S.C. § 2255 based on new legal principles enunciated in
Supreme Court case law decided after the date of this Plea Agreement that are both
substantive and have retroactive effect. For purposes of this provision, legal
principles that are substantive and retroactive are those that narrow the reach of the
offense of conviction and render the defendant’s conduct non-criminal or that render
the sentence imposed illegal.

The defendant has discussed these rights with the defendant’s attorney. The
defendant understands the rights being waived, and the defendant waives these
rights knowingly, intelligently, and voluntarily.

16. FOIA Requests. The defendant waives all rights to obtain, directly or

through others, information about the investigation and prosecution of this case
under the Freedom of Information Act and the Privacy Act of 1974, 5 U.S.C. §§ 552,

17. Complete Agreement. This, along with any agreement signed by the

parties before entry of plea, is the entire agreement and understanding between the
United States and the defendant. By signing this plea agreement, the defendant
acknowledges: (a) that the defendant has read the entire agreement and has reviewed
every part of it with the defendant’s counsel; (b) that the defendant fully understands
this plea agreement; (c) that no promises, agreements, understandings, or conditions
have been made or entered into in connection with his decision to plead guilty, except
those set forth in this plea agreement; (d) that the defendant is satisfied with the

legal services and representation provided by defense counsel in connection with this

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CASE 0:22-cr-00223-NEB-DTS Doc. 689 _ Filed 06/26/25 Page15of15

plea agreement and matters related to it; (e) that the defendant has entered into this
plea agreement freely, voluntarily, and knowingly; and (f) that the defendant’s
decision to plead guilty in accord with the terms and conditions of this plea agreement

is made of the defendant’s own free will.

Dated: JOSEPH H. THOMPSON

A Acting Upite# States Attorney

BY: MATTHHW S. EBERT
HARRY M. JACOBS
DANIEL W. BOBIER
Assistant United States Attorneys

Dated: 6/26 ka 025

Defendant

Dated: Su for y
GLENN P. BRUDER

Counsel for Defendant

15


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