Response in Opposition — United States v. Bock et al. (Feeding Our Future) (Dkt. 853, D. Minn.)

Summary

Defendant Aimee Marie Bock's memorandum in response to the Government's Motion to Modify the Protective Order and for Sanctions, Doc. 853, in United States of America v. Aimee Marie Bock, Criminal No. 22-CR-223 (NEB/DTS), in the United States District Court District of Minnesota, filed April 29, 2026. It states that the Government seeks to restrict Bock's access to protected discovery except in counsel's presence, to require control or removal of protected materials from third-party possession, and to prohibit contact between Bock and her two sons until sentencing. The memorandum argues that a warning and a tailored protective-order modification are sufficient, and its Proposed Order section lists the relief the defense proposes. It asks that the Government's motion be granted only in part.

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Cite this document

“Response in Opposition — United States v. Bock et al. (Feeding Our Future) (Dkt. 853, D. Minn.).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/response-in-opposition-united-states-v-bock-et-al-feeding-our-future-d-ad35a13a72/, SHA-256 8a7a5355b9d66e204bc24c141c46207a35349ea61d8ca2c2f2166421e927367f.

Full text

CASE 0:22-cr-00223-NEB-DTS Doc. 853 Filed 04/29/26 Page 1 of 10

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

United States of America,

DEFENDANT AIMEE BOCK’S
Plaintiff, MEMORANDUM IN RESPONSE TO THE
vs. GOVERNMENT’S MOTION TO MODIFY
THE PROTECTIVE ORDER AND FOR
SANCTIONS
Aimee Marie Bock (1),

Defendant.

I. INTRODUCTION

Aimee Marie Bock respectfully submits this memorandum in response to the

Government’s Motion to Modify the Protective Order Governing Discovery and for

Sanctions. The defense does not ask the Court to ignore the seriousness of an alleged

protective-order violation, nor does it ask the Court to tolerate any further dissemination

of protected discovery. Ms. Bock will comply with any directive from this Court. The

question is not whether the Court may act; it is how far the Court should go on the

present record.

The Government seeks relief in three materially distinct categories: First, to

restrict Ms. Bock’s access to protected discovery except in counsel’s presence; second, to

require the control, surrender, or removal of protected materials from third-party

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CASE 0:22-cr-00223-NEB-DTS Doc. 853 Filed 04/29/26 Page 2 of 10

possession; and third, to prohibit any contact between Ms. Bock and her two sons, Cale

and Camden, until sentencing. The first two categories can be addressed by a focused

order that protects discovery and witnesses. Cale and Camden are college students. They

are amenable to being asked to delete any material related to their mom’s federal case,

whether protected or not. That way, there will be no risk of release.

Surrendering the computers Cale and Camden use for school is overly punitive

and will cause unintended negative academic consequences. Their mother, who used to

be their primary source of financial support, is in custody. Life has been very difficult for

Cale and Camden since January 2022, when the government executed search warrants at

the Feeding Our Future office. They were teenagers in high school. Now that they have

secured computers for college, they cannot afford another for schoolwork.

The third category - a categorical ban on a mother speaking with her children - is

equally punitive, overbroad, and unnecessary. The Court should deny the request and

instead issue a clear warning, coupled with precise restrictions that bar any family

member or third party from distributing protected materials. Counsel can communicate

the Court’s order to the Bock family, being that they would unlikely wish to discuss this

case before sentencing.

II. FACTS

The Government’s motion rests largely on its account of recorded jail calls and its

inference that Ms. Bock, directly or through others, caused protected materials to be

transmitted to elected officials and members of the press. The Government alleges that a

legislator received emails from a Proton Mail account under the name “Daisy Hill” that

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CASE 0:22-cr-00223-NEB-DTS Doc. 853 Filed 04/29/26 Page 3 of 10

attached documents governed by the Protective Order, including Monday.com entries and

Feeding Our Future email records.1 Doc. 848 at 3. It further alleges that a Star Tribune

reporter obtained law-enforcement interview reports, although the Government expressly

states that it has not been able to determine with certainty who provided those reports to

the reporter. Id. at 3-4, 9.

Ms. Bock does not ask the Court to approve any disclosure of protected discovery.

She does, however, contest the Government’s attempt to turn a protective-order issue into

a family-separation sanction. The record, as described by the Government, supports a

narrower solution: prohibiting further disclosure, deleting protected material, limiting

access to counsel-supervised review only, and warning Ms. Bock in unmistakable terms

that any violation may affect sentencing and result in additional sanctions. That relief

protects the Court’s authority and the integrity of the proceedings without severing the

only immediate family contact Ms. Bock has while she awaits sentencing. Her regular

communication with her two boys is the only meaningful thing in her life in jail and for

the foreseeable future.

Ms. Bock’s communications, as reflected in the Government’s motion, were not

threats to witnesses. There were no instructions to contact witnesses. They were not

making efforts to procure false testimony. They were not efforts to conceal assets, flee, or

obstruct a pending trial. They were, at most, an inartful, desperate, and legally misguided

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Monday.com entries are not covered under the protective order. Monday.com is a web-based database that
Feeding Our Future staff communicated with one another about claims. Ms. Bock had access to the database while
employed by Feeding Our Future. Nonetheless, it is better not to share information on Monday.com without
counsel’s approval.

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CASE 0:22-cr-00223-NEB-DTS Doc. 853 Filed 04/29/26 Page 4 of 10

attempt by a detained defendant who believes her prosecution has been unfair to seek

public and governmental review by legislators and executive-branch officials. That

motive does not excuse any violation of the Protective Order. But it matters when the

Court selects a sanction. A sanction should be corrective and preventive, not

unnecessarily destructive of family relationships.

III. GOVERNING PRINCIPLES

This Court has meaningful authority to manage litigation and enforce court orders,

but the chosen sanction must fit the violation. The Eighth Circuit held that district courts

may sanction violations of criminal pretrial orders, but the sanction must be calibrated.

The court must weigh “the reasons” for the violation, intentionality/bad faith, prejudice,

and whether “any less severe sanction” would remedy the violation. United States v.

DeCoteau, 186 F.3d 1008 (8th Cir. 1999). In Bergstrom v. Frascone, although a civil

case, the caution applies. Severe sanctions require careful attention to willfulness,

prejudice, and the availability of lesser sanctions. See Bergstrom v. Frascone, 744 F.3d

571, 575-76 (8th Cir. 2014). The court is to examine whether a lesser sanction will

suffice unless the misconduct is deliberate or in bad faith: Bergstrom, 744 F.3d at 576.

The same proportionality principle is even more important here because the

Government seeks to restrict personal associations between a detained mother and her

children. A woman facing considerable time in prison. In the supervised-release context,

the Eighth Circuit requires that liberty restrictions be reasonably related to legitimate

sentencing purposes and involve no greater deprivation of liberty than is reasonably

necessary. United States v. Scott, 270 F.3d 632, 635-36 (8th Cir. 2001). Restrictions that

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CASE 0:22-cr-00223-NEB-DTS Doc. 853 Filed 04/29/26 Page 5 of 10

burden important personal relationships must be especially fine-tuned. Scott, 270 F.3d at

636.

IV. ARGUMENT

A. The Court Can Protect the Protective Order Without Imposing a Family-
Separation Sanction.

The Government’s legitimate concern is the protection of discovery materials and

witnesses. That concern is fully addressed by an order prohibiting Ms. Bock, Cale,

Camden, and any third party acting on her behalf from possessing, accessing,

transmitting, or distributing protected materials except through defense counsel and for

purposes of this criminal case. The Court may also require counsel-supervised access to

protected materials, removal of protected materials from any non-lawyer cloud account,

and the return or deletion of protected files under counsel’s supervision. These remedies

are directly tied to the alleged violation.

By contrast, an absolute ban on all contact with Cale and Camden is not tied to

protected discovery; it is tied to identity. It would prohibit ordinary family

communication, even when a call involves only health, education, finances, emotional

support, or the realities of awaiting sentencing in one of the country’s largest Covid-19

and child nutrition fraud cases. If the Court is concerned that Ms. Bock’s sons may be

used as intermediaries, the solution is not silence between mother and children. The

solution is a no-intermediary order: no request, instruction, suggestion, or coded

communication asking either son to access, move, send, describe, publish, or preserve

protected materials, and no discussion of protected discovery with them at all.

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CASE 0:22-cr-00223-NEB-DTS Doc. 853 Filed 04/29/26 Page 6 of 10

That narrower remedy is more enforceable than the Government's proposed ban.

Ms. Bock is in custody. Her calls are recorded. A clear warning, a subject-matter

restriction, and counsel-supervised access to discovery give the Court immediate tools to

detect and punish noncompliance. A total family-contact ban adds little to the record’s

protection and imposes a disproportionate human cost.

B. The Government's Motion Conflates Whistleblowing and Public Petitioning
with Witness Intimidation.

The Government repeatedly characterizes Ms. Bock and her sons’ conduct as

corrupting the judicial process and suggests that Ms. Bock is endangering witnesses. The

defense does not minimize the risk of publishing interview reports or personal

information. But the remedy should align with the record. The motion does not identify

any phone call in which Ms. Bock threatened a witness, directed anyone to threaten a

witness, asked anyone to contact a witness, insulted the judge, maligned the prosecution,

sought to contact or intimidate witnesses who testified against her and for the

Government, or sought to influence any testimony. Nor does it identify any witness who

received an intimidating message from Ms. Bock or her sons, despite the deluge of racial

and gender-based attacks she receives. The Government’s concern is the dissemination of

protected materials. The sanction should therefore target the dissemination of protected

materials.

Ms. Bock generally believes that the Government’s prosecution has been unfair

and that the legislative and executive branches should examine broader governmental

conduct related to the Feeding Our Future investigation. She may be wrong about legal

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CASE 0:22-cr-00223-NEB-DTS Doc. 853 Filed 04/29/26 Page 7 of 10

strategy. She may have acted inartfully. She may have misunderstood the boundary

between protected discovery and materials she believed exposed governmental

wrongdoing. But a misguided effort to seek legislative or executive attention is not the

same as witness intimidation.

The Court should draw that line clearly. It should warn Ms. Bock that she may

pursue lawful complaints, clemency, legislative requests, or public-record advocacy only

through counsel and only without protected discovery, witness statements, sealed

materials, personal identifiers, or court-protected information.

C. A Warning and a Tailored Protective-Order Modification Are Sufficient and
More Consistent With Eighth Circuit Proportionality Principles.

The defense proposes a sanction that is firm, immediate, and proportionate. First,

the Court should warn Ms. Bock on the record that any violation of the Protective Order

may result in contempt proceedings, further restriction of communications, consideration

at sentencing to the extent lawful, and any other sanction the Court deems appropriate.

Second, the Court should restrict Ms. Bock's access to protected discovery to review in

the presence of defense counsel or counsel’s authorized staff. Third, the Court should

order that protected discovery not be stored, accessed, or transmitted through any non-

lawyer Dropbox, Proton Mail, personal email, or third-party account. Fourth, the Court

should order Cale, Camden, and any other third party acting in Ms. Bock’s direction not

to possess, access, transmit, or distribute protected materials. Fifth, the Court should

permit ordinary family contact but prohibit discussion of protected materials or the use of

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CASE 0:22-cr-00223-NEB-DTS Doc. 853 Filed 04/29/26 Page 8 of 10

family members as intermediaries for any media, political, legislative, or executive

outreach involving protected materials.

That proposed remedy gives the Government the protection it says it needs while

preserving the essential human contact that the Government’s motion would eliminate.

Ms. Bock has not been sentenced. She is detained. Her future is uncertain. Her two

young, college-aged children are central to her remaining family life. Cutting off all

contact with them until sentencing would be a severe sanction with no demonstrated

necessity.

V. PROPOSED ORDER

The defense respectfully requests that the Court deny the Government’s request to

prohibit contact between Ms. Bock and her sons. In lieu of that sanction, the defense

proposes the following relief:

• All protected materials shall remain subject to the existing Protective Order and

may be used only for purposes of this criminal case.

• Ms. Bock shall not access protected discovery except in the presence of defense

counsel or counsel’s authorized staff, unless further ordered by the Court.

• Ms. Bock shall not ask, direct, encourage, or permit Cale Bock, Camden Bock, or

any third party to access, possess, copy, transmit, quote, summarize, publish, or

distribute protected discovery.

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CASE 0:22-cr-00223-NEB-DTS Doc. 853 Filed 04/29/26 Page 9 of 10

• Cale Bock, Camden Bock, and any third party acting on Ms. Bock’s behalf shall

not access, possess, copy, transmit, quote, summarize, publish, or distribute

protected material.

• Any protected discovery stored in Cale Bock, Camden Bock, or any family

member’s cloud account, personal email account, removable drive, computer,

telephone, or other device shall be deleted or returned to defense counsel, and

deleted under counsel supervision.

• Ms. Bock may maintain ordinary personal contact with Cale and Camden Bock,

but she shall not discuss protected discovery with them or use them as

intermediaries for media, legislative, executive-branch, or public dissemination of

protected materials.

• The Court shall warn Ms. Bock that any further violation may result in contempt,

additional communication restrictions, adverse consideration to the extent lawful

at sentencing, or any other sanction authorized by law.

VI. CONCLUSION

The Court should enforce its Protective Order. But enforcement does not require

the Court to cut off Ms. Bock from her children. A warning, counsel-supervised

discovery access, retrieval, or deletion of protected materials from non-lawyer accounts,

and a strict no-intermediary/no-disclosure directive will protect the proceedings while

avoiding unnecessary and disproportionate family-separation sanctions. The

Government’s motion should therefore be granted only in part and denied to the extent it

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CASE 0:22-cr-00223-NEB-DTS Doc. 853 Filed 04/29/26 Page 10 of 10

seeks to prohibit Ms. Bock from ordinary contact with Cale and Camden Bock before

sentencing.

KENNETH UBONG UDOIBOK, P.A.

April 29, 2026 /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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