JT gn ‘AO 106 (Rex. 4/10) Applicaton orn Search Warant ananR02t0| UNITED STATES DISTRICT COURT for the District of Minnesota IN ‘THE MATTER OF THE SEARCH OF SEALED BY ORDER OF THE COURT ‘THE SINGLE-FAMILY HOME LOCATED AT 13299 BRONZE PARKWAY, ROSEMOUNT, MINNESOTA 55068, AS FURTHER DESCRIBED. IN ATTACHMENT A-2 ‘Case No. 22-MI-040 TNL APPLICATION FOR A SEARCH WARRANT 1, Travis Wilmer, a federal law enforcement officer or an attorney for the government, request a search warrant and state under penalty of perjury that I have reason to believe that on the following person or property ‘See Attachment A-2, incorporated here located in the State and District of Minnesota, there is now concealed: ‘See Attachment B-2, incorporated here ‘The basis for the search under Fed. R. Crim, P. 41(c) is (check one or more): _X evidence of a crime; x contraband, fruits of crime, or other items illegally possessed; TR propsrydesied So sy, inde few orto a omnia iy a person to be arrested or a person who is unlawfully restrained, ‘The search is related to a violation of: Code Section Offense Description Title 18, United States Code, Section 1341 Mail Fraud Title 18, United States Code, Section 1343 Wire Fraud Title 18, United States Code, Section 1349 Conspiracy Title 18, United States Cade, Section 1956, 1957 Money Laundering ‘The application is based on these facts: See Affidavit, incorporated here x ‘Continued on the attached sheet. a 7 “Applicant's Signature SUBSCRIBED and SWORN before me by reliable ‘electronic means (FaceTime, Zoom and/or email) pursuant to Fed. R. Crim, P. 41(d)() Travis Wilmer, Special Agent Federal Bureau of Investigation pate: Ten. Me Lore Printed Name and Tile City and State: Minneapolis, MN ‘The Honorable Tony PEung United States Magistrate Judge Printed Name and TieSTATE OF MINNESOTA ) ) ss, AFFIDAVIT OF TRAVIS WILMER COUNTY OF HENNEPIN) ‘Your affiant, Travis Wilmer, being duly sworn, does state the following is true and correct to the best of his knowledge and belief: 1. Thaye been employed as a Special Agent with the Federal Bureau of Investigation (BD) since November 8, 2021. 2. Asa Special Agent, my primary duties and responsibilities consist of conducting investigations of individuals and businesses for possible violations of federal laws. Lam presently assigned to the FBI's Minneapolis, Minnesota field office where I am a member of the Civil Rights and Public Corruption Squad. 3. During my employment as a Special Agent, I have conducted and participated in investigations of varying degrees involving mail fraud, wire fraud, fraud against the government, money laundering, and other criminal acts, including criminal schemes where individuals misappropriate money from the investing public, Furthermore, in the course of my training and experience, I have become familiar with the types of records businesses typically maintain in the course of their regular activity, including ledgers, journals, invoices, receipts, and bank documents. 4, Based upon my work experience and training, as well as discussions with law enforcement agents, I know that: a. Businesses generally maintain or keep journals, ledgers, bank statements and records, receipts, invoices and other documents evidencing thereceipts and disbursements of funds, inventories, assets of the business and personnel information. These records are usually kept and maintained for extended periods of time, often several years, at the place of business or residence. I know from previous investigations that such records are also often maintained at the residence of subjects. b. Individuals, including those receiving income from fraud schemes, often maintain within their residence records of assets and financial transactions, These items often include financial statements, receipts, invoices, bank statementa and records, bank money order and cashier's check receipts, property records, investment vecords, assets, stock and bond records, tax records, correspondence, diaries, and handwritten notes. These records are often maintained for extended periods of time, often several years, ¢. Due to the increasing prevalence of electronic communications and storage, paper records can be converted and stored electronically. As a result, any record or document could be found in either paper or electronic format. Almost all wire transfers, even intrastate wire transfers, cross state lines. 5. This affidavit is submitted in support of an application for warrants to search: a. The office located at 3055 Old Highway 8, Suites 312 and 229, Saint Anthony, Minnesota 55418, ns further described in Attachment A-1 (‘Subject Premises 1”);b, ‘The single-family home located at 18299 Bronze Parkway, Rosemount, Minnesota 55068, as further described in Attachment A-2 (“Subject Premises 2”); c. The office suite located at 1506 Southcross Drive West, Burnsville, Minnesota 55306, as further described in Attachment A-3 (‘Subject Premises 3”); d. The office located at 8249 Hennepin Avenue South, Unit 75, Minneapolis, Minnesota 55408, as further described in Attachment A-4 (‘Subject Premises 4”); and e. The single-family home located at 15101 County Road 5, Burnsville, Minnesota 55306, as further described in Attachment A-5 (“Subject Premises 5”); £. ‘The office located at 2854 Columbus Avenue South, Minneapolis, Minnesota 55407, as further described in Attachment A-6 (‘Subject Premises 6”) (collectively, the “Subject Premises”); for evidence, fruits, and instrumentalities of violations of Title 18, United States Code, Section 1341 (mail fraud), 1343 (wire fraud), 1349 (conspiracy), and 1956/1957 (money laundering). 6. ‘This affidavit is based on my personal knowledge, interviews of witnesses, physical surveillance, information received from other law enforcement. agents, my experience and training, and the experience of other agents. Because this affidavit is being submitted for the limited purpose of establishing probable cause insupport of a search warrant: for the Subject Premises, I have not included each and every fact known to me concerning this investigation. I have set forth only the facts that I believe are necessary to establish probable cause to believe that evidence, instrumentalities, and fruits of violations of Title 18, United States Code, Sections 1841, 1843, 1349, and 1956/1957 are located at the Subject Premises. 1. Overview 7. Inrecent years, individuals and companies in Minnesota have engaged ina large-scale scheme to fraudulently obtain and misappropriate federally funded child nutrition programs. The scheme was carried out by individuals who owned and operated companies purportedly in the business of providing federally funded free meals to underprivileged children and adults, including during the global Covid-19 pandemic, The companies and their owners received tens of millions of dollars in federal funds for use in providing nutritious meals to underprivileged childven and adults. Almost none of this money was used to feed children. Instead, the participants in the scheme misappropriated the money and used it to purchase real estate, cars, and other luxury items. To date, the conspirators have stolen millions of dollars in federal funds. The scheme is ongoing. TI. Locations To BE SEARCHED A. Subject Premises 1 8. Subject Premises 1 is the office of Feeding Our Future located at, 3056 Old Highway 8, Suites 229 and 312, Saint Anthony, Minnesota 65418. 9. During the investigation, the government obtained a federal search warrant for the contents of an email account used by Aimee Bock to conduct businesson behalf of Feeding Our Future. A review of these emails showed that Aimee Bock sent and received hundreds of documents identifying Subject Premises 1 as the office location of Feeding Our Future. These documents included correspondence with the Minnesota Department, of Education related to the company’s participation in federal child nutrition programs. 10. U.S. Postal Service records show that Feeding Our Future regularly receives mail at Subject Premises 1, including mail from the Minnesota Department of Education and various banks. On or about January 13, 2022, an FBI agent conducted surveillance at Subject Premises 1, The agent saw the mailboxes located in the lobby of the building. The boxes for Suites 312 and 229 were both. labeled “Feeding Our Future.” 11. FBI surveillance agents have regularly observed a Volkswagen Atlas SUV bearing Minnesota license DVN 744 parked outside of the Subject Premises 1, including on January 12, 2022. Minnesota Department of Motor Vehicles records: show that this car is registered to Aimee Bock. 12. The door to Suite 312 has signs indicating that the suite is used by Feeding Our Future.B. Subject Premises 2 13. Subject Premises 2 is the single-family home located at 18299 Bronze Parkway, Rosemount, Minnesota 55068. Subject Premises 2 is the residence of Aimee Bock, the President of Feeding Our Future. Tt is also a mailing address used by Feeding Our Future. 14. Dakota County property records show that Aimee Bock owns Subject Premises 2. 15. According to Minnesota Department of Motor Vehicles, Aimee Bock lives at Subject Premises 2. 16. FBI surveillance agents have regularly observed the Volkswagen Atlas SUV registered to Aimee Bock parked in the driveway of Subject Premises 2, including on January 13, 2022, 17. According to Minnesota Secretary of State records, Feeding Our Future was incorporated in November 2016, Aimee Marie Bock is listed as the President of the company. Subject Premises 2 is listed as Feeding Our Future's addzess with the Minnesota Secretary of State. 18. Aimee Bock has a number of bank accounts, including an account at US Bank, As explained below, Aimee Bock deposited into this account a $310,000 skickback payment from a company that was misappropriating federal child nutrition program funds, Subject Premises 2 is listed as the addvess on Aimee Bock’s bank accounts. 19, Subject Premises 2 is also a mailing address used by Handy Helper's [sic] LLG, a company created by Aimee Bock’s partner Empress Malcolm Watson Jr.‘As explained below, the company was used to misappropriated approximately $600,000 in federal child nutrition program funds from Feeding Our Future. 20. U.S. Postal Service records show that Aimee Bock, Empress Watson, and Handy Helper’s LLC have all received mail at Subject Premises 2 since December 2021. C, Subject Premises 3 21. Subject Premises 8 is office suite located at 1506 Southoross Drive West, Burnsville, Minnesota 55306, Subject Premises 3 is a site location at which Feeding Our Future purports to serve meals as part of the federal child nutrition program, 22, Minnesota Department of Education records show that Feeding Our Future submitted applications and reimbursement claims stating that the company was serving meals at Subject Premises 3. Spcnsnng Autor ntrnan Sponsor ZO00025¢-Fatng Our Fle te trmaton: sue se0001878- Sons © Approve. Detain sueappeatonsaus 7 Deactivate Aerovateetve te ate. sep 222 se aauess 1800 Souoss OW, Buns S506, Da Cony ate rogram ame Souths |Program Year 2021-2022 Stop Payment () contact tormaton contact contact Frat Aimee tat Bock hse name cornet Prone carat ndenrecuveDectr PRONE gxzaasiond23. Minnesota Department of Education records show that Feeding Our Future claimed to be serving tens of thousands a meals a month to children at Subject Premises 3. For example, Feeding Our Future claimed to have served more than 50,000 meals at Subject Premises 8 in November 2021. 24. An FBI agent. conducted surveillance at Subject Premises 8 on several occasions in December 20201. There were signs posted on windows near the entrance indicating that Feeding Our Future was offering free meals. D. — Subject Premises 4 25. Subject Premises 4 is the office suite located at 3249 Hennepin ‘Avenue South, Unit 75, Mimeapolis, Minnesota 65408. Subject Premises 4 is the office of Abdikerm Abdelahi Eidleh and various entities controlled by Abdikerm Abdelahi Kidleh. As explained below, these entities have been used to fraudulently misappropriate federal child nutrition program funds and to solicit and receive ‘kickbacks from entities participating in the federal child nutrition program. 26, Minnesota Secretary of State records show that Abdikerm Abdelahi Bidleh controls several companies that are registered at Subject Premises 4, including Hope Suppliers LLC, Bridge Logistics LLC, Bidleh Ine., and Charm Home Care LLC. 27. As explained below, Abdikerm Abdelahi Hidleh opened more than 20 bank accounts in the name of his various corporate entities. Subject Premises 4 is listed as the address on most or all of the accounts.28. U.S, Postal Service records show that Abdikerm Abdelahi Kidleh, Hope Suppliers LLC, Bridge Logistics LLC, and Charm Home Care LLC have all received mail at Subject Premises 4 in December 202] or January 2022. 29, ‘The building directory at 3249 Hennepin Avenue South indicates that Hidleh Inc. and Charm Home Care LLC are both located in Unit 75. E, Subject Premises 5 30. Subject Premises 6 is the single-family home located at 15101 County Road 5, Burnsville, Minnesota 55306. Subject Premises 5 is the residence of Abdikerm Abdelahi Hidleh, an employee of Feeding Our Future. 81. Dakota County property records shows that Abdikerm Abdelahi Eidleb owns Subject Premises 5. U.S. Postal Service records show that Abdikerm Abdelahi Bidleh currently receives mail at Subject Premises 5. 32. As explained below, Abdikerm Abdelahi Hidleh misappropriated federal funds from Feeding Our Future and also solicited and received kickbacks from sites participating in the federal child nutrition program. Abdikerm Abdelahi Bidleh then used this money to pay personal expenses. Abdikerm Abdelahi Bidleh opened more than 80 bank accounts in the name of his various corporate entities and then used the accounts to receive and launder the proceeds of his scheme. Subject Premises 5 is listed as the address on many of these accounts, including accounts held in the name of Eidleh Inc. and Bridge Logistics LLC. 33. In or about November 2020, Abdikerm Abdelahi Hidleh took out a loan for approximately $294,000 for use in purchasing Subject Premises 5. Bank records show that Abdikerm Abdelahi Hidleh later used approximately $212,000 infraudulently misappropriated federal child nutrition program to make payments on that loan. ‘The Joan documents all list Subject Premises 6 as Abdikerm Abdolahi Bidleh’s address. F, Subject Premises 6 34, Subject Premises 6 is a building located at 2854 Columbus Avenue South, Minneapolis, Minnesota 55407. Subject Premises 6 is the location of another site at which Feeding Our Future claimed to be serving federally funded meals to children. Feeding Our Future referred to this site as “Feeding Our Future Taylor” (the “Taylor Site”). 835. Minnesota Department of Education records show that Feeding Our Future submitted an application for the Taylor Site’s participation in the Federal Child Nutrition Program in or about January or February 2021. The application stated that the Taylor Site was located at Subject Premises 6. 36. The application indicated that Feeding Our Future would be serving approximately 2,000 children a day. Aimee Bock was listed as the contact person for Feeding Our Future. The contvact stated that a company called Metro Area Catering would be the vendor providing the meals for the Taylor Site. 37. On or about January 4, 2022, an IRS agent conducted surveillance at Subject Premises 6, ‘The IRS agent observed a sign indicating that I-Care Home Health Care was located at Subject Premises 6. According to Minnesota Secretary of State records, [-Care Home Health Care LLC is a Minnesota limited liability company located at Subject Premises 6. Mohamoud Warsame is identified as the manager and registered agent for I-Care Home Health Care LLC. 1088. As described below, Mahamoud Warsame also controls Metro Area Catering, the vendor company that purported to be providing the meals to be served at the Taylor Site/Subject Premises 6. TIL BAcKGRouND A. The Federal Child Nutrition Programs 39. This warrant relates to an ongoing investigation into a scheme to defraud United States Department of Agriculture (USDA) programs that provide federal funding to nutrition programs for children and low-income individuals across the nation. The USDA operates two such programs—the Summer Food Service Program and the Child and Adult Care Food Program. 40. ‘The Summer Food Service Program (SFSP) is a federal program designed to ensure that low-income children continue to receive nutritious meals when school is not in session. 41, The Child and Adult Care Food Program (CACFP) is a federal program that provides reimbursements for nutritious meals and snacks to eligible children and adults who are enrolled for care at participating child care centers, day care homes, and adult day care centers, CACFP also provides reimbursements for meals. served to children participating in afterschool care programs or residing in emergency shelters and adults over the age of 60 or living with a disability and enrolled in day’ care facilities. 42, The Summer Food Service Program and Child and Adult Care Food Program (together, the “Federal Child Nutrition Programs’) operate throughout the United States. The USDA’s Food and Nutrition Service administers the programs at iLthe national and regional levels by disbursing federal funds to state governments, which provide oversight over the Federal Child Nutrition Programs. 43. Within each state, the Federal Child Nutrition Programs are administered by the state department of education or an alternate state-designated agency. In Minnesota, the programs are administered by the Minnesota Department of Bducation (MDE). 44, Locally, meals funded by the Federal Child Nutrition Program are served at sites such as schools or daycare centers (‘Sites’). Each Site must be sponsored by a public or private non-profit organization that is authorized to participate in the Federal Child Nutrition Programs (“Sponsors”). Sponsors seeking to participate in the Federal Child Nutrition Programs are xequired to submit an application to the MDE for approval for each site from which they intend to operate Fedeval Child Nutrition Programs. Sponsors are responsible for monitoring each of their sites and preparing reimbursement claims for their sites. 45. Federal Child Nutrition Program funds are supposed to be used to provide nutritious meals and food to children and low-income individuals. See 7 CFR. § 225.15(a)(4) (AN Program reimbursement funds must be used solely for the conduct of the nonprofit food service opevation.”). 46. Historically, the Federal Child Nutrition Program has generally functioned through the provision of meals to childven involved in educational-based programs or activities. During the Covid-19 pandemic, however, the USDA waived some of the standard requirements for participation in the Federal Child Nutrition 12Program. Among other things, USDA allowed for-profit restaurants to participate in the program, It also allowed for off-site food distribution to children outside of educational programs. At the same time, the state government's stay-at-home order and telework policies interfered with its ability to oversee the program. According to MDE officials, this left the program vulnerable to fraud and abuse. B, Feeding Our Future 47, ‘This warrant is an investigation into the widespread diversion and misuse of Federal Child Nutrition Program funds during the Covid-19 pandemic, ‘Much of this fraud was committed by sites operated under the sponsorship of Feeding Our Future, a non-profit organization purportedly in the business of helping community partners participate in the Federal Child Nutrition Program and related. federal programs. Feeding Our Future sponsors and helps administer sites that participate in the Federal Child Nutrition Program. According to its website, Feeding Our Future “utilize[s] the Child and Adult Care Food Program to increase healthy food access for Mirmesota’s youth and seniors.” The website lists Aimee Bock as the founder and executive director of Feeding Our Future. 48. Records obtained from MDE show that after being formed in 2017, Feeding Our Future quickly began receiving and distributing millions of dollars in Federal Child Nutrition Program Funds. The company went from receiving $3.4 million in 2019 to move than $197 million in 2021. 13,Year | Approximate amount of Federal Child Nutrition Program funds to Feeding Our Future 2018 $307,253 2019 $3,487,168 2020 $42,681,790 2021 $197,932,695, Total $24,408,906 49. Feeding Our Future entered into contracts with the sites it sponsored. Under these contracts, Feeding Our Future deducted 10 percent of all Federal Child Nutrition Program reimbursements received by the sites under its sponsorship as its “administrative fee.” 14. Receive payments of CACFF reimbursements from FEEDING OUR FUTURE, after deduction of ‘administrative fee of 10 percent, within five working days of FEEDING OUR FUTURE's receipt of program reimbursement funds from MOE. 50. ‘This provided an incentive for Feeding Our Future, and its Executive Director Aimee Bock, to increase the number of sites under its sponsorship as well as the amount of Federal Child Nutrition Program reimbursements each site was receiving. 51, MDE became concerned about the massive increase in Federal Child Nutrition Program funds going to sites sponsored by Feeding Our Future as well as the large increase in the number of sites under Feeding Our Future sponsorship. According to MDE employees, MDE began more carefully scrutinizing new site applications submitted by Feeding Our Future. Feeding Our Future later sued MDE, alleging that it unlawfully denied its site applications and withheld reimbursements 14to which Feeding Our Futue and sites under its sponsorship were entitled. This Jawsuit is currently pending in Ramsey County District Court. 52. At various times during this litigation, the presiding judge has concluded that MDE wrongfully withheld funds and violated federal regulations in its attempts to oversee Feeding Our Future and sites under its sponsorship. 58. Tn April 2021, MDE provided information to the FBI alleging that. Feeding Our Future and sites under its sponsorship were diverting funds away from the nutrition program, MDE believed certain sites were submitting fraudulent documents to support reimbursement of funds in addition to artificially inflating the number of children and low-income individuals receiving benefits in order to obtain funds, But MDE did not have access to the participating companies’ bank records so was unable to conclusively determine whether they were misappropriating Federal Child Nutrition Program funds. 54, In May 2021, the FBI began investigating the allegations surrounding the misuse of federal funds intended for feeding children and low-income individuals. ‘As part of this investigation, the FBI obtained records of hundreds of bank accounts that received, either directly or indirectly, Federal Child Nutrition Program funds. A review of these financial records showed a massive fraud scheme involving the misuse and theft of tens of millions of dollars in Federal Child Nutrition Program funds. C. Feeding Our Future-Sponsored Sites Fraudulently Misappropriated Millions of Dollars in Federal Child Nutrition Program Funds 55. Safari Restaurant and Event Center is one of the sites receiving Federal Child Nutrition Program money under the sponsorship of Feeding Our Future. A wbgroup of individuals who own or are associated with Safmi Restaurant have participated in a fraudulent scheme to obtain and misappropriate millions of dollars in Federal Child Nutrition Program funds, Beginning in 2020, these individuals have created several companies for use in carrying out these schemes. They enrolled their companies in the Federal Child Nutrition Program under the sponsorship of Feeding Our Future. They then claimed to be feeding meals to thousands of children a day, for which they were reimbursed more than $10 million, But bank records show they misappropriated most of this money and used it to purehases reall estate, cars, and other huxury items. 56. Safari Restaurant applied to participate inithe Fedeval Child Nutrition Program under the sponsorship of Feeding Our Future in April 2020. Salim Said signed the application (on behalf of Safari Restaurant and Aimee Bock signed on behalf of Feeding Our Future. 57. Ono dbout April 24, 2020, MDE informed Bock that it was denying the application, In an email to Bock, an MDE employee explained that “[blased on guidance from USDA, we aren't creating any new CACKP At-Risk site IDs for locations not currently providing care.” 58. Bock and Feeding Our Future objected to the denial of the application. On or about April 24, 2020, Bock claimed that “[t}hese sites are already providing meals to the states youth with the expectation of the meals being reimbursed” and asked what “authority .. . allows you to deny site applications to sites that are clearly eligible.” 1659. Bock and Feeding Our Future subsequently submitted a formal complaint to MDE about the denial of Safari Restaurant's application. In an email sent on April 28, 2020, an attorney representing Feeding Our Future told MDE he was going to be filing a formal complaint about the denial of the application. He explained that the sites, including Safari Restaurant, were “all minority owned businesses serving almost exclusively economically disadvantaged childxen of color.” In an apparent reference to the Covid-19 pandemic, he cited “the extraordinary times we ave in now” and said it was “critical that we get a speedy decision from MDE on this” because “[tJhese children, families, and businesses desperately need the federal help they are entitled to.” 60, Later that day, Bock sent a follow-up email to an MDE employee. Bock said she “was extremely disappointed that MDE would deny these sites the opportunity to feed youth culturally relevant foods during this national emergency. It was even more shocking considering the great work these sites do,” 61. ‘Two days later, on or about April 30, 2020, MDE approved Safari Restaurant's application and authorized its participation in the Federal Child Nutrition Program. D. Safari Restaurant Almost Immediately Claimed it was Entitled to Hundreds of Thousands of Dollars in Federal Child Nutrition Program Funds 62. By July 2020, Safari Restaurant claimed that it was serving or providing meals to 5,000 children a day. That month, MDE conducted an administrative review and audit of Safari Restaurant's participation in the Summer Food Service Program 7(GFSP). As part of that review, MDE requested meal count records showing the number of meals served at the site each day. 63. In response to MDE's request, Feeding Our Future submitted weekly count forms purporting to show that Safari Restaurant provided both breakfast and lunch for 5,000 children a day, seven days a week, in July 2020. Safari Restaurant claimed that it served both breakfast and lunch to between 4,985 and 4,998 children each day of July 2020. Y i Brordsenmves 3 SUMMER MEAL COUNTS ~ CLICKER [xt [ueaintcanne foe — fans | (aoa [Reonwomoe Ca ee avanarg symone ry MD nantewerefvn % | 93] $5 [95] 55 | 55 fea ffl T= [277/a0 | 64, This is an exceedingly large number of children. By way of comparison, the largest high school in the state of Minnesota—Wayzata High School—has an enrollment of approximately 3,600 students. 65. Bank records show that Safari Restaurant received approximately $476,000 in Federal Child Nutrition Program funds in July 2020. The company 18received approximately $702,000 in Federal Child Nutrition Program funds in August 2020, E. Individuals Involved in Safari Restaurant Applied to Open Additional Sites in Fall 2020 Under the Sponsorship of Feeding Our Future 66, In the fall of 2020, individuals associated with Safari Restaurant enrolled additional sites in the Federal Child Nutrition Program under the sponsorship of Feeding Our Future, These sites were run by new companies created for use in participating in the Federal Child Nutrition Program, including ASA Limited LLC and Olive Management Inc. These sites quickly began reporting that they were serving meals to large numbers of children on a daily basis. 1. ASA Limited LLC 67. According to Minnesota Secretary of State records, Abdihakim Ali Ahmed created ASA Limited LLC on or about September 4, 2020. That same day, ASA Limited LLC completed an application to enroll in the Federal Child Nutrition Program under the sponsorship of Feeding Our Future. The application and accompanying “New Site Intake” form stated that ASA Limited LLC would be serving both breakfast and lunch to 3,000 children on Saturday and Sundays, Abdihakim Ahmed signed the application on behalf of ASA Limited LLC. Aimee Bock signed the application on behalf of Feeding Our Future, In correspondence with MDE, Bock explained that ASA Limited would be “serving youth living in St. Paul” and “in an’ area that does not have other culturally appropriate food sites.” 68. ASA Limited immediately began claiming that it was entitled to large amounts of Federal Child Nutrition Program funds. For example, ASA Limited 19claimed that it was entitled to more than $700,000 in Federal Child Nutrition Program funds for meals served in September and October 2020. 69. Inall, MDE records show that ASA Limited has received more than $5.3 million in Federal Child Nutrition Program funds since its creation in September 2020. 2. Olive Management 70, Minnesota Secretary of State records show that Olive Management was eveated by Ahmed Omar-Hashim in September 2020. That same month, the company submitted an application to participate in the Federal Child Nutrition Program under the sponsorship of Feeding Our Future, The application stated that Olive ‘Management would be serving both breakfast and lunch, totaling 2,500 meals a day. Ahmed Omar-Hashim signed the application on behalf of Olive Management and. Aimee Bock signed on behalf of Feeding Our Future, The application included an agreement between Feeding Our Future and Olive Management authorizing Feeding Our Future to charge administration fees “not to exceed 10 percent” of the Federal Child Nutrition Program reimbursements received by Olive Management. 71. Olive Management immediately began claiming that it was entitled to large amounts of Federal Child Nutrition Program funds. For example, the company claimed that it was entitled to more than $1.2 million in Federal Child Nutrition Program funds for meals served from September to November 2020. 72. In all, MDE records show that Olive Management: has received more than $5.2 million in Federal Child Nutrition Program funds since its creation in September 2020. 20F, Feeding Our Future Filed a Lawsuit After MDE Terminated Safari Restaurant from the Federal Child Nutrition Program 73. Tn the fall of 2020, MDE raised concerns about the number of new sites being sponsored by Feeding Our Future. MDE also questioned the size of the reimbursements being claimed by these sites. For example, in a September 2020 letter to Feeding Our Future, an MDE employee noted that Safari Restaurant “is projected to serve a comparable number of meals” to “the entire St, Paul Public School District.” MDE asked Feeding Our Future to “[p}lease explain how Safari Restaurant has this capacity to serve this number of meals, the need for these meals, and how the site is promoted.” 74, In October 2020, MDE terminated Safari Restaurant's participation in the Federal Child Nutrition Program effective October 31, 2020. During this same time frame, MDE utilized a multi-step review process for approving new sites to ensure that Federal Child Nutrition Program funds were being used properly. 76. In November 2020, Feeding Our Future sued MDE for failing to process its site applications. In the complaint, Feeding Our Future claimed that MDE was unlawfully refusing to approve their site applications and unlawfully withholding payments of Federal Child Nutrition Programs funds to sites under Feeding Our Future's sponsorship. Feeding Our Future alleged that, as a result, “[thousands of qualified children, in low-income and minority communities are going without desperately needed federal food programs because MDE refuses to process Feeding Our Future's applications.” Feeding Our Future further alleged that MDE had violated the Minnesota Human Rights Act by “discriminating” against Feeding Our 2Future due to its “eaterfing] to members of a protected class of racial minorities and foreign nationals.” 76. As this litigation has proceeded, Safari Restaurant and related entities have continued to receive millions of dollars from the Federal Child Nutrition Program. As explained below, a review of bank records shows that this money was not used to feed children, Instead, the bull of the money was stolen and used to, among other things, purchase expensive cars and real estate, G. Feeding Our Future and Safari Restaurant Provided Fake Documentation to MDE 77. In January 2021, MDE conducted an audit of Feeding Our Future. This audit was triggered, in part, by suspicions about the large amount of Federal Child Nutrition Program money being received by Feeding Our Future and sites under its sponsorship, In responding to that audit, Feeding Our Future provided claim detail yeports and summer meal counts that purport to document the meals served by Safari Restaurant in March 2021. 78. Feeding Our Future also submitted weekly meal count forms for certain days in March 2021 as part of its response to MDE’s audit. These weekly meal count forms stated that Safari Restaurant prepared both breakfast and lunch for 6,000 children a day, seven days a week, in March 2021. The meal count forms indicate that for each of these days, Safari Restaurant actually served between 5,991 and 5,999 children, 22@G seoncourroes SUMMER MEAL COUNTS — CLICKER ae aaa [st [niente [om [DS Sa ana ra ita [0/01/27 ipsa [a = st ah eee = a Hthorbe” chest receheioress_ a ee re 1000 Heo00 |ea0o) aera ee le age Coane Seer | mw | seo a |e Wun ef haar reet eae | aq 15994599 Gls 948] sana} sana anaemia 17 3 Sete ascaauewecremaa=——=t{—[e-[ epee ete eae Frac rea ae [4s ir Sk te |e a oe ee a Sama [laa ia | Lon [WA Seimei! || be le |e la te 7 het be te tele eneromeyenmreneme=™ | (| ss [AS [AS [As [AS lon Saran a ee eae exe [eZ Tow [03 fat ZL 79. According to Feeding Our Future's audit response, Safari Restaurant served meals to children all 31 days of March 2021. In all, the response stated that Safari Restaurant served 185,908 children in March 2021. Safari Restaurant received approximately $1,143,303 in Federal Child Nutrition Program funds based on these claims for March 2021 alone. Feeding Our Future received an additional $95,740 on top of this amount for administering Safari Restaurant's participation in the Federal Child Nutrition Program in March 2021, 80. By way of comparison, the average McDonalds franchise has approximately $2.9 million in annual revenue, according to QSR, a trade magazine for the quick-service and fast-casual restaurant industry.! 1 See https:/iwww.qsrmagazine.com/content/these-29-fast-food-brands-carn-most- restaurant (last accessed Nov. 2, 2021), 2381. Feeding Our Future and Safari Restaurant also appear to have submitted false invoices purporting to support their reimbursement claims. For example, on or about August 3, 2021, an accountant sent an email to Bock with the subject line “INVOICES.” Attached to the email was a PDF document titled “INVOICES FOR SAFARI SITES:pd£” The document consisted of five separate invoices to Feeding Our Future from Safari Restaurant and sites run by the Safari Restaurant group—Stigma Free Mankato, Stigma Free Willmar, Brava Restaurant, Olive Management, and ASA Limited. Each of the invoices was dated July 81, 2021. ‘And each of the invoices was identical. The invoices charged for the serving of 2,000 meals per day for all 31 days of July 2021. They billed Feeding Our Future at a vate of $7.11 per meal. This resulted in charges of $14,220 a day and $440,820 for the month for each of the five sites. EERREGS TEETER [EEEEETSEEEEER 2482. In total, the five invoices sent on August 3, 2021, billed $2,204,100 to Feeding Our Future, which was responsible for distributing Federal Child Nutrition Program funds to these sites. This $2.2 million was for the one month of July 2021, IV. SAFARI RESTAURANT AND RELATED ENTITIES MISAPPROPRIATED $15 MILLION IN FEDERAL CHILD NUTRITION PROGRAM FUNDS 83, Bank records show that more than $15 million in Federal Child Nutrition Program funds were deposited into bank: accounts held by Cosmopolitan Business Solutions dba Safari Restaurant between May 2020 and November 2021. 84. A review of these accounts shows that little of this money was used to buy food or other items xelated to participation in the Federal Child Nutrition Program. Instead, the most significant withdrawals from the Safari Restaurant accounts were transfers to limited liability companies controlled by owners or associates of Safari Restaurant. This money was then used to purchase real estate, cars, and other luxury items. 85. For example, bank records show that approximately $7.9 million was deposited into an account at Bridgewater Bank between October 2020 and July 2021. ‘More than $6.9 million of this amount represented Federal Child Nutrition Program funds from Feeding Our Future (most of the remaining $1 million was transferred 25from velated corporate entities), The account did not show any significant deposits from the operation of the restaurant or event center. 86. Bank records show that almost none of the Fedeval Child Nutrition Program funds deposited into this account were used to purchase food to prepare and. feed to children. Instead, the majority of the money deposited into the account was transferred to limited liability companies owned or controlled by owners of Safari Restaurant. In all, bank yecords show that approximately $5.3 million was transferred to LLCs controlled by owners or associates of Safari Restaurant. Entity Entity owner/account | Amount Transferred Bank Account(s) _| holder (approximate) 3017 LLC Abdulkadir Nur Salah. $1.9 million Salim Limited LLC Salim Said $1.4 million Afra Grill LLC Abdirahman Ahmed $1.35 million Sagal Aden AG Limited LLC Ahmed Ghedi $694,000 ‘Total $5.3 million 87. Safari Restaurant also has accounts at Bell Bank. Abdulkadir Nur Salah is the signatory on the accounts. Approximately $6.5 million was deposited into the account, between approximately July 15 and November 30, 2021, More than $6.2 million (or 92 percent) were Federal Child Nutrition Program funds received from Feeding Our Future. 88, Again, bank records show that almost none of this money was used to purchase food. Instead, a large portion of this money was transferred to limited liability companies owned or controlled by owners of associates of Safari Restaurant. 26In all, bank records show that approximately $1.1 million was transferred to companies owned or controlled by the owners of Safari Restaurant. Bntity Entity owner/account | Amount holder ‘Transferred is (approximate) ‘ASA Limited LLG | Abdihakim Ahmed {$859,000 Salim Said Ahmed Ghedi 3017 LLG ‘Abdulkadir Nur Salah $138,000 ‘Salim Limited LLG | Salim Said $25,000 1130 Holdings Ine._| Abdihakim Ahmed $82,000 Total $1,114,000 89, Another $1,909, 100 was transferred to bank accounts held by two other entities—Tunyar Trading LLC and Horseed Management LLC. Entity ntity owner/account | Amount Received from holder Safari Restaurant (approximate) Tunyar Trading LLC ‘Abdikadix Mohamud $956,400 Horseed Management LLC | Abdinasir Abshir $952,700 ‘Total $1,909,100 90. Both Tunyar Trading LLC and Horseed Management LLC were set up in September-October 2020. According to Minnesota Secretary of State records, ‘Tunyar Trading LLC was formed on or about September 28, 2020, and Horseed. Management LLC was formed on October 9, 2020. Both Tunyar Trading and Horseed Management: had vendor contracts to provide food or meals to sites sponsored by Feeding Our Future. According to these contracts, Feeding Our Future would pay the companies $2.13 per breakfast and $3.67 per lunch. 2791, Both companies opened bank accounts into which millions of dollars in fraudulently obtained Federal Child Nutrition Program funds flowed, But bank veeords show that these companies did not use these funds to buy food or prepare meals. Instead, the companies appear to function essentially as shell companies designed to help launder misappropriated and fraudulently obtained Federal Child Nuizition Program funds 92. Tunyar Trading had accounts at US Bank, JP Morgan Chase, and ‘TruStone Financial Credit Union. More than $4 million was deposited into these accounts in 2021. Almost all of this money came from Safari Restaurant or other entities whose owners appear to be fraudulently obtaining Federal Child Nutrition Program funds, including Safari Restaurant and Stigma-Free International Inc. Entity Owner ‘Amount Transferred to Tunyar Trading LLC in 2021 (approximate) Stigma-Free International | Ahmed Artan $3,154,216 Ine. Cosmopolitan Business | Salim Said $504,859 Solutions dba Safari Ahmed Ghedi Restaurant Abdihakim Ahmed Abdulkadir Nur Salah Salim Limited LLC Salim Said $65,000 ‘Horseed Management LLC | Abdinasir Abshir $56,701 ‘AG Limited LLC Ahmed Ghedi $30,000 ‘Total $8,900,776 93. Stigma-Free International Inc. is another company that appears to be fraudulently receiving Federal Child Nutrition Program funds under the sponsorship of Feeding Our Future. Records obtained from U.S. Bank and Bank of America show that Stigma-Free International Inc. received more than $6.5 million from FeedingOur Future since January 2021. Bank records show that none of this money was used to purchase food or meals for underprivileged children. Instead, the bulk of the money was transferred to entities controlled by individuals associated with Safari Restaurant, 94, Although bank records show that Stigma-Tvee did not use the Federal Child Nutrition Program funds to purchase food or prepare meals, the company aimed to be serving meals to thousands of children a day. For example, in September 2021, the owner of Stigma Free, Abdikadir Mohamud, sent an email to Aimee Bock with the subject line “Willmar Meal Count/Invoice for September.” Attached to the email were "Summer Meal Counts” claiming that Stigma Free served 2,000 meals a day, seven days a week during August 2021 in Willmar, Minnesota. 29FEEDING CUR FUTURE SUMMER MEAL COUNTS — CLICKER Sine [eons OR FRE tot [eettetainatanon [Prove [6550002 Ste [sa rez WHA feel Aiktale teow (t talc | Mest Type, BREAKFAST [ teuwor Pte ae Saar [aw [rr [mie [or | | er | Taber of men eee [aoe |2ou | 200 |e00 fase _hio00 eb co on yest @ |e le Iv |v [¢ |e |e Me oun a [oar [er [ee [er | n_[ we | ume of tat erected Tag [i995 | tas | 1499 [igen [avn [ideo Tings. ber fc edo rn aoa 3 a re Tank af edt ROPE amet ete fe ier nea redone as ren « ete ]e anon fre rerg netfee n [3 FOOD TEMPERATURE Ion |e nb farm henge amet a © |v le Nar ofr re = ele sfc ng yen ck ate le | © le envio Tn some 1 ha aba 95. According to the latest census data, only 21,000 people live in Willmar. 96. Bank records show that little of the money deposited into the Tunyar ‘trading LLC accounts was used to purchase food or meals to serve to underprivileged children. Instead, the bulk of the money was transferred to other limited liability companies and entities, including entities controlled by owners of associates of Safari Restaurant. 97. Similarly, records of the accounts held by Horseed Management LLC show that those accounts also appear to have served as pass through accounts: through which money was transferred to and from entities involved in fraudulently obtaining Federal Child Nutrition Program funds. 30