United States v. Mahad Ibrahim · PIN's control of the claim process & the co-defendants who fixed the numbers · § 1B1.3 / § 3553(a)(6)
What this shows. When a claim was missing documents, wrong, or held up, PIN staff sent an email asking someone to produce it, correct it, or pad it after the fact. This exhibit maps that fix mechanism from the government's own discovery: PIN — the sponsor — controlled the claim process and drove the after-the-fact fixing, and the co-defendants (Empire) carried it out. Mr. Ibrahim appears only for contrast — to show he had no hand in fabricating or inflating the numbers. (His own operational role is the subject of a separate exhibit.)
The document-fix requests ran between the sponsor and the fabricators. PIN (Kara Lomen, Jodie Luzum) asked Abdiaziz Farah, Abdimajid Nur, and Hayat Nur to add counts, resend rosters, backfill menus and food-production records, and run adjustments — and the software vendor executed the count changes. Of 39 claim-fix requests, Mahad Ibrahim is absent from 35; on the four where he appears he is only cc'd, mentioned, or forwarding — never the requester, never the author. Across all 68 demand-side emails he authored zero fixes. Where he appears at all it is on administrative notices (rosters, training logs, the 500-limit rule) as a copied recipient. The claim is not that he had no role — it is that he had no role in fabricating or inflating the numbers.
39
claim-fix requests — every one originated by PIN (Lomen / Luzum)
3
co-defendants who executed the fixes (Farah, A. Nur, H. Nur) + software vendor
0
of those fixes authored by Mahad Ibrahim
68
demand-side emails reviewed (government Bates)
Category A — fixing the numbers
fabricating / inflating the numbers
Post-submission demands to correct counts, resend missing rosters, backfill prior-month menus / food-production records, and run claim adjustments. Includes the January 2022 thread where counts were adjusted upward by thousands.
Requested by PIN (Lomen / Luzum) → executed by Farah · Abdimajid Nur · Hayat Nur and the software vendor.
Mahad Ibrahim: absent from 35 of 39 · authored 0 · (the other 4: cc’d / mentioned / forwarding)
Category B — administrative & compliance
onboarding / rules / rosters
Roster setup, duplicate-children compliance notices, training-log requests, point-of-service reminders, the 500-meal limit. PIN's own rule sent the actual roster edits back to PIN: "Do not add or remove your own children in software … all roster updates should be sent to Partners in Quality Care."
Addressed to the recipient group Farah + Mahad + Bianca Scott, cc PIN site-support.
Mahad Ibrahim: a copied recipient on 23 · authored 0
- He was never the requester. Every demand originates with PIN — Kara Lomen or Jodie Luzum. Mahad asks no one to fix a count.
- He was never the fixer. The counts, rosters, menus, and food-production records were produced or corrected by Abdiaziz Farah, Abdimajid Nur, and Hayat Nur; the count adjustments were executed by the software vendor (My Food Program).
- He authored zero fixes. On the 16 administrative emails where he is a copied recipient, he replies with no correction and produces no document. The record shows him receiving notices, not repairing claims.
Scope & caveats. Government discovery, PIN lane only (TTA / Mind Foundry sites; requesters at Partners in Quality Care). The Feeding Our Future / Afrique lane is a separate matter and is excluded. Custodian coverage is strongest for Abdiaziz Farah, Abdimajid Nur, and Mahad's Mind Foundry mailbox; PIN emails sent only to other TTA addresses may be under-captured and would require the @thinktechact / @mindfoundry custodians. Two events are marked needs-verify in the detail view. For counsel review before any external use.
How a claim's paperwork got built or repaired after the fact — and where Mr. Ibrahim was in that cycle. Click any box to see the underlying emails.
1 · The request
PIN — the sponsor
Kara Lomen · Jodie Luzum · controlled the claim process
"add the rest" · "claims I cannot run" · "fill out a new meal count sheet"
asks to fix / produce / backfill
→
2 · The fix
The co-defendants (Empire)
Abdiaziz Farah · Abdimajid Nur · Hayat Nur
count adjustments executed by the software vendor
corrected & backfilled documents
→
3 · The claim runs
Reimbursement claimed
PIN certifies & submits to MDE via CLiCS
↻ the corrected paperwork returns to PIN, and the claim is run
◆ Mahad Ibrahim — a recipient/conduit at the edges, never the author
0
fix requests he originated
0
document fixes he authored
27
emails he appears on (23 admin · 4 claim-fix) — all as recipient / cc / conduit
The clearest instance: in January 2022, meal counts were corrected upward by +3,018 / +2,790 / +3,444 — routed between Hayat Nur, the software vendor, and PIN. Mr. Ibrahim is on none of it.
▸ click a box above to jump to those emails
These emails ask for four kinds of thing. Here is what each is and why it matters to loss and relevant conduct.
Missing-document requests
PIN tells the operator a claim is missing meal counts, rosters, menus, or food-production records and asks for them — often for a month already past.
Why it matters: the substantiation behind a claim is being assembled after the meals were supposedly served. Example: "Claims I cannot run" — nine sites missing November counts/menus/FPRs, requested December 9 (GJS-00476592).
Corrections
PIN flags that a number is wrong — a discrepancy, a mismatched invoice, or too few children for the meals claimed — and asks for it to be changed.
Why it matters: this is where the claimed numbers are altered. Example: "add the rest" — March attendance was 1,023 children but counts were 1,100/day, so PIN asks the operator to add 77 more (EML-00001446).
Backfill
A prior period's document is requested or created late — a "new meal count sheet" for a day already gone, or menus for months already claimed.
Why it matters: PIN's own rule says counts must be taken at point of service and that late counts are ineligible — yet the record shows late counts being built. Example: "fill out a new meal count sheet … include 9/4 … can you get this done today?" (EML-00004251).
Claim-holds
PIN states it is holding or cannot run a claim until the documents are supplied or fixed.
Why it matters: it shows PIN — not TTA or Mr. Ibrahim — controlled whether and when a claim was submitted. Example: "I haven't ran Al-Ihsan or Winfield because the meal counts were incorrect" (EML-00003220, Jodie Luzum).
A note on Food-Production Records (FPRs)
An FPR documents what food was actually prepared and served — the proof tying a claimed meal to real food. The sponsor required a completed FPR before a claim could be submitted.
In this record FPRs were authored on the vendor / restaurant side, not by Mr. Ibrahim — PIN's own February 2022 request lists "Food Production Records — Entered by the vendor or restaurant" (Mind Foundry mailbox, 2/7/2022).
In every category the requests run from PIN to the fabricators, and the fixes are authored by them or the software vendor. See Every request & correction to inspect each email, its Bates number, and — where produced — the source document.
Category
Request
PIN asker
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About this view. Each tile is a demand-side email from the government's discovery — click the thumbnail to open the actual Bates-stamped email (PDF). The quote is the request text; the flow line shows who asked and who was asked to fix it. Tiles outlined in red are the ones Mr. Ibrahim was copied on — on those he authored no correction. 66 of 68 emails have the source image in hand; 2 (marked) are in discovery without a local copy. PIN lane only; discovery PDFs are confidential — for counsel review before external use.