Defense work record · United States v. Ibrahim · Counsel work product
Professional Roles & Market Value
What the email record shows Mr. Ibrahim actually did — classified into the professional roles it documents, drawn from his own mailboxes (Mind Foundry, 2016–2022; Afrique / Zawadi, 2020–2021), and what those roles cost to hire in the market.
The correspondence does not show one job. It shows one person performing the functions of several distinct senior roles at once, across two organizations (plus his own consulting firm, Gobee) — the profile of a founder/operator who wears every hat. Each role below is evidenced by specific, dated work streams in the underlying record.
The roles the record documents
Director of Operations / Operations Executive
Mind Foundry · Afrique
$85k–$140k+ / yr
or fractional/consulting COO
Ran day-to-day operations across both ventures — hiring and HR systems, payroll, licensing and regulatory compliance, insurance, and back-office systems.
Documented in the record
- Breezy ATS & Gusto HR-systems build-out MF · 2017
- DHS pre-licensing site inspections & compliance corrections MF · 2020–21
- Arcoro ATS + Kraus-Anderson HR implementation AF · 2021
- Gusto payroll setup, administration & policy AF · 2021
- HR policy — handbook, job descriptions, wage bands AF · 2021
- xtraCHEF ↔ Toast accounting/POS integration AF · 2021
Owner's Representative / Development Project Manager
Afrique — ground-up facility buildout
$95k–$140k / yr
or owner's-rep ~$100–200+/hr
Directed the design and construction of a commercial hospitality facility from the ground up — the building that opened as Afrique and now operates as Zawadi — coordinating architect, MEP engineer, general contractor, kitchen, AV/low-voltage, and municipal approvals.
Documented in the record
- New-site buildout & municipal approval — 1701 American Blvd E AF · 2021–22
- Facility design & permit-phasing — architect, MEP engineer, land-use counsel AF · 2021
- Commercial kitchen design & walk-in cooler/freezer build AF · 2021
- Audiovisual & low-voltage systems buildout AF · 2021
- Special inspections & final building-permit approval AF · 2021
- General contractor engagement (Contract Design) AF · 2021
Procurement / Purchasing Manager
Afrique — foodservice, multi-location
$65k–$100k / yr
foodservice procurement
Sourced and managed food and supply procurement across multiple locations — vendor accounts, weekly ordering and logistics, pricing and volume negotiation — and openly documented purchases to the principals. The Sysco relationship alone runs to roughly 780 emails.
Documented in the record
- Sysco account setup, credit terms & Sysco Pay across locations AF · 2021
- Weekly Sysco ordering & multi-location logistics (Owatonna/Warehouse/MPLS) AF · 2021
- Product sourcing, substitutions & pricing negotiation AF · 2021
- General Mills K-12 bid pricing setup AF · 2021
- Open reporting of purchases/invoices to the operating principals AF · 2021
- Point-of-sale & inventory systems (Toast, MarketMan) AF · 2021
Curriculum Developer / Education Program Director
Mind Foundry · Afrique (menus)
$65k–$115k / yr
designer → program director
Designed educational curricula and ran youth enrichment programs; separately developed institutional food-program menus to federal meal-pattern standards.
Documented in the record
- STEM/coding curriculum design (Short Circuits, Coding Club, Digital Worlds) MF · 2017
- Culturally-responsive literacy curriculum MF · 2019–20
- GEMS/ROV robotics enrichment with the City of Minneapolis MF · 2018
- Youth Program Quality Assessment (YPQA) adoption MF · 2017
- School / At-Risk meal-pattern menu development AF · 2021
- CACFP whole-grain menu compliance & dietitian coordination AF · 2021
Grant Writer / Development Officer
Mind Foundry
$60k–$95k / yr
or consultant $75–150/hr
Wrote and pursued competitive grants and public funding, and conducted legislative funding advocacy.
Documented in the record
- 21st Century Community Learning Centers application to MDE MF · 2019
- Wege Foundation $100,000 grant pursuit MF · 2021
- Hennepin County COVID-19 relief grants MF · 2020
- Best Buy Foundation grant (Storytelling Studio) MF · 2017–18
- J.D. Graves Foundation & Minneapolis Foundation grants MF · 2017–22
- MN House Education Finance bill (HF 3879) advocacy MF · 2018
Business Development / Partnerships Lead
Mind Foundry · Afrique
$90k–$140k+ / yr
partnerships & contracts
Built and negotiated partnerships and contracts with school districts, public agencies, foundations, and vendors.
Documented in the record
- Minneapolis Public Schools multi-year contract renewal MF · 2020–22
- Aflah Tutoring partnership (4 charter schools + 170 daycares) MF · 2019
- St. Paul City School after-school contract (Wilder Foundation) MF · 2017
- City of Minneapolis service contract (CPED) MF · 2018
- Caspian Realty lease & multi-property setup AF · 2021
- Vendor/platform contracts (BentoBox, Tripleseat, Ryder, Beledweyne) AF · 2021
A seventh, supporting function — marketing & brand production (apparel, vehicle graphics, video/content, printed materials) — recurs across both ventures and would ordinarily be a further paid role or agency spend.
What it adds up to
One person, several jobs, at once
In a normally staffed organization, the functions above are four to six separate salaried positions. The record shows one person covering all of them — simultaneously, across two organizations, while also running his own consulting firm. That is the direct answer to “money for nothing”: the documented labor maps to multiple real, compensable professional roles, performed at the same time.
Valued as separate roles
~$350k–$600k+ / yr
Illustrative combined salaried cost of hiring out the functions the emails document — before pricing the facility-buildout project-management work, which is often billed separately.
Valued at his own market rate
$270 / hr
The rate Mr. Ibrahim actually commanded (Gobee Group). For a senior multi-domain operator, that is squarely within — arguably at the conservative end of — the market (senior operations/management consultants commonly bill $200–500+/hr).
How to read these figures
- Illustrative, not an opinion. The role classifications and dollar ranges are a reasoned read of the record against general U.S. market knowledge — not a valuation opinion. For any filed use, retain a vocational or forensic economist to confirm the role classifications against the documented tasks and attach defensible figures (BLS/OES data, salary surveys).
- Email under-counts the work. The record cannot see phone calls, in-person work, or the finished deliverables themselves, so any hours-based figure is a floor, not a ceiling.
- This values the labor, not the money. The analysis speaks only to what the professional work was worth. It says nothing about the source of any venue funds — a separate question this exhibit does not address.