◆ SpookStack

O O UNCLASSIFIED To: San Diego From: San Diego Re: 205-SD-72665, 06/15/2011 In response to the m les and ‘contact from Sempra, separate meetings with and his attorney, and Sempra representatives were conducted. Representatives from U.S. pepartment of Justice (DOJ) Fraud Section, the USAO SDCA, the U.S. Securities and Exchange Commission (SEC) and the rr were present. the] interview is documented in a separate FD-302. € meeting between the DOJ, FBI, SEC, and Sempra outside counsel was memorialized in a separate EC, dated 02/10/2011. In summary, advised that he was instructed by a high-ranking Sempra employee to provide veel i pesos from Sempra's bank account to Sempra employee who would use the money t ond with the Ensenada orney General's (AG's) office. a told the purpose of the bond was to cover any damages at may result from the physical eviction of squatters located on property in Ensenada to which Sempra held legal title. ircumstances arising since this transaction,[/ fame to the belief that the cash paid to the AG's off Was a bribe to an official(s) at the AG's office to evict individuals property dispute between the squatter, and Sempra is on- going. Sempra hired an independent law firm with expertise in FCPA matters to conduct an internal investigation of the above allegation. In summary, the internal investigation concluded that the cash payment was not a bribe but was used toward the legitimate posting of a bond with the AG's office. Sempra provided certified copies of the legal documents that were obtained from t ! ice evidencing the bond. At the request of o03,P | was made availa an interview, which is documented in a separate ro-302. [advised that he used the money to legitimately obtain a bo m the AG's office. In response to a DOJ request to provide documentation bye ~~~ from “the AG's office that the bond was still pending; Sempra——-——— later confirmed that the money was still being held by the AG's office and provided a copy of the check when the money was returned to Sempra from the ' Given the evidence provided by Sempra to refute allegation, DOJ concluded that no further investigation was necessary regarding this specific allegation. At Sempra's request, DOJ provided two separate declination letters related to this specific allegation, which are maintained in the case file. UNCLASSIFIED 2