◆ SpookStack

@2 UNCLASSIFIED To: San Diego From: San Diego Re: 205-SD- , 03/15/2011 Operates, there are ample facts and indicators which reflect that Sempra and its business executives may have engaged in criminal activity so as to justify the opening of a full investigation. STATEMENT OF THE AUTHORIZED PURPOSE: A full investigation will be conducted in order to determine whether a federal crime has occurred, to identify, locate, .and apprehend co-conspirators, and to obtain evidence necessary for prosecution. FEDBRAL VIOLATION: The above facts and circumstances indicate that the captioned subject and individuals employed by the subject participated in violations of 15 U.S.C. §§ 78dd-1, the Foreign Corrupt, Practices Act. INITIAL INVESTIGATIVE STRATEGY: The initial investigative strategy consists of identifying those documents and other evidence indicating that Sempra employees had knowledge of and concealed a scheme to bribe Mexican officials, identifying and interviewing witnesses to the criminal conduct, and interviewing the individuals identified as subjects. PROSECUTORIAL OPINION: DOJ Fraud Section Deputy chief eer and Assistant Uni Attorney (Southern District o Galifornia)| Jaze currently the assigned prosecutors on this matter, an ave been involved in all m . date with Sempra representatives and witnesses. Both andl wer! have agreed to prosecute any meritorious case] ZS develope bé b7C through the investigation of this matter. + UNCLASSIFIED 5