◆ SpookStack

UNCLASSIFIED To: San Diego From: San Diego Re: 205-SD- 73645, 03/15/2011 In response to the media articles and contact from separate meetings with and his attorney, and Sempra representatives were conducted. b6 b7C Representatives from U.S. Department of Justice. (DoJ) Fraud Section, the Usao sDcA, the U.S. Securities and, Exchana.. Commission (Sec) and the FBI were present. The interview is documented in a separate FD-302. The 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. empioyee. to provide 180 000 Mes an pesos from Sempra's bank account to Sempra employee who would. d,nenauag Raunonay epeuaaug ayn yaem puog e nsod o? Aauoe ay? asn (AG's) office. was told the purpose of the bond was to b6 cover any damages that may result from the physical eviction of b7C legal title. Due to circumstances arising,'since this transaction, came to the'belief/that the cash paid to. the Ag's office was a bribe to an official(s) at the Ag's office to evict individuals from the propertv. The, 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 inyestigation 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 the Ag's office evidencing the bond. At the request of DOJ, was made available for an interview,. which is documented in a separate FD-302.. advised that he used the money to legitimately obtain a bona rrom the AG's office. In response to a DoJ request to provide documentation.. from the AG's office that the bond was still pending, Sempra b6 later confirmed that the money was'still being held'by the AG's b7C office and provided a copy of the check when the money was returned to Sempra from the AG's. office. Given the evidence provided by Sempra to refute. allegation, DoJ concluded that no further investigation was necessary regarding this. specific allegation.. later provided to Writer via e-mail several DOJ. These e-mails are documented in a separate Ec, dated. UNCLASSIFIED 2