◆ SpookStack

“ between the squatter. office. In response to a DOJ request to provide. documentation | Q UNCLASSIFIED To: San Diego From: San Diego Rez 205-SD- 7465, 03/15/2011 In response to the ee oe and contact f separate meetings with and his attorney, and Sempra representatives were conducted. be Ssentatives from U.S. Department of Justice. (DOJ) Fraud bic, Se ¢tion, the USAO SDCA, the U.S. Securities and Commission (SEC) and the FBI were present. The| | interview is documented in a separate FD-302. e meeting between the DOJ, FBI, SEC; and Sempra outside counsel was memorialized in a separate EC, dated 02/10/2011. In sumnary,| __ pavised that he was instiucted by a high-ranking Sempra’ © provide 180 ican pesos from Sempra's bank account to Sempra employee who would use the money t ond with the Ensenada Attorney General's (AG's) office. pee ras told the purpose of the bond was to bé cover any damages at may result from the physical eviction of b7C squatters located on property in’Ensenada to which Sempra held legal title. Due to circumstances arising.’Since this transaction, came to the beliefthat the cash paid to the AG's office was a bribe to an offscial (s) at the AG's office to evict individuals property dispute’ 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 ice evidencing the bond. At the request of pos vas made availa an interview, which is documentéd in a separate FD-302. | __ bevases that he t used the money to legitimately obtain a b the AG's may be eee ‘from the AG's office that the bond was still pending, Sempra bE later confirmed that the money was’ still being held’ by the AG's BIC office and provided a copy of the check when the money was returned to Sempra from the AG! j Given the evidence provided by Sempra to refute allegation, DOJ concluded that no further investigation was necessary regarding this specific allegation. [___1ater provided to Writer via e-mail several documents which initiated additional follow-up with Sempra by DOJ. These e-mails are documented in a separate EC, dated UNCLASSIFIED 2