◆ SpookStack

) 130ecp03 ee (Rev. 05-01-2008) a) UNCLASSIFIED FEDERAL BUREAU OF INVESTIGATION Precedence: ROUTINE : Date: 05/10/2011 Tot San Diego From: San Diego Squad WC3 be Contact: SA BIC Approved By: Case ID #: 205-SD-72665 (Pending)*Joe - Title: SEMPRA ENERGY; FOREIGN CORRUPT PRACTICES ACT Synopsis: To document investigative activity regarding FCPA allegations against Sempra Energy (Sempra or the Company). GS Details: On 04/29/2011, a meeti tween the following articipants: FBI Special Agents and curities and Exchange Commission ( attorney via telephone), Assistant United States Attorney Justice (DOJ) Deputy Chief ia telephone), and Attorneys of Jones Day law firm € purpose of discussing Sempra's Ensenada Trust (the Trust) and Sempra's use of agents/vendors in Mexico. All documents provided during this meeting will be maintained in the 1A section of the case file. b6 b7C Ensenada Trust Sempra enacted the Trust for the-purpose of -- establishing good corporate citizenship in Ensenada due to Sempra's intentions to build a liquified natural gas (LNG) facility in the area. Prior to establishing the Trust, Sempra obtained an outside counsel opinion from Winston and Strawn, LLP specifically for the purpose of determining whether the terms of the Trust would violate the Foreign Corrupt Practices Act (FCPA). HSBC Bank, headquartered in London, is the trustee. The funding of the Trust followed the following schedule: UNCLASSIFIED ROS-So-7 ICS HQ