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O O UNCLASSIFIED To: San Diego From: San Diego Re: 205-SD-72665, 06/15/2011 later provided to Writer via e-mail several be documents which initiated additional follow-up with Sempra by BIC DOJ. These e-mails are documented in a separate EC, dated 02/28/2011. As a result, DOJ requested that Sempra outside counsel: (1) conduct an investigation of any cash transactions in Mexico over the last four years; (2) conduct an investigation of any charitable or political donations exceeding $25,000 made by Sempra to Mexican officials or entities over the last four years, to include specifically the transactions associated with a fire station given by Sempra as a charitable donation to Tijuana; (3) .conduct an inquiry into the allegations that Sempra offered cash to members of the Navajo Nation Council to vote in favor of a Sempra resolution; (4) conduct a review of consultants and agents hired in Mexico over the last four years. Sempra outside counsel assembled responses to all of the above inquiries, which are documented in a separate EC, dated 02/17/2011. Based on Sempra's responses, it was determined that further investigation was warranted concerning a trust (Ensenada Trust or the Trust) established by Sempra for charitable donations to the Ensenada community. According to Sempra outside counsel, the primary purpose for establishing the Trust was to engender goodwill amongst Ensenada community members. Between 2004 and present, Sempra donated over $7 million to the Ensenada Trust. Currently $1.8 million of the total $7 million has been designated or spent. The Trust is overseen by two boards, one of which includes two Sempra employees and local citizens. In response to questions from DOJ, Sempra outside counsel was unable to provide immediate answers concerning oversight of the Ensenada Trust, to include whether an independent audit of the fund is regularly conducted, if due diligence is performed on donation recipients, and the names of board members, to include whether any public officials have served as board members, and whether those board members are paid a salary. Sempra outside counsel agreed to research these issues and provide answers to DOT" s questions. — 7 - j al Sempra accounting memorandum provided to Writer py eT aated February 11, 2005, appears to refute Sempra outside counsel's explanation for the initiation of the Trust and raised additional concerns regarding Sempra’ s accounting treatment of the C ust. was written by bE Cos Sempra LNG at the time the memorandum was byc written and current Chief Executive Officer of Sempra LNG. The memorandum states that the Ensenada Trust was established at the UNCLASSIFIED 3