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O O UNCLASSIFIED To: San Diego From: San Diego Re: SD 205-0, 02/10/2011 i were: FBI Spe SEC attorneys ssistant United State¢ OD Baker & McKenzie was hired by Sempra to conduct an internal bé investigation of the Foreign Corrupt Practices Act (FCPA) bic allegation. | | presented the results of Baker & McKenzie's vestigation, which ultimately c at [__fatiegations were without weriec[ [vas one of empra employees laid off in early 2010 Sempra's [within in Force" program. Sempra attempted to relocate within the Company, but was unable to identify a position for him. L FCPA allegation j e company concerned a cash transaction in which was involved to execute the eviction of a squatter on in Ensenada Mexico to which Sempra held legal title. Sempra had initiated a legal proceeding in Mexico, known as a" " ispossession, proceeding against the squatter, and was informed by the Ensenada Attorney neral's S$) Office that a bond would be required to cover any damages that may result from the physical eviction of the squatters. Several options existed for posting the bond, including a cash deposit, mortgage, pledge, trust, personal bond or corporate bond. Sempra was notified on or about 09/13/2006 that a small bond would be required for the Despojo and that the execution order would take place between be 3:00am and 5:00am on 09/15/2006. Since Sempra was given only one day to post the bond, Sempra's only option was to pay cash to post. the bond since every other method would have required more than one day to obtain. [vas instructed to withdraw 180,000 Mexican pesos from sempra’s bank account and give the cash to Sempra employee who would post the bond with the Ensenada AG's office. overnment affairs attorney i xi} inc} was scheduled t , id as instructed an pesos 's Energia C BBVA Bancomer. rovi of t ck evidencj withdrawal of cash by When arrived at office on 09/14/2006 to retrieve the cash, otfere UNCLASSIFIED 2