◆ SpookStack

UNCLASSIFIED To: San Diego From: San Diego Re: SD 205-0, 02/17/2011 1977 (FcpA) would have no jurisdiction in this matter for these three reasons: 1.) the FcpA applies to foreign sovereignties, and although Native American reservations are dependent political communities, they are ultimately under the sovereignty of the U.S.; 2.) in legislative history, the FcpA was established to address concerns with business conducted with foreign countries; and 3.) a separate statute within Title 18, United States Code (Usc) 666 covers bribes with Native American tribes. From 2008. to 2010, Sempra partnered with International Piping Products, Inc. (Ipp) to negotiate a lease aqreement for a b6 Arizona Chapter) Council. On 06/03/2010. b7C aaaressea a letter to of the NN, expressing Sempra's decisior the wind project proposal due to "lack of satisfactory progress" (Tab A-1). In August of 20i0, the NN Council informed Sempra and. IPp that circumstances surrounding the wind project had changed and encouraged both parties to attend a NN Resources Committee meeting on 09/23/2010. IPp Agent who lived on the Navajo Nation reservation, accepted the invitation; however, no Sempra employees attended. During this meeting, Resolution No. c0-42-10 reestablished negotiations for the wind project. between Sempra, IPP and the NN. On 10/21/2010, the NavajowTribal Council met to vote on the above resolution. NN Council Delegate announced that he would not vote on the resolution because he had been offered campaign funds at the 09/23/2010 meeting to "vote green." Attending NN members admonished not to make this allegation simply because he was on the losing end of a favorable vote. The resolution subsequently passed. On 11/08/2010. asya result of bribery allegation and other concerns, laddressed a memorandum to stating that he yeeeed b6 the Counc b7C Tab A-2). followed with a letter to on 11/12/2010, which expressed that Sempra stood f1rm on their decision to cease negotiations on the wind project, that Sempra took the bribery accusation seriously, and that consequently, Sempra initiated an independent review of the allegation (Tab A- 3). The NN and Rules Office (NNERo) interviewed on 11/16/2010 reaardina his allegation. On 11/18/2010, NN Council Delegate provided a memorandum to UNCLASSIFIED 2