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UNCLASSIFIED To: San Diego From: San Diego Re: 205-SD-72665, 06/15/2011 In response to the medi cles and 'contact from Sempra, separate meetings with and his attorney, and Sempra representatives were conducted.. Representatives from U.s. Department of Justice (DoJ) Fraud Section, the Usao sdcA, the U.S. Securities and Exchange be Commission (sec) and the FBI were present. The. b7C interview is documented in a separate FD-302. The meeting between the DoJ, FBI, 'sEc, and Sempra outside counsel was memorialized in a separate Ec,. dated 02/10/2011. In summary, advised that he was instructed by aoaad uengxnn 0oo'o8t apdaoad o? aaondun eadend bugyuex-ybty e from Sempra's bank -account to Sempra employee. who would (AG's) office. was told the purpose of the bond was to cover any damages that may result from the physical eviction of peay eadeed yogee oa epeueeeg ut Aaaadoad uo paaeeee aaaaaenbs legal title. Due to circumstances arising since this transaction, came to the belief that the cash paid to. the AG's office was a'bribe to an official(s) at the AG's office to evict individuals from the pronerty. The property dispute. between the squatter and Sempra is on- going. Sempra hired an independent law firm with expertise in 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 the Ag's office evidencing the bond. At the request of DOJ, was made available for an interview, which is documented in a separate FD-302. advised that he used the money to legitimately obtain a bona rrom the AG's b6 office. In response to a DoJ request to provide documentation b7C from the Ag's "office' that-the bond was still pending, Sempra later confirmed that the money was still being held by the AG's office and provided a copy of the check when the money was returned to Sempra from the Ag's office. Given the evidence. provided by Sempra to refute allegation, DoJ concluded that no further investigation was necessary regarding this specific allegation. At Sempra's request, DoJ provided two separate declination letters related to this specific allegation, which are maintained in the case file. UNCLASSIFIED 2