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UNCLASSIFIED To: San Diego From San Diego Re: SD 205-0, 02/10/2011 were: FBI Special Agents. and SEC attorneys Assistant United States Attorney (AusA). DOJ Deputy Chief (Fraud Section) Attorneys and i.rm esenting Sempra, and Attorneys and Baker & McKenzie. b6 investigation of the Foreign Corrupt Practices Act (FcpA) b7C allegation. presented the results of Baker & McKenzie's internal nvestigation, which ultimately concluded that.. allegations were without merit.. was one of 90 Sempra employees laid off in early 2010! F Sempra's 2010 "peduction in Force" program. Sempra attempted to relocate within the Company, but. was unable to identify a. position for him. FcpA allegation aaainst the company concerned a cash transaction in which was involved to execute the eviction of a squatter on property in Ensenada Mexico to which Sempra held legal title. Sempra had initiated a legal proceeding in Mexico, known as a "Desnoio.' dispossession,. proceeding against the squatter,. and was informed by the Ensenada Attorney General's (Ag's) Office that a eong aonaan Aew nean sabeeep Aue naaen on pannnban aq ponom pueq 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 b6 3:00am and 5:00am on 09/15/2006. Since Sempra was given only one b7C 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. was instructed to withdraw 180,00o 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. government affairs attorney in Mexico. Coincide was scheduled to be id as instructed and pesos at'bBVA Bancomer. provjded cony of the check evidencina the. withdrawal of cash by. When arrived at. office on 09/14/2006~to offered UNCLASSIFIED 2