250036_FORM_700.pdf
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- Solicitation number
- 250036
- Issued by
- Orange County, California
About this file
This file is an internal email correspondence from the Orange County Transportation Authority (OCTA) General Counsel regarding Form 700 conflict of interest filing requirements for RFP 250036, the OC Streetcar Ridership Marketing and Customer Communications Program. The correspondence documents OCTA's legal review process, initiated in October 2025, to determine whether consultant personnel performing services under this solicitation would be required to file California Form 700 conflict of interest statements. The project involves contracting with qualified consultants to provide marketing and customer communications services for the OC Streetcar program with a total budget of $200,000 for an initial two-year contract term.
In his November 4, 2025 response, OCTA General Counsel James M. Donich provided a written determination that Form 700 filings would not be required for consultant personnel under this agreement. Donich's opinion was based on the analysis that consultant personnel would not authorize or direct actions, votes, or contractual decisions on behalf of OCTA, nor would they provide recommendations intended to affect agency decisions without significant intervening substantive review by OCTA personnel, counsel, and management. This determination satisfies OCTA's internal audit procedures requiring formal legal review of conflict of interest requirements prior to contract award.
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From: James M. Donich To: Iris Deneau Cc: Michael Cardozo Subject: Re: Review FORM 700: RFP 250036 OC Streetcar Ridership Marketing and Customer Communication Program Date: Tuesday, November 4, 2025 1:36:21 PM
I have reviewed the SOW for RFP 5-0036 as to whether the personnel performing these duties would be required to file Form 700's under OCTA's Conflict of Interest Code. Based upon my review, it is the opinion of General Counsel that this RFP and the SOW would not require the filing of Form 700's.
The consultant personnel anticipated by this RFP would not authorize or direct any actions, votes, appoint any person, obligate or commit OCTA to any course of action or enter into any contractual agreement on behalf of OCTA.
Moreover, no personnel provided for by this RFP would provide information, an opinion or a recommendation for the purpose of affecting a decision without significant intervening substantive review by OCTA personnel, counsel and management.
James Donich OCTA General Counsel
555 Anton Blvd Suite 1200 Costa Mesa CA 92626
James M. Donich Director & Shareholder D: 714-415-1015 jdonich@woodruff.law www.woodruff.law
CONFIDENTIALITY NOTICE – This e-mail transmission, and any documents, files or previous e-mail messages attached to it may contain information that is confidential or legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this transmission in error, please immediately notify the sender by telephone at 714-415-1015 or return e-mail and delete the original transmission and its attachments without reading or saving in any manner. Thank you.
From: Iris Deneau <ideneau@octa.net> Date: Tuesday, November 4, 2025 at 12:42 PM To: James M. Donich <jdonich@woodruff.law> Cc: Michael Cardozo <mcardozo@octa.net> mailto:jdonich@woodruff.law mailto:ideneau@octa.net mailto:mcardozo@octa.net mailto:jdonich@woodruff.law https://nam11.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.yourdomain.url%2F&data=05%7C02%7Cmcardozo%40octa.net%7C48ed72a5a099417e854d08de1bea2e1a%7C1e952f6cc8fc4e38b476ab4dd5449420%7C0%7C0%7C638978889807587226%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=Tp1nazFSwrQrZqMGw6m3egDwjFK%2BB4s8FVqU0ynG6Io%3D&reserved=0 https://nam11.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodruff.law%2F&data=05%7C02%7Cmcardozo%40octa.net%7C48ed72a5a099417e854d08de1bea2e1a%7C1e952f6cc8fc4e38b476ab4dd5449420%7C0%7C0%7C638978889807612833%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=GnhhusFRqofJ4TjAS%2BuGCKOxPl4e%2BkISFchQooLuiFg%3D&reserved=0
Subject: RE: Review FORM 700: RFP 250036 OC Streetcar Ridership Marketing and Customer Communication Program
Hi James, Following up on the email below. I don’t think we have a received a response.
Thank you, Iris Deneau | Section Manager, Procurement Contracts Administration and Materials Management Orange County Transportation Authority ( 714.560.5786 | 7 714.560.5792 550 South Main Street | PO Box 14184 | Orange, CA 92863-1584 CAMM - Procurement with Integrity
P Please consider the environment before printing this e-mail.
From: Iris Deneau Sent: Wednesday, October 8, 2025 1:38 PM To: James M. Donich <jdonich@woodruff.law> Cc: Michael Cardozo <mcardozo@octa.net> Subject: FW: Review FORM 700: RFP 250036 OC Streetcar Ridership Marketing and Customer Communication Program
Hi James, As part of the Form 700 procedures that CAMM is required to follow as a result of the recent Internal Audit, attached please find the scope of work for OC Streetcar Ridership Marketing and Customer Communication Program. Upon your review, please provide your written determination if the agreement awarded as a result of this solicitation will be subject to the Form 700 requirements. If you require additional information, please let me know.
Thank you, Iris Deneau | Section Manager, Procurement Contracts Administration and Materials Management Orange County Transportation Authority ( 714.560.5786 | 7 714.560.5792 550 South Main Street | PO Box 14184 | Orange, CA 92863-1584 CAMM - Procurement with Integrity
P Please consider the environment before printing this e-mail.
From: Michael Cardozo <mcardozo@octa.net> Sent: Wednesday, October 8, 2025 1:24 PM To: Iris Deneau <ideneau@octa.net> Subject: Review FORM 700: RFP 250036 OC Streetcar Ridership Marketing and Customer Communication Program
Hello Iris, Please see attached for FORM 700 review.
Thank you, Michael Cardozo | Contract Administrator Contracts Administration and Materials Management Orange County Transportation Authority ( 714.560.5627 550 South Main Street | PO Box 14184 | Orange, CA 92863-1584
The information in this e-mail and any attachments are for the sole use of the intended recipient and may contain privileged and confidential information. If you are not the intended recipient, any use, disclosure, copying or distribution of this message or attachment is strictly prohibited. If you believe that you have received this e-mail in error, please contact the sender immediately and delete the e-mail and all of its attachments.
mailto:mcardozo@octa.net mailto:ideneau@octa.net
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