250182_Response_from_James_M_Donich__Form_700_Review_-_HP_Printer_Maintenance.pdf
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- Attached to
- HP Printer Maintenance
- Solicitation number
- 250182
- Issued by
- Orange County, California
About this file
This file is a legal opinion from James M. Donich, General Counsel at Woodruff Sawyer & Associates, regarding Form 700 conflict of interest filing requirements for the Orange County Transportation Authority's (OCTA) HP Printer Maintenance contract. The opinion addresses whether consultant personnel performing maintenance duties under this RFP would be required to file Form 700 declarations under OCTA's Conflict of Interest Code. The HP Printer Maintenance contract is a five-year term agreement effective April 1, 2026 through March 31, 2031, with a budget of $100,000 for on-call maintenance services with no guaranteed usage.
General Counsel Donich determined that personnel providing HP printer maintenance services would not be required to file Form 700 declarations. The opinion concludes that maintenance personnel would not have authority to authorize or direct actions, cast votes, appoint persons, obligate OCTA to courses of action, or enter into contractual agreements on behalf of OCTA. Additionally, no information, opinions, or recommendations provided by such personnel would affect OCTA decisions without substantial intervening review by OCTA personnel, counsel, and management. This determination was made following OCTA's recent Internal Audit, which prompted the Procurement, Contracts Administration and Materials Management (CAMM) department to implement enhanced Form 700 review procedures for solicitations.
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From: James M. Donich To: Iris Deneau Cc: Desiree Fernandez Subject: Re: Form 700 Review - HP Printer Maintenance Date: Monday, February 2, 2026 9:37:27 AM
I have reviewed the SOW for HP Printer Maintenance 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
James M. Donich Shareholder D: 714-415-1015 jdonich@woodruff.law 555 Anton Boulevard, Suite 1200 Costa Mesa, California 92626 Celebrating 50 years of excellence www.woodruff.law
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From: Iris Deneau <ideneau@octa.net> Date: Saturday, January 31, 2026 at 4:24 PM To: James M. Donich <jdonich@woodruff.law> Cc: Desiree Fernandez <dfernandez1@octa.net> Subject: Form 700 Review - HP Printer Maintenance mailto:jdonich@woodruff.law mailto:ideneau@octa.net mailto:dfernandez1@octa.net mailto:jdonich@woodruff.law https://nam11.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.yourdomain.url%2F&data=05%7C02%7Cdfernandez1%40octa.net%7C19a107acd07a40d4617108de6281b7dd%7C1e952f6cc8fc4e38b476ab4dd5449420%7C0%7C0%7C639056506465170427%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=yhPnitKC%2FWDeVb%2BTHwdcrIeH1afe2GxYTF0GLpvqLTE%3D&reserved=0 https://nam11.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodruff.law%2F&data=05%7C02%7Cdfernandez1%40octa.net%7C19a107acd07a40d4617108de6281b7dd%7C1e952f6cc8fc4e38b476ab4dd5449420%7C0%7C0%7C639056506465200126%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=3CpUhiVFUtf%2F4tzYmNehx07%2FobFi0j913%2FRsRQ%2BZoDc%3D&reserved=0
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 HP Printer Maintenance. 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
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