250204__Response_from_James_M_Donich__Form_700_Review_-_On-Call_Videography_Services_Bus_Safety.pdf
PDF 403 KB Posted
- Attached to
- On-Call Bus Safety Videography Services
- Solicitation number
- 250204
- Issued by
- Orange County, California
About this file
This is a legal correspondence from OCTA General Counsel James M. Donich regarding Form 700 compliance requirements for an on-call videography services contract. The Orange County Transportation Authority (OCTA) sought a legal determination on whether personnel providing on-call video production services for bus safety would be required to file Form 700 declarations under OCTA's Conflict of Interest Code. The contract opportunity involves one-year on-call video production services with a budget of $100,000, effective April 1, 2026 through March 31, 2027.
Following his review of the Scope of Work, General Counsel Donich determined that Form 700 filings would not be required for personnel performing these videography services. His determination was based on the finding that consultant personnel would not authorize or direct actions, votes, or appointments; would not obligate or commit OCTA to any course of action; would not enter into contractual agreements on behalf of OCTA; and would not provide information, opinions, or recommendations affecting decisions without substantial intervening substantive review by OCTA personnel, counsel, and management. This legal opinion cleared the way for the procurement to proceed without the additional Form 700 documentation requirements that would otherwise apply under California's conflict of interest regulations.
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From: James M. Donich To: Iris Deneau Cc: Desiree Fernandez Subject: Re: Form 700 Review - On-Call Videography Services Bus Safety Date: Wednesday, February 4, 2026 10:29:37 AM
I have reviewed the SOW for On-Call Videography Services 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> Sent: Tuesday, February 3, 2026 2:40 PM To: James M. Donich <jdonich@woodruff.law> Cc: Desiree Fernandez <dfernandez1@octa.net> Subject: FW: Form 700 Review - On-Call Videography Services Bus Safety 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%7C2081a829199e473e91d808de641b55e7%7C1e952f6cc8fc4e38b476ab4dd5449420%7C0%7C0%7C639058265764639274%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=DbwhTfNRGPmgz03AhTrNmrjceTERfLUmw6H5Q8Somyc%3D&reserved=0 https://nam11.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodruff.law%2F&data=05%7C02%7Cdfernandez1%40octa.net%7C2081a829199e473e91d808de641b55e7%7C1e952f6cc8fc4e38b476ab4dd5449420%7C0%7C0%7C639058265764673894%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=D5b%2BLGkAkuVdq8rxyXH3U0RL0WaefGFh9ON6QkzxOok%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 On-Call Videography Services Bus Safety. 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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From: Desiree Fernandez <dfernandez1@octa.net> Sent: Tuesday, February 3, 2026 12:07 PM To: Iris Deneau <ideneau@octa.net> Subject: Form 700 Review - On-Call Videography Services Bus Safety
Hi Iris, Can you please send this to James, when you have a chance.
Thank you, Desiree Fernandez
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