C250014_Form_700_Review_Email_2025-09-12.pdf

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Attached to
Harbor Boulevard Transit Signal Priority Deployment
Solicitation number
250014
Issued by
Orange County, California

About this file

This is a Form 700 conflict of interest determination email from OCTA's General Counsel regarding the Harbor Boulevard Transit Signal Priority Deployment Project (RFP 250014). The Orange County Transportation Authority (OCTA) requested a legal review to determine whether consultant personnel performing work under this solicitation would be required to file Form 700 declarations under OCTA's Conflict of Interest Code. The project involves a technology-driven solution for transit signal priority deployment on Harbor Boulevard in California. The Procurement Contracts Administration and Materials Management (CAMM) department submitted the scope of work for review as part of Form 700 procedures required following an internal audit.

OCTA's General Counsel James M. Donich provided a written determination that personnel performing duties under this RFP would not be required to file Form 700s. The determination was based on the finding that consultant personnel would not authorize or direct actions, votes, appoint persons, obligate or commit OCTA to any course of action, or enter into contractual agreements on behalf of OCTA. Additionally, no personnel provided by the RFP would furnish information, opinions, or recommendations affecting decisions without substantial intervening substantive review by OCTA personnel, counsel, and management. This determination effectively exempts the contractor from Form 700 filing requirements for this project.

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From: James M. Donich To: Iris Deneau Subject: Re: Form 700 Review - RFP 250014 Date: Friday, September 12, 2025 8:59:29 AM

I have reviewed the SOW for RFP 5-0014 Harbor Blvd Transit Signal Priority Deployment 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: Thursday, September 11, 2025 at 2:41 PM To: James M. Donich <jdonich@woodruff.law> Subject: Form 700 Review - RFP 250014

Hi James, mailto:jdonich@woodruff.law mailto:ideneau@octa.net mailto:jdonich@woodruff.law https://nam11.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.yourdomain.url%2F&data=05%7C02%7Cideneau%40octa.net%7C9588994dbbcf4dc2e88008ddf2155911%7C1e952f6cc8fc4e38b476ab4dd5449420%7C0%7C0%7C638932895689342915%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=iojUbpGcb8vsFZX3vUoJB4u01EqMqQ2B22t45m0vtD0%3D&reserved=0 https://nam11.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodruff.law%2F&data=05%7C02%7Cideneau%40octa.net%7C9588994dbbcf4dc2e88008ddf2155911%7C1e952f6cc8fc4e38b476ab4dd5449420%7C0%7C0%7C638932895689365132%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=83hU9OLduok3STK5lPpBEJzGb8CU4t2SygzpYxN9%2Fow%3D&reserved=0

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 Harbor Boulevard Transit Signal Priority Deployment. 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.

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.

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