C250090_Form_700_Legal_Counsel_Response_11-3-25.pdf
PDF 1 MB Posted
- Attached to
- Community Engagement Consultant Services
- Solicitation number
- 250090
- Issued by
- Orange County, California
About this file
This is a legal counsel response memorandum from the Orange County Transportation Authority (OCTA) General Counsel addressing Form 700 filing requirements for RFP 250090, which seeks Community Engagement Consultant Services. The RFP solicits qualified consultants to assist with planning, implementation, and evaluation of a community outreach program targeting Orange County's underserved and underrepresented communities. The project has a budget of $885,000 for an initial two-year term. The memorandum was issued on November 3, 2025, in response to a request from OCTA's Procurement, Contracts Administration and Materials Management (CAMM) section to determine whether consultant personnel performing these services would be required to file Form 700 Statements of Economic Interest under OCTA's Conflict of Interest Code.
OCTA General Counsel James M. Donich determined in his written opinion that this RFP and its associated Scope of Work do not require Form 700 filings from consultant personnel. The determination was based on the finding that anticipated consultant personnel would not authorize or direct actions, votes, appoint personnel, obligate or commit OCTA to any course of action, or enter into contractual agreements on behalf of OCTA. Additionally, the counsel noted that no personnel provided under this RFP would provide information, opinions, or recommendations intended to affect decisions without significant intervening substantive review by OCTA personnel, counsel, and management. The contract will be procured on a time and materials basis.
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Gina Torres
From: James M. Donich <jdonich@woodruff.law> Sent: Monday, November 3, 2025 10:03 AM To: Iris Deneau Cc: Gina Torres Subject: Re: 700 Form - RFP 250090 Community Engagement Consultant Services
I have reviewed the SOW for RFP 5=0090 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
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From: Iris Deneau <ideneau@octa.net> Sent: Monday, November 3, 2025 9:11 AM To: James M. Donich <jdonich@woodruff.law> Cc: Gina Torres <gtorres@octa.net> Subject: FW: 700 Form - RFP 250090 Community Engagement Consultant Services
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 Community Engagement Consultant Services. 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 | 714.560.5792 550 South Main Street | PO Box 14184 | Orange, CA 92863-1584 CAMM - Procurement with Integrity Please consider the environment before printing this e-mail.
From: Gina Torres <gtorres@octa.net> Sent: Thursday, October 30, 2025 3:19 PM To: Iris Deneau <ideneau@octa.net> Subject: 700 Form - RFP 250090 Community Engagement Consultant Services
Hi Iris, Please see attached SOW for RFP 250090 Community Engagement Consultant Services. This will be procured as a time and expense contract.
Thank you, Gina Torres | Senior Contract Administrator Contracts Administration and Materials Management Orange County Transportation Authority
714.560.5566 | 714.560.5792 550 South Main Street | PO Box 14184 | Orange, CA 92863-1584 CAMM - Procurement with Integrity Please consider the environment before printing this e-mail.
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