C250113_Form_700_Review_11-12-25.pdf
PDF 1 MB Posted
- Attached to
- Move OC Active Transportation Plan
- Solicitation number
- 250113
- Issued by
- Orange County, California
About this file
This file is an internal legal memorandum from the Orange County Transportation Authority (OCTA) General Counsel regarding Form 700 conflict of interest filing requirements for RFP 250113, the Move OC Active Transportation Plan project. The memorandum documents OCTA's determination that consultant personnel performing work under this solicitation would not be required to file Form 700 declarations of economic interests. The General Counsel's opinion is based on the scope of work analysis, which indicates that consultant personnel would not authorize or direct actions, votes, appoint persons, obligate OCTA to any course of action, or enter into contractual agreements on behalf of OCTA. The determination was requested by OCTA's Procurement Contracts Administration and Materials Management section as part of Form 700 procedures required following a recent internal audit.
The Move OC Active Transportation Plan project is budgeted at $1,000,000 for a three-year contract term with the Orange County Transportation Authority in California. The legal review confirms that while the consultant will provide services, any information, opinions, or recommendations they provide would require significant intervening substantive review by OCTA personnel, counsel, and management before affecting any agency decisions. This determination ensures clarity regarding conflict of interest compliance obligations for potential bidders and the selected consultant on the project.
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Rhea Aninzo
From: James M. Donich <jdonich@woodruff.law> Sent: Wednesday, November 12, 2025 8:47 AM To: Iris Deneau Cc: Rhea Aninzo Subject: Re: Form 700 Review: RFP 250113 "Move OC"
I have reviewed the SOW for RFP 5-0113 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> Sent: Tuesday, November 11, 2025 8:04 AM To: James M. Donich <jdonich@woodruff.law> Cc: Rhea Aninzo <raninzo@octa.net> Subject: FW: Form 700 Review: RFP 250113 "Move OC"
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 Move OC. 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: Rhea Aninzo <raninzo@octa.net> Sent: Monday, November 10, 2025 11:16 AM To: Iris Deneau <ideneau@octa.net> Subject: Form 700 Review: RFP 250113 "Move OC"
Hi Iris, Please find the attached scope of work for Form 700 review.
Thank you, Rhea 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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