C250131_Form_700_Legal_Counsel_Response_12-16-25.pdf
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- Solicitation number
- 250131
- Issued by
- Orange County, California
About this file
This is a legal counsel response from the Orange County Transportation Authority (OCTA) General Counsel regarding Form 700 filing requirements for RFP 25-0131, the Los Angeles 2028 Olympics Transportation Service Plan and Capital Needs Assessment project. The project, procured as a time and materials contract with a budget of $950,000 over a twenty-month term, seeks qualified consultants to develop a comprehensive transportation framework, service plan, and capital needs assessment in preparation for the 2028 Summer Olympic and Paralympic Games in Los Angeles. OCTA's General Counsel, James M. Donich, provided written determination that personnel performing work under this solicitation would not be required to file Form 700s under OCTA's Conflict of Interest Code.
In his legal opinion, General Counsel Donich determined that the consultant personnel anticipated by this RFP 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 under this RFP would provide information, opinions, or recommendations for the purpose of affecting decisions without significant intervening substantive review by OCTA personnel, counsel, and management. This determination was made following a recent Internal Audit requiring OCTA's Contracts Administration and Materials Management (CAMM) section to implement enhanced Form 700 procedures for federally funded projects administered through the Federal Transit Administration.
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Gina Torres
From: James M. Donich <jdonich@woodruff.law> Sent: Tuesday, December 16, 2025 9:05 AM To: Iris Deneau Cc: Gina Torres Subject: Re: 700 Form - RFP 250131 LA28 Olympics Planning
I have reviewed the SOW for RFP 25-0131 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 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: Tuesday, December 16, 2025 at 7:32 AM To: James M. Donich <jdonich@woodruff.law> Cc: Gina Torres <gtorres@octa.net> Subject: FW: 700 Form - RFP 250131 LA28 Olympics Planning
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 LA28 Olympics Planning. 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: Monday, December 15, 2025 4:09 PM To: Iris Deneau <ideneau@octa.net> Subject: 700 Form - RFP 250131 LA28 Olympics Planning
Hi Iris, Please see attached SOW for RFP 250131 LA28 Olympics Planning. 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.
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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