C250211_Form_700_Review_03-25-26.pdf
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- Solicitation number
- 250211
- Issued by
- Orange County, California
About this file
This file is a Form 700 conflict of interest review memorandum from OCTA General Counsel James M. Donich regarding RFP 25-0211 for an ADA WCAG Title II Assessment. The Orange County Transportation Authority (OCTA) issued a Request for Proposals to procure consultant services for a comprehensive accessibility assessment of the Authority's digital assets against Web Content Accessibility Guidelines (WCAG) 2.1 Level A and AA success criteria or the most current applicable standard. The solicitation is for a time and expense type professional services contract with a budget of $350,000 for an eighteen-month term.
Based on General Counsel's review of the scope of work, OCTA determined that Form 700 filings would not be required for personnel performing the contracted duties. The General Counsel opinion concluded 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 consultant personnel would provide information, opinions, or recommendations affecting decisions without significant intervening substantive review by OCTA personnel, counsel, and management. This determination was provided in response to Form 700 procedures required by OCTA as a result of an Internal Audit.
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Rhea Aninzo
From: James M. Donich <jdonich@woodruff.law> Sent: Wednesday, March 25, 2026 8:45 AM To: Georgia Martinez Cc: Rhea Aninzo Subject: Re: Form 700 Review: RFP 250211 ADA WCAG Title 2 Assessment
I have reviewed the SOW for RFP 25-0211 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: Georgia Martinez <gmartinez@octa.net> Sent: Tuesday, March 24, 2026 8:01 PM To: James M. Donich <jdonich@woodruff.law> Cc: Rhea Aninzo <raninzo@octa.net> Subject: FW: Form 700 Review: RFP 250211 ADA WCAG Title 2 Assessment
Hi James, As part of the Form 700 procedures that CAMM is required to follow as a result of an Internal Audit, attached please find the scope of work for the “ADA WCAG Title 2 Assessment” for your review. This is a professional services procurement and will be issued as a time and expense type contract for a consultant perform a comprehensive accessibility assessment of OCTA’s digital assets against the Web Content Accessibility Guidelines (WCAG) 2.1 Level A and AA success criteria, or the most current applicable standard.
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, Georgia Martinez Department Manager, Contracts and Procurement Contracts Administration and Materials Management Orange County Transportation Authority
714.560.5605 | 714.560.5792 550 South Main Street | PO Box 14184 | Orange, CA 92863-1584
From: Rhea Aninzo <raninzo@octa.net> Sent: Monday, March 23, 2026 8:14 AM To: Georgia Martinez <gmartinez@octa.net> Subject: Form 700 Review: RFP 250211 ADA WCAG Title 2 Assessment
Hi Georgia, Please find the attached scope of work for Form 700 review.
Thank you, Rhea
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