C250435_FORM_700.pdf
PDF 382 KB Posted
- Attached to
- Public Outreach Services for the State Route 55 Improvement Project between Interstate 5 and State Route 91
- Solicitation number
- 250435
- Issued by
- Orange County, California
About this file
This is a legal correspondence file regarding Form 700 conflict of interest compliance determinations for the Orange County Transportation Authority (OCTA) related to RFP 25-0435 for Public Outreach Services supporting the State Route 55 Improvement Project between Interstate 5 and State Route 91. The correspondence, dated June 29, 2026, documents OCTA General Counsel James M. Donich's legal opinion on whether consultant personnel performing services under this solicitation would be required to file California Form 700 declarations. The project is structured as a professional services procurement with a firm-fixed contract vehicle and encompasses a five-year initial term with a total budget of $2,359,750.00.
In his determination, General Counsel Donich concluded that Form 700 filing would not be required for personnel providing services under this RFP. The legal opinion was based on the analysis that consultant personnel would not authorize or direct actions, votes, appoint persons, obligate OCTA to courses of action, or enter into contractual agreements on behalf of OCTA. Additionally, the opinion noted that no personnel provided under this RFP would furnish 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 that OCTA's Contracts Administration and Materials Management (CAMM) section was required to implement following an internal audit.
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From: James M. Donich To: Rebecca Abeyta Cc: Michael Cardozo Subject: Re: FORM 700 Review RFP 250435 State Route 55 Improvement Project Between Interstate 5 and State Route
91 Public Outreach Support Date: Monday, June 29, 2026 9:48:31 AM Attachments: linkedin_32x32_efaa60bc-61e3-49c7-9eae-b11d0d4add83.png instagram_32x32_6fd2d21d-23da-4a28-969b-2e0d145a9d7d.png
I have reviewed the SOW for RFP 25-0435 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 www.woodruff.law Celebrating 50 years of excellence
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On Jun 29, 2026, at 11:23 AM, Rebecca Abeyta <rabeyta@octa.net> wrote:
Hello 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 (“State Route 55 mailto:jdonich@woodruff.law mailto:rabeyta@octa.net mailto:mcardozo@octa.net mailto:%7bE-mail%7d https://nam11.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.linkedin.com%2Fcompany%2Fwoodruffsmart%2F&data=05%7C02%7Cmcardozo%40octa.net%7C9138e60386c14a24b04308ded5fe3a5a%7C1e952f6cc8fc4e38b476ab4dd5449420%7C0%7C0%7C639183485106040682%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=zMCfAp2S2n46%2FuNG5QiJ1CfIQy%2BAOy%2BmPaDhwSpPRZA%3D&reserved=0 https://nam11.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.instagram.com%2Fwoodruff_smartapc%3Figsh%3DNTc4MTIwNjQ2YQ%253D%253D%26utm_source%3Dqr&data=05%7C02%7Cmcardozo%40octa.net%7C9138e60386c14a24b04308ded5fe3a5a%7C1e952f6cc8fc4e38b476ab4dd5449420%7C0%7C0%7C639183485106071500%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=BtikZExvdg%2F%2FfvWMSgC4LJ5jVgGi88sTLwbdbUM4eQA%3D&reserved=0 https://nam11.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodruff.law%2F&data=05%7C02%7Cmcardozo%40octa.net%7C9138e60386c14a24b04308ded5fe3a5a%7C1e952f6cc8fc4e38b476ab4dd5449420%7C0%7C0%7C639183485106086501%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=htHkDGK6K%2BM2rWSMgXROzskl1h3gI%2FI0TpWnwPzmBrI%3D&reserved=0
Improvement Project Between Interstate 5 and State Route 91 Public Outreach Support)” for your review. This is a professional services procurement and will be issued as a firm-fixed contract for State Route 55 Improvement Project Between Interstate 5 and State Route 91 Public Outreach Support.
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.
Rebecca Abeyta Section Manager, III Contracts Administration and Materials Management Orange County Transportation Authority ( 714.560.5478 | 7 714.560.5792 550 South Main Street | PO Box 14184 | Orange, CA 92863-1584
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