RFP_250389_Form_700_Legal_Response.pdf

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Attached to
Foreign Language Translation Services
Solicitation number
250389
Issued by
Orange County, California

About this file

This is a legal determination document from the Orange County Transportation Authority's (OCTA) General Counsel regarding Form 700 filing requirements for RFP 25-0389, Foreign Language Translation Services. OCTA issued a Request for Proposals to solicit qualified consultants to provide foreign language translation services with a budget of $150,000 for a five-year term. The document does not specify response dates, due dates, site visits, or bidder's meetings; however, it confirms that this is a professional services procurement to be awarded as a firm-fixed price contract.

Based on OCTA General Counsel James M. Donich's review of the Scope of Work, the personnel performing translation duties under this RFP would not be required to file Form 700s under OCTA's Conflict of Interest Code. The determination was made because 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 the agency. Additionally, any information, opinions, or recommendations provided by RFP personnel would undergo significant intervening substantive review by OCTA personnel, counsel, and management before affecting any decisions. This legal opinion clarifies that no conflict of interest filing requirements apply to the awarded contractor's personnel.

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From: James M. Donich To: Rebecca Abeyta Cc: Andrew Coppolo Subject: Re: RFP 250389 - Foreign Language Translation Services - Correction Date: Thursday, June 4, 2026 10:30:33 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 25-0389 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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From: Rebecca Abeyta <rabeyta@octa.net> Sent: Thursday, June 4, 2026 10:01 AM To: James M. Donich <jdonich@woodruff.law> Cc: Andrew Coppolo <acoppolo@octa.net> Subject: RFP 250389 - Foreign Language Translation Services - Correction mailto:jdonich@woodruff.law mailto:rabeyta@octa.net mailto:acoppolo@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%7Cacoppolo%40octa.net%7C5ce952ab114848f1f54a08dec25ef713%7C1e952f6cc8fc4e38b476ab4dd5449420%7C0%7C0%7C639161910326386394%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=vkChAWYWdtO7olHE%2BNneA1UVl2RJwvMfF9IDL1f9Ipk%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%7Cacoppolo%40octa.net%7C5ce952ab114848f1f54a08dec25ef713%7C1e952f6cc8fc4e38b476ab4dd5449420%7C0%7C0%7C639161910326433084%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=w%2BA02KaHynu7wm5vJC2JirdDvJ4UD5sElqkluyxA2dw%3D&reserved=0 https://nam11.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodruff.law%2F&data=05%7C02%7Cacoppolo%40octa.net%7C5ce952ab114848f1f54a08dec25ef713%7C1e952f6cc8fc4e38b476ab4dd5449420%7C0%7C0%7C639161910326449820%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=qfIz%2FcDEHLXRU82OiZ%2F0sr3oQZ%2F8lneKzQaXyWu5rAQ%3D&reserved=0

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 “Foreign Language Translation Services ” for your review. This is a professional services procurement and will be issued as a firm-fixed contract for Foreign Language Translation 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.

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

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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