In July 2021, a senior deputy in Orange County’s Office of County Counsel, known in the halls of government as “CoCo” and headed by Leon Page, raised a red flag. According to the County’s forensic audit, the deputy told the Health Care Agency that the County needed to “review the contract with 360 [Clinic] and assess/determine whether they are in compliance with their contractual terms.”
Three months later, with that review still open, the agency’s director asked Supervisor Andrew Do for the go-ahead to pay 360 Clinic $814,650, citing “concerns over a potential lawsuit.” Andrew Do gave it, and the County paid. A question of legal risk was settled by a Supervisor, not by the County’s lawyer. The review CoCo’s own deputy had requested was overtaken.
Whose lawyer is CoCo? The law is clear. “The Los Angeles County Counsel has only one client, namely, the County of Los Angeles,” a California appeals court wrote in Ward v. Superior Court. California’s Rule of Professional Conduct 1.13 says “the client is the organization itself.”
CoCo’s client is the County and its residents. Not the Supervisors, not the department heads, not the senior managers. But in Orange County, CoCo has become part of a poor governance culture rather than a check on it.
That client relationship carries an affirmative duty. When an official’s conduct threatens the organization, Rule 1.13 says the lawyer “shall proceed as is reasonably necessary in the best lawful interest of the organization,” up to taking the matter “to the highest authority” that can act. The rule’s commentary adds that a government lawyer “may have authority … to question such conduct more extensively” than a private company’s lawyer. That duty doesn’t shrink when the official is elected and department heads are going along. That is exactly when it matters most. A lawyer for the County, having spotted a problem, shouldn’t just walk away.
The pattern repeated in 2023. Staff raised a conflict of interest involving Do’s daughter and asked in writing, “Please advise if we need to reach out to CoCo.” Nobody did. The agency director rebuked the staffer for raising it: “Supervisor Do was an attorney and he would know if there was a conflict.”
According to the auditor, CoCo learned of the conflict only in November 2023, when the press exposed it. That is no excuse. A lawyer with a duty to protect the County doesn’t wait to be invited. Even after the scandal broke, nine months passed with no public action by CoCo. Then came demand letters and a lawsuit that named the nonprofit and Do’s daughter, but not Andrew Do. He was added as a defendant only after agreeing to plead guilty to federal charges. Every month of delay means money can vanish and suspects can flee. Peter Pham, who ran the nonprofit at the center of the scheme, is today a “fugitive from justice,” according to prosecutors.
Then there is the Fraud Hotline, meant for reporting wrongdoing. CoCo has run it since 2015, and the auditor found that the Do conflict “was not reported through the County’s fraud hotline.” The general manager of the county employees’ union offered this explanation: “Many believe the hotline is neither anonymous nor trustworthy, with some experiencing backlash after reporting issues.” Leon Page himself described the hotline as “fundamentally … a management tool.” A management tool cannot protect the County from its managers. CoCo appears to serve the managers rather than the County.
It isn’t just history. On May 5, 2026, the Board approved a retroactive renewal of a Sheriff’s contract with Federal Technology Solutions, adding $900,000 for a contract term that had begun on March 1. CoCo’s review: “Approve agreement to form.” Such retroactive approvals, rare elsewhere, are routine in OC, and every one I reviewed this year carries CoCo’s sign-off. The County’s own Contract Policy Manual says “Retroactive contracts or contract overruns are not permitted,” citing the state Constitution. Why does CoCo raise no objection when managers commit the County before Board review?
Public lawyers elsewhere have acted for their organization, even against those at the top. In San Francisco, the City Attorney’s own public-integrity investigation found wrongdoing by two department heads, who then resigned. Just up the freeway, the city of Bell sued its former city manager. It also sued its own former city attorney for failing to stop officials from paying themselves outsized salaries. In Orange County, by contrast, senior managers are treated as beyond question.
The fixes:
- Make the duty concrete. When CoCo learns that an official may be harming the County, it must notify the full Board and the elected Auditor-Controller in writing.
- Conflict-of-interest allegations should go in writing to CoCo or an independent ethics office, as the forensic auditor recommended, and never be settled by a department head alone.
- Stop the rubber stamp. CoCo should flag every retroactive contract to the Board as a breach of County policy instead of approving it “as to form.”
- Move the Fraud Hotline to the Auditor-Controller, and tell whistleblowers what came of their reports.
- Give the head of CoCo a single, non-renewable term, with no reappointment to angle for.
County department heads may be CoCo’s friends, but they are not CoCo’s clients. The County and its taxpayers are. Until CoCo starts serving them, CoCo is part of the problem.
Michael Mavrovouniotis retired from a research career in finance and academia.
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