The District paid another vendor $17,800 for meetings with state legislators, community outreach and activities related to the private company. We reviewed e-mails between this vendor and District personnel and governing members of the private company. We also examined the original contract scope of work, budget documents and business plan and conducted interviews with District staff and the vendor. We determined all activities billed to the District by this vendor were related to the private company. The program manager approved a personal services contract with this vendor that listed work.