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“As chairman, Lorraine was not responsible for day-to-day campaign activities and performed the duties she had during her personal time,” Amtrak spokesman Steve Kulm said of Ms. Green’s work with the Gray campaign.

“Likewise, as the leader of the transition team, she is doing that work on her own time,” he said.

“Prior to accepting the positions, she sought and received guidance and clearance from Amtrak. It was determined that her activities are within the guidelines of Amtrak’s own ethics and conflict of interest policies and other applicable laws.”

In announcing Ms. Green as its chairman, the Gray transition team referred to her on its web site — www.graytransition2010.org — as “a corporate executive with more than 25 years of private sector and government experience in the areas of financial management, procurement, contracting and human resources.”

A biography of Ms. Green on the Gray website also notes that she is a native of Washington and a D.C. Public Schools graduate who was twice confirmed by the U.S. Senate as the deputy director of the Office of Personnel Management and as a member of the bipartisan U.S. Census Monitoring Board.

In a profile of Mr. Gray that appeared in The Washington Post in September, Mr. Gray referred to Ms. Green as his closest friend and adviser. They first met when Mr. Gray was in charge of the city’s Department of Human Services under then-D.C. Mayor Sharon Pratt.