AN 3.101 gold washer, ☸Dhamma-vitakka💭 in this context defintely is the vitakka of first jhāna

 These are all the occurrences of 'Dhamma vitakka' in the suttas. 

AN 8.30 is especially explicit, unambiguous, unequivocal in giving eight examples of linguistic, verbal thoughts, right before using the same word, vitakka, to describe standard formula for first jhāna.

Because AN 3.101 doesn't explicitly call out which jhānas the samādhi is referring to, Sujato tries to use AN 3.101 in support of his erroneous interpretation of vitakka in first jhāna being non linguistic, non verbal, non-thought even.

But AN 8.30 makes it unequivocal that first jhāna is using a verbal vitakka. 

4👑☸ → EBpedia📚 → ☸Dhamma-vitakka💭 

• DN 22 part of 6 sense base vitakka vicara dependent origination of tanha/craving
• MN 10 (in burmese canon same as DN 22)
• AN 3.101 simile of gold, first jhana
• AN 5.73 Dhamma vitakketi (verb), oral tradition, samatha and jhana
• AN 7.95 just listing dhamma-vitakka as part of 6 sense base, as in DN 22
• AN 8.30 eight great Dhamma-vitakka thoughts for first jhana
• AN 11.22 just listing dhamma-vitakka as part of 6 sense base, as in DN 22
• KN Iti 86 dhamma and not dhamma thoughts in “dhamma-anu-dhamma-patipanna”
• KN Snp 5.14 Dhamma-takka equivalent, using four jhanas to realize nirvana

(KN Snp 5.14 is 'Dhamma-takka' in verse, which often for meter reasons, will use variations on standard terms, for example 'pekkhamano' and 'avekkhanta' are obviously 'upekkha' in Snp 5 context).