2020 Order (Dkt. No. 33), as modified by this Court on March 30, 2021 (Dkt. No. 80), Pla intiff

Summary

Plaintiff Blue Flame Medical LLC's Witness List, Document 92, filed April 15, 2021 in Blue Flame Medical LLC v. Chain Bridge Bank, N.A., John J. Brough and David M. Evinger, Civil Action No. 1:20-cv-00658, in the U.S. District Court for the Eastern District of Virginia, before the Honorable Leonie Brinkema. The list is made under Rule 26 and the court's September 9, 2020 Order (Dkt. No. 33), as modified on March 30, 2021 (Dkt. No. 80). It names the witnesses the plaintiff intends to call, marked for live or deposition testimony, including defendants Brough and Evinger by cross-examination, and a separate list of witnesses it may call if the need arises. The plaintiff reserves the right to call impeachment, rebuttal and authentication witnesses. The five-page filing is signed by counsel at Schulte Roth & Zabel LLP and includes a certificate of service.

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Case 1:20-cv-00658-LMB-IDD           Document 92        Filed 04/15/21      Page 1 of 5 PageID# 605




                         IN THE UNITED STATES DISTRICT COURT
                        FOR THE EASTERN DISTRICT OF VIRGINIA
                                    Alexandria Division

                                                )
  BLUE FLAME MEDICAL LLC                        )
                                                )
                 Plaintiff,                     )
                                                )
  v.                                            )       Civil Action No. 1:20-cv-00658
                                                )
  CHAIN BRIDGE BANK, N.A.,                      )       The Honorable Leonie Brinkema
  JOHN J. BROUGH, and                           )
  DAVID M. EVINGER,                             )
                                                )
                 Defendants.                    )
                                                )
                                                )
  CHAIN BRIDGE BANK, N.A.                       )
                                                )
                 Third-Party Plaintiff,         )
                                                )
  v.                                            )
                                                )
  JPMORGAN CHASE BANK, N.A.                     )
                                                )
                 Third-Party Defendant.         )
                                                )

                    PLAINTIFF BLUE FLAME MEDICAL LLC'S WITNESS LIST

         Pursuant to Rule 26 of the Federal Rules of Civil Procedure and this Court’s September 9,

  2020 Order (Dkt. No. 33), as modified by this Court on March 30, 2021 (Dkt. No. 80), Plaintiff

  Blue Flame Medical LLC hereby discloses the following list of witness it intends to or may call to

  testify at trial. Plaintiff reserves the right to call impeachment and/or rebuttal witnesses that are

  not disclosed on this list, and to amend, supplement, or otherwise modify this list, including

  pending the outcome of any pretrial motions or order of the Court. Plaintiff also reserves the right

  to call witnesses designated or disclosed by Defendants or Third-Party Defendant, as necessary.
Case 1:20-cv-00658-LMB-IDD                 Document 92          Filed 04/15/21        Page 2 of 5 PageID# 606




  Plaintiff also reserves the right to call any witness or witnesses necessary to authenticate and/or

  establish the manner in which records were kept.

             Plaintiff anticipates presenting testimony, either live (“L”) or by deposition (“D”), or both,

  of the following witnesses at trial:

                 1. Mike Gula (L)

                 2. John Thomas (L)

                 3. Ethan Bearman (L)

                 4. John Brough (L) (by cross-examination during Plaintiff’s case as part of Blue

                     Flame Medical LLC’s case in chief)

                 5. David Evinger (L) (by cross-examination during Plaintiff’s case as part of Blue

                     Flame Medical LLC’s case in chief)

                 6. Heather Schoeppe (L) (by cross-examination during Plaintiff’s case as part of Blue

                     Flame Medical LLC’s case in chief)

                 7. Maria Cole (L) (by cross-examination during Plaintiff’s case as part of Blue Flame

                     Medical LLC’s case in chief)

                 8. Claudia Mojica-Guadron (L) 1 (by cross-examination during Plaintiff’s case as part

                     of Blue Flame Medical LLC’s case in chief)

                 9. Sean O'Malley2 (L)

                 10. Marc Prisament (L)

                 11. William Baskett (L)

                 12. Rakesh Korpal (L or D) (by cross-examination during Plaintiff’s case as part of

                     Blue Flame Medical LLC’s case in chief)


  1
      Ms. Mojica-Guadron may be contacted through counsel for Defendant Chain Bridge Bank, N.A.
  2
      Sean O'Malley, Marc Prisament, and William Baskett may be contacted through the undersigned counsel.

                                                           2
Case 1:20-cv-00658-LMB-IDD                 Document 92           Filed 04/15/21          Page 3 of 5 PageID# 607




               13. Richard Chivaro (D)

               14. Natalie Gonzales (D)

               15. Daniel Kim (D)

               16. Andrew Sturmfels (D)

               17. Michael Wong (D)

               18. Henry Huang (L or D) 3

               19. Any witness listed on Defendants’ Witness List/Rule 26(a)(3) Disclosures and/or

                    offered at trial.

           If the need arises, Plaintiff may call the following witnesses at trial:

               1. Joanna Williamson (L) (by cross-examination during Plaintiff’s case as part of Blue

                    Flame Medical LLC’s case in chief)

               2. Tim Coffey (L or D)

               3. Stephanie Daily Smith (D)

               4. Suuchi Ramesh (L)

               5. William Lee (L)

               6. Any witness listed on Defendants’ Witness List/Rule 26(a)(3) Disclosures and/or

                    offered at trial.




  3
    Mr. Huang, whom both Plaintiff and Defendants have sought to depose, has been unable to appear for deposition
  because he has been located in China for the pendency of this action, where local laws prevent him from testifying,
  and has been unable to travel outside of China due to travel restrictions imposed by the Chinese Government in
  response to the COVID-19 pandemic. Plaintiff intends to seek leave from the Court to conduct a deposition of Mr.
  Huang once such restrictions are lifted, and reserves the right to present his testimony at trial, either live or by
  deposition, if possible.

                                                            3
Case 1:20-cv-00658-LMB-IDD   Document 92   Filed 04/15/21    Page 4 of 5 PageID# 608




  Dated: April 15, 2021                Respectfully submitted,

                                       /s/ Peter H. White
                                       Peter H. White (VA Bar No. 32310)
                                       Jason T. Mitchell (pro hac vice)
                                       Gregory Ketcham-Colwill (pro hac vice)
                                       SCHULTE ROTH & ZABEL LLP
                                       901 Fifteenth Street, NW, Suite 800
                                       Washington, DC 20005
                                       Tel.: (202) 729-7476
                                       Fax: (202) 730-4520
                                       pete.white@srz.com
                                       jason.mitchell@srz.com
                                       gregory.ketcham-colwill@srz.com

                                       William H. Gussman, Jr. (pro hac vice)
                                       SCHULTE ROTH & ZABEL LLP
                                       919 Third Avenue
                                       New York, New York 10022
                                       Tel.: (212) 756-2044
                                       Fax: (212) 593-5955
                                       bill.gussman@srz.com

                                       Counsel for Plaintiff Blue Flame Medical LLC




                                       4
Case 1:20-cv-00658-LMB-IDD            Document 92           Filed 04/15/21    Page 5 of 5 PageID# 609




                                    CERTIFICATE OF SERVICE

                  I hereby certify that on this 15th day of April, 2021, I caused the foregoing document

  to be filed and served electronically using the Court’s CM/ECF system, which automatically sent

  a notice of electronic filing to all counsel of record.


  Dated: April 15, 2021                                      /s/ Peter H. White
                                                            Peter H. White, Esq. (VSB# 32310)
                                                            SCHULTE ROTH & ZABEL LLP
                                                            901 Fifteenth Street, NW, Suite 800
                                                            Washington, DC 20005
                                                            Tel: 202-729-7476
                                                            Fax: 202-730-4520
                                                            peter.white@srz.com

                                                            Counsel for Blue Flame Medical LLC


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