Order (Dkt. 33), Third-Party Defendant JPMorgan Chase Bank, N.A. (“JPMC”) respectfully — Blue Flame Medical LLC v. Chain Bridge Bank, N.A., et al.

Date: 2020-09-09

Source document: Order (Dkt. 33), Third-Party Defendant JPMorgan Chase Bank, N.A. (“JPMC”) respectfully — Blue Flame Medical LLC v. Chain Bridge Bank, N.A., et al.; document type: Evidentiary objections (exhibit list).

Full text

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
(Alexandria Division)
BLUE FLAME MEDICAL LLC,

Plaintiff,
v.
CHAIN BRIDGE BANK, N.A.,
JOHN J. BROUGH, and
DAVID M. EVINGER,

Defendants.

Civil Action No. 1:20-cv-00658

CHAIN BRIDGE BANK, N.A.,

Third-Party Plaintiff,
v.
JPMORGAN CHASE BANK, N.A.,

Third-Party Defendant.

JPMORGAN CHASE BANK, N.A.’S OBJECTIONS TO THE EXHIBIT LIST OF
CHAIN BRIDGE BANK, N.A., JOHN J. BROUGH, AND DAVID M. EVINGER

Under Federal Rule of Civil Procedure 26(a)(3) and this Court’s September 9, 2020
Order (Dkt. 33), Third-Party Defendant JPMorgan Chase Bank, N.A. (“JPMC”) respectfully
submits the following objections, set forth in Attachment A, to the Exhibit List of
Defendant/Third-Party Plaintiff Chain Bridge Bank, N.A. and Defendants John J. Brough and
David M. Evinger (Dkt. 93).
Chain Bridge did not distinguish between exhibits for use in its defense against Plaintiff
Blue Flame Medical, and those for use in its third-party case against JPMC. JPMC reserves the
right to object to the mode in which any exhibit identified by Chain Bridge is offered at trial, or
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 1 of 57 PageID#
696

to the purpose for which Chain Bridge offers any exhibit at trial. To the extent the context in
which an exhibit will be offered is not apparent until the time of trial, JPMC reserves the right to
make additional objections at the time the exhibit is offered.
Moreover, JPMC reserves the right to amend or modify any of the below-listed
objections resulting from any stipulation entered into by the parties or any corrections, revisions,
or other modifications to the underlying exhibits. JPMC reserves the right to supplement these
objections, including through motions in limine and in light of any rulings thereupon.
Notwithstanding the referenced objections in Attachment A, JPMC expressly reserves the right
to object to any exhibit on grounds of relevance under Federal Rules of Evidence 402 or 403 at
the appropriate time. See Fed. R. Civ. P. 26(a)(3).
In its Exhibit List (Dkt. 93), Chain Bridge reserves the right “to introduce any exhibit
designated by Blue Flame Medical LLC … to which Defendants do not lodge an objection.”
JPMC reserves the right to object to any such exhibits upon all available grounds for exclusion,
until such time as such exhibits have been specifically identified by Chain Bridge.

Dated: April 26, 2021
Respectfully submitted,
WILMER CUTLER PICKERING HALE
AND DORR LLP
/s/ Meredith K. Loretta

Meredith K. Loretta (92369)
Whitney Russell (pro hac vice)
Albinas J. Prizgintas (pro hac vice)
1875 Pennsylvania Avenue N.W.
Washington, DC 20006
Tel.: (202) 663-6981
meredith.loretta@wilmerhale.com

Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 2 of 57 PageID#
697

Alan E. Schoenfeld (pro hac vice)
Marissa W. Medine (pro hac vice)
7 World Trade Center
250 Greenwich Street
New York, NY 10007
Tel.: (212) 230-8800
alan.schoenfeld@wilmerhale.com

Felicia Ellsworth (pro hac vice)
60 State Street
Boston, MA 02109
Tel.: (617) 526-6000
felicia.ellsworth@wilmerhale.com

Margarita M. Botero (pro hac vice)
1225 17th Street, Suite 2600
Denver, CO 80202
Tel.: (720) 274-3135
margarita.botero@wilmerhale.com

Attorneys for Third-Party Defendant
JPMorgan Chase Bank, N.A.
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 3 of 57 PageID#
698

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX001
BFM000163503-
514
06/26/2020
Email from Marc Serio to Michael Bueche
re: Fwd: As Filed with the Committee, with
attachment
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX002
N/A
10/13/2020
Plaintiff’s Responses to Defendants’ First
Set of Interrogatories to Blue Flame
Medical LLC

DTX003
BFM000008866-
68
03/20/2020
Email from Chad Jones to Michael Jensen
with cc: Mike Gula, Bryan Krastins, Kate
Arnold, John Thomas re 3m Mask POs?
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX004
BFM000008593-
94
03/19/2020
Email from John Thomas to Jason Lee,
Chad Jones, Mike Gula, Bryan Krasins,
Kate Arnold, Michael Jensen re
100,000,000 masks sitting at port of long
beach - intro
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX005
BFM000200058-
115
03/20/2020 -
04/29/2020
Texts between Matthew Littman and John
Thomas
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX006
BFM000200119-
133
03/20/2020 -
03/27/2020
Texts between Betty Yee (California) and
John Thomas
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX007
BFM000009263-
65
03/20/2020
Email from Mike Gula to Chad Jones with
cc: Michael Jensen, Kate Arnold, John
Thomas re Seller PO - Parkland (DRAFT)
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 4 of 57 PageID#
699

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX008
BFM000115637-
41

03/20/2020
Email from Bill Simonson to John Thomas
re FW: Email Connect - DGS and John
Thomas
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX009
BFM000009832-
33
03/20/2020
Email from John Thomas to Bill Simonson
with bcc: Mike Gula re Medical Supplies
Listing with attachment
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX010
BFM000200135-
44
03/22/2020 -
04/09/2020
Texts between Michael Wong (California)
and John Thomas
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX011
CBB00002342-43
(CAL-OES-
00000010-11)
03/23/2020
Email from Abby Browning to Kim Danile,
Mitchell Medigovich re specs for COVID-
19 supply request with attachment
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX012
BFM000066185-
86
03/23/2020
Email from John Thomas to Michael Wong
with bcc: Jennilee@blueflame.agency re
Medical Supplies Sheet with attachment
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX013
BFM000066417-
27
03/25/2020
Email from John Thomas to Jennilee
Brown, Ethan Bearman re Fwd: Medical
Supplies Sheet
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 5 of 57 PageID#
700

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX014
BFM000074877
03/23/2020
Texts between Betty Yee (California) and
John Thomas
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX015
BFM000012554-
60
03/24/2020
Email from John Thomas to Jennilee
Brown, Ethan Bearman, Mike Gula re
Fwd: Medical Supplies Sheet with
attachment
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX016
BFM000116156-
62
03/24/2020
Email from Michael Wong to John Thomas
re Medical Supplies Sheet
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX017
BFM000012804-
05
03/25/2020
Email from Mike Gula to John Thomas,
Jennilee Brown, Ethan Bearman, Paris
Pope re Invoice inventory with attachment
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX018
BFM000110967-
79
03/24/2020
Email from John Thomas to Michael Wong
re Medical Supplies Sheet
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX019
BFM000066391-
92
03/25/2020
Email from Ethan Bearman to Mike Gula
with cc: Jennilee Brown, John Thomas re
Gula make sure the bank knows the wire is
coming
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 6 of 57 PageID#
701

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX020
BFM000111121-
22
03/25/2020
Email from John Thomas to Michael Wong
re Invoice with attachment
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX021
BFM000074887
03/25/2020
Texts between Betty Yee (California) and
John Thomas
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX022
BFM000013558-
59
03/25/2020
Email from Ethan Bearman to John
Thomas, Mike Gula, Jennilee Brown re
Latest spreadsheet with attachment
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX023
BFM000013560-
61
03/25/2020
Email from Ethan Bearman to Mike Gula,
John Thomas, Jennilee Brown re To get to
100MM with attachment
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX024
BFM000116497-
98
03/25/2020
Email from Ethan Bearman to John
Thomas re Another version of the
spreadsheet for Dan Kim with attachment
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX025
BFM000129957-
60
04/21/2020
Email from John Thomas to John Thomas
re [no re line] with attachment
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX026
CBB00002221-89
(CAL-DGS-
00000195- 263)
03/25/2020
Email from Ethan Bearman to John
Thomas with cc: Michael Wong re Intro -
Blueflame Corp Counsel with attachments
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 7 of 57 PageID#
702

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX027
BFM000072285-
86
04/08/2020
Email from John Thomas to Michael Wong
with cc: Ethan Bearman re Blue Flame
Medical N95’s
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX028
BFM000109726-
30
04/10/2020
Email from John Thomas to Michael Wong
with bcc: Ethan Bearman re 100M Mask
Order
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX029
BFM000076870-
74
04/29/2020
Email from John Thomas to Henry Huang
with cc: Ethan Bearman,
Wujin@winteam500.com re PO1-6 with
attachments
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX030
BFM000120324-
27
04/07/2020
Email from Ethan Bearman to Marc Serrio,
John Thomas re URGENT PO 1-4 with
attachments
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX031
BFM000125347-
48
03/26/2020
Email from Suuchi Ramesh to Mike Gula,
John Thomas, Ethan Bearman with cc:
Victor Cortes, Mark Herman re Please
advise ASAP N95s CE (+ FDA) certified
stock
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX032
BFM000192584
09/15/2020
Email from Marc Serrio to John Thomas,
Mike Gula with cc: Ethan Bearman re Cash
Balance Down to Minimum Levels
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 8 of 57 PageID#
703

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX033
N/A
06/12/2020
Blue Flame Medical LLC v. Chain Bridge
Bank, John Brough, David Evinger
Complaint (E.D. Va. 20cv658)
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX034
CBB00000523-25
03/23/2020
Delaware Certificate of Formation of Blue
Flame Medical LLC
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX035
BFM000009163-
65
03/20/2020
Email from Kate Arnold to Mike Gula,
Chad Jones with cc: Stacie Monroe, Bryan
Krastins, Michael Jensen,
vitoc44@gmail.com re West Virginia and
Louisiana
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX036
BFM000011436-
45
03/23/2020
Email from Mike Gula to Genevieve Hills
re FW: Velox Medical Product Inventory
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX037
BFM000012055-
59
03/24/2020
Email from Mike Gula to Brian Chatwin
with cc: Tom Datwyler re FW: south koren
plant [sic]
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX038
BFM000012733-
39
03/24/2020
Email from Mike Gula to Michael Jensen
with cc: Chad Jones, Kate Arnold, Bryan
Krastins re Updated invitation: COVID-19
Supplies @ Mon Mar 23, 2020 5:30pm
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX039
VLX-007876-907
03/05/2020
iMessages for (202) 255-9745
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 9 of 57 PageID#
704

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX040
BFM000012837-
39
03/25/2020
Email from Mike Gula to Paul Sposito re
Fwd: COVID help - supplies
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX041
BFM000013610-
11
03/26/2020
Email from Henry Huang to Mike Gula re
Attachment order 002 revise with
attachment
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX042
BFM000095501
03/25/2020
State of California General Services
Procurement Division Purchasing
Authority Purchase Order for Blue Flame
Medical LLC
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX043
CBB00001781-84
03/25/2020
Email from Maria Cole to Mike Gula re
wire with attachment
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX044
CBB00001518-19
03/25/2020
Email from DocuSign System to Maria
Cole re Please DocuSign: Blue Flame
Medical LLC
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX045
CBB00000555-56
03/25/2020
Account Agreement for Blue Flame
Medical LLC
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 10 of 57 PageID#
705

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX046
CBB00002563-71
03/25/2020
Email from Mariano Castagnello to Mike
Gula re Fwd: need BF Medical
EIN/registration with attachments
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX047
CBB00001202-03
03/27/2020
Email from Tsega Yohannes to Mariano
Castagnello re Expected activity
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX048
BFM000110311
03/25/2020
Email from Mike Gula to Doug Graham re
[no re line]
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX049
BFM000110662-
65
03/22/2020
Email from Mike Gula to Todd Boulanger
re Fwd: email thoughts with attachments
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX050
CBB00002794
03/25/2020
Transcript of call between Mike Gula and
Heather Schoeppe
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901. JPMC
objects to the admissibility of this exhibit under
Fed. R. Evid. 1002
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 11 of 57 PageID#
706

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX051
CBB00002794
03/26/2020
Call between Mike Gula and Heather
Schoeppe
JPMC objects to this dating of this call
recording. Chain Bridge identifies it as
occurring on March 26, 2020, but the call
occurred on March 25, 2020.
DTX052
CBB00001460-62
03/25/2020
Email from Mike Gula to Maria Cole re
wire

DTX053
CBB00001433-36
03/25/2020
Email from Mike Gula to Maria Cole re
wire
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX054
BFM000074101-
06
03/26/2020
Email from Mike Gula to John Thomas re
Contact Info

DTX055
BFM000202988-
3009
03/26/2020
Signal Texts between Ethan Bearman,
Mike Gula, and John Thomas
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX056
CBB00001938-39
03/26/2020
Email from Chain Bridge Bank Wire
Department to Mike Gula re INCOMING
WIRE CONFIRMATION (send secure)
with attachment

DTX057
CBB00000639
03/26/2020
Email from Mike Gula to David Evinger re
Coming in. Are you there?
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 12 of 57 PageID#
707

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX058
BFM000067627-
28
03/27/2020
Email from Lindsay Angerholzer to
lindsay@blueflame.com re COVID supply
help
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX059
BFM000045714-
21
04/14/2020
Email from Mike Gula to Zach Hargett
with cc: Morgan Nichols, Brielle
Appelbaum re South Carolina COVID-19
Emergency Supply Collaborative with
attachments
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX060
CBB00002313-32
(CAL-DGS-
00000292-311)
03/21/2020 -
03/27/2020
Texts between Michael Wong (California)
and John Thomas
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX061
BFM000116128-
35
03/24/2020
Email from John Thomas to Michael Wong
re Medical Supplies Sheet with attachment
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX062
BFM000116274-
76
03/25/2020
Email from Ethan Bearman to Michael
Wong, John Thomas re Bank Wire
instructions for Blue Flame Medical LLC
with attachment
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 13 of 57 PageID#
708

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX063
BFM000111148-
50
03/25/2020
Email from John Thomas to Michael Wong
re Invoice
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX064
BFM000116341
03/25/2020
Email from John Thomas to Michael Wong
with bcc: Jennilee Brown, Mike Gula re
Reminder - Documents
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX065
CBB00002291-
312 (CAL-DGS-
00000270- 92)
04/03/2020
Email from Mathew Littman to Michael
Wong re Calif Details with attachments
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX066
BFM000113888-
94
04/15/2020
Email from John Thomas to Michael Wong
re 100M Mask Order
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX067
CBB00002281-86
(CAL-DGS-
00000255- 60)
03/25/2020
Texts between Michael Wong (California),
Dan Kim (California), and John Thomas
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX068
BFM000206166-
87
07/05/2020
Executive Employment Agreement
between Blue Flame Medical LLC and
Ethan Bearman
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX069
BFM000000675-
81
03/13/2020
Referral Fee Agreement between Velox
Medical and Blue Flame Strategies LLC
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 14 of 57 PageID#
709

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX070
BFM000198682-
700
03/20/2020 -
03/25/2020
Group texts between Ethan Bearman and
John Thomas
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX071
BFM000115813-
17
03/22/2020
Email from Ethan Bearman to Mike Gula
with cc: John Thomas re Regarding your
line list for N95 Protective Masks and
Surgical Masks
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX072
BFM000202805-
69
03/24/2020 -
03/27/2020
Signal texts between Ethan Bearman, Mike
Gula, and John Thomas
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX073
BFM000116277
03/25/2020
Email from Ethan Bearman to John
Thomas re California Invoice
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX074
BFM000066135-
36
03/23/2020
Email from Ethan Bearman to John
Thomas with cc: Jennilee Brown re
Possible spreadsheet to send Suuchi after
NDA is signed
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX075
BFM000116521-
22
03/26/2020
Email from Suuchi Ramesh to Ethan
Bearman, Mark Herman with cc: John
Thomas, Victor Cortes, Ingrid Lacourt re
Request on N95 Masks
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 15 of 57 PageID#
710

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX076
CBB00001385
03/26/2020
Email from Ethan Bearman to Maria Cole
with cc: John Thomas, Mike Gula re Blue
Flame Medical LLC - Wire Transfer
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX077
BFM000000668-
74
03/13/2020
Referral Fee Agreement between
Healthcom Pacific Inc and Blue Flame
Strategies LLC
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX078
BFM000116254-
56; 116342-46
03/25/2020
Email from Ethan Bearman to Henry
Huang with cc: John Thomas, Mike Gula
re Healthcom Pacific Inc. Referral Fee
Agreement with attachment
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX079
CBB00002779
3/26/2020
Fedwire Funds Processor Completed

DTX080
CBB00002780
03/26/2020
Fedwire Funds Processor Completed

DTX081
CBB00002786
03/26/2020
Call between Maria Cole and John Thomas
DTX082
CBB00002787
03/26/2020
Call between Maria Cole and John Thomas
DTX083
CBB00002788
03/26/2020
Call between Maria Cole and John Thomas
DTX084
CBB00002501-
505
03/26/2020
California warrants for N95 mask purchase
DTX085
BFM000163112-
113
03/26/2020
Memo from Andrew Sturmfels to Natalie
Gonzales authorizing $465,888,600.00

Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 16 of 57 PageID#
711

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
wire for purchase of N95 masks from Blue
Flame Medical
DTX086
JPMC-00000027-
28
03/26/2020
Email from Ana Prieto to Natalie Gonzales
indicating that wire had been released
JPMC objects to this exhibit because it is
incomplete under Fed. R. Evid. 106.
DTX087
N/A
05/11/2020
Testimony of Fiona Ma at 05/11/2020
hearing before the California State
Assembly
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX088
BFM_CA_STO0
001 (STO0626-
648)
03/26/2020
Email from Natalie Gonzales to Amin
Pirasteh noting that it’s “really weird”
neither of them can find reference to Blue
Flame Medical on the internet

DTX089
JPMC-00000135
03/26/2020
Email from Natalie Gonzales to Ana Prieto
asking whether it’s possible to reach out to
CBB for an update re the return wire
JPMC objects to this exhibit because it is
incomplete under Fed. R. Evid. 106.
DTX090
SCO0131-56
03/26/2020
Email from Andrew Sturmfels to Karen
Ross Greene, Rick Chivaro, Natalie
Gonzales, Fee Chang, Monica Cuellar,
Andre Rivera, Dan Kim, Allan Watson
with cc: Jim Spano, Jutta, Angela Shell,
Jason Hollingsworth, Karen Finn, Bill
Simonson, Lilian Lee, Coleen Morrow,
Bertha Mejia, Jennifer Chavez, Shirley
Dong, Roland Mar, Elizabeth Gonzalez,

Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 17 of 57 PageID#
712

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
Michael Wong re email chain restored
w/all who need to know..
DTX091
CBB00002699-70
03/25/2020
Email from Mike Gula to David Evinger,
John Brough re Screenshot 2020-03-25 at
6.26.08 PM with attachment

DTX092
CBB00002686
03/26/2020
Email from Mike Gula to David Evinger re
Blue Flame Medical / Fighting Coronavirus
JPMC objects to this exhibit because it is not
relevant to any issue to be decided in this case
under Fed. R. Evid. 401-402. JPMC objects to
this exhibit on the ground that the foundation
necessary for its admission has not been laid
under Fed. R. Evid. 602. JPMC objects to this
exhibit because it constitutes or contains
hearsay under Fed. R. Evid. 801-802. JPMC
objects to this exhibit because it contains a
document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX093
CBB00002543
03/26/2020
Call between David Evinger and Fee
Chang

DTX094
CBB00002545
03/26/2020
Call between John Brough, David Evinger,
and Tim Coffey

DTX095
CBB00004445
03/25/2020
Handwritten notes of John Brough

DTX096
BFM000013445-
48
03/25/2020
Email from Mike Gula to John Brough,
David Evinger re Contact Info with
attachment

DTX097
CBB00002541
03/26/2020
Call between John Brough, David Evinger,
and Rakesh Korpal

Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 18 of 57 PageID#
713

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX098
CBB00002544
03/26/2020
Call between John Brough, David Evinger,
and Rakesh Korpal

DTX099
JPMC-00000084-
88
03/26/2020
Email from Jenifer Robinson to Rakesh
Korpal re FW [RFI-89021]: EXPEDITE
REVIEW/APPROVAL Held Payment
>=$50MM USD CLIENT NAME:
CALIFORNIA STATE TREASURER SP
CASE ID: with attachments

DTX100
JPMC-00000089-
94
03/26/2020
Email from Jenifer Robinson to Rakesh
Korpal re FW [RFI-89021]: EXPEDITE
REVIEW/APPROVAL Held Payment
>=$50MM USD CLIENT NAME:
CALIFORNIA STATE TREASURER SP
CASE ID: with attachments

DTX101
JPMC-00000392-
93
03/27/2020
Email from Alexander Leonard to Art
Neville, Alex Grant with cc: Daniel
Wilkening, Brian Page, Rakesh Korpal,
June Cantrell, Joshua Pope, Mike Kelly
Michael Nevins re Confidential State of
California
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX102
JPMC-00000003-
5
03/26/2020
Email from Fraud Alert to Jenifer
Robinson, Rakesh Korpal, Timothy Coffey
with cc: Michelle Long re [RFI-89021]:
EXPEDITE REVIEW/APPROVAL Held
Payment >=$50MM USD CLIENT
NAME: CALIFORNIA STATE

Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 19 of 57 PageID#
714

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
TREASURER SP CASE ID: with
attachments
DTX103
CBB00002784
03/26/2020
Recording of call to Chain Bridge Bank
(Mariano Castagnello) from Tim Coffey
requesting to speak to fraud or wire transfer
department

DTX104
JPMC-00000101-
05
03/26/2020
Email from Tim Coffey to Debra Naughton
with cc: Rakesh Korpal) re PRPC case
JPM200326-004818 with attachments

DTX105
JPMC-00000386
05/21/2020
Email from Fiona Ma to Jamie Dimon with
cc; Tim Schaefer, Genevieve Jopanda re
Thank You
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX106
DGS2491-95
03/25/2020
State of California Purchasing Authority
Purchase Order with attachments

DTX107
JPMC-00000009
03/26/2020
Email from Timothy Coffey to Fraud Alert,
Jenifer Robinson, Rakesh Korpal, Michelle
Long re [RFI-89021]: EXPEDITE
REVIEW/APPROVAL Held Payment
>=$50MM USD CLIENT NAME:
CALIFORNIA STATE TREASURER SP
CASE ID:

Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 20 of 57 PageID#
715

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX108
JPMC-00000170-
76
03/26/2020
Email from Timothy Coffey to Debra
Naughton with cc: Rakesh Korpal re PRPC
case JPM200326-004818 with attachments

DTX109
N/A
01/22/2021
Subpoena to Testify at a Deposition in a
Civil Action to the California State
Controller’s Office
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX110
SCO1521-80
03/20/2020 -
03/27/2020
Texts between Betty Yee (California) and
John Thomas
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX111
DGS5408-09
03/26/2020
Email from Mai Chang to Naoko Reese
with cc: Thanh Thao Au, Robert Bachiller,
Bla Lee, Anthony Cantrell, Tawnya Castro
Harris, Samantha Curry, Debra Rossaro,
Kristoffer Hernandex, Molly McClure,
Patti Moore, Thy Nguyen, Greg Okumura,
Tracy Oliver, Tadashi Taira, Nicholas
Walls re DENIED SID 0000160359 BLUE
FLAME MEDICAL LLC
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX112
BFM000121643-
647
04/10/2020
PO-20200410-002 dated 4/10/20 from Blue
Flame Medical, LLC to Quonset
Development Corporation
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX113
BFM000072442-
443
04/09/2020
Blue Flame Medical Bulk Price Sheet on 4-
09-20
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 21 of 57 PageID#
716

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX114
BFM000128078-
079
04/16/2020 -
04/17/2020
Emails between Matthew Hayes
(Tennessee) and John Thomas re:
[EXTERNAL] Updated Costs And
Potential Solutions
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX115
BFM000063226
04/29/2020
Emails between Julia Pickle (Alabama) and
Mike Gula
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX116
BFM000134376
05/01/2020
Sales Quote to the State of Colorado
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX117
BFM000080369
05/04/2020
Email from Colorado to John Thomas and
Tracy Austin re: Firm Denial - Quote
packet received
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX118
BFM000080065
05/04/2020
Email from Ethan Bearman to John
Thomas, Michael Collins, Marc Serrio re:
Colorado
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX119
BFM000126777
04/09/2020
Purchase Order issued April 9, 2020 to
Office of Governor Jay Inslee
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 22 of 57 PageID#
717

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX120
BFM000126774-
779
04/13/2020
Email from Ethan Bearman to Elena
McGraw re: isolation gown pic/certificate
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX121
BFM000046448-
459
04/15/2020
Email from Mike Gula to Bradley Knox
(Tennessee) re: WA State COVID-19
Supplies - Isolation Gowns Questions -
Time Sensitive
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX122
BFM000050658-
659
04/16/2020-
04/18/2020
Emails between Elena McGrew and Mike
Gula re: We want to work with you on
price point
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX123
DGS6516-6518
10/26/2020
Dan Kim Typed Noted
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX124
DGS2493
03/24/2020
Payee Data Record for Blue Flame Medical JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX125
DGS2948-2959
03/25/2020
Email from Andrew Sturmfels to Karen
Greene Ross, Dan Kim, Jutta Wiechec re:

Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 23 of 57 PageID#
718

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
email chain restored w/all who need to
know....
DTX126
DGS0775-0787
03/25/2020
Email from Dan Kim to Allan Watson Re:
email chain restored w/all who need to
know...

DTX127
DGS5363-5365
03/25/2020 -
03/27/2020
Texts between Dan Kim (California) and
John Thomas
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX128
BFM000200134
03/25/2020 -
03/27/2020
Texts between Dan Kim (California) and
John Thomas
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX129
DGS4966-4980
03/24/2020 -
03/25/2020
Email from Karen Greene Ross to Dan
Kim Re: email chain restored w/all who
need to know.

DTX130
DGS6030-6049
03/25/2020 -
03/26/2020
Email from Dan Kim to Monica Cuella,
Andre Rivera, Andrew Sturmfels, Allan
Watson Re: email chain restored w/all who
need to know..

DTX131
DGS8016-8021
N/A
Chronology of email correspondence and
notes taken by Dan Kim

DTX132
BFM000007156
03/17/2020
Email from Mike Gula to Mike Gula re:
Current contracts 3.17
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 24 of 57 PageID#
719

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX133
BFM000012806-
807
03/25/2020
Email from Mike Gula to John Thomas,
Jennilee Brown, Ethan Bearman, Paris
Pope, RE: Invoice Inventory
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX134
BFM000012824-
825
03/25/2020
Email from Mike Gula to Ethan Bearman
re: Gula make sure the bank knows the
wire is coming
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX135
BFM000198724-
736
03/22/2020-
05/06/2020
Texts between Matthew Littman, Ethan
Bearman, and John Thomas
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX136
BFM_DGS0294-
0322
07/29/2020
Ltr. from Jennifer Dauer to Angela Shell
(CA Procurement) Re: Purchase Order No.
M12948-T6619 to Blue Flame Medical
LLC

DTX137
BFM000162406-
07
06/17/2020
Emails from Matthew Swift to Michael
Gula re: Blue Flame Medical Files Suit
Against Chain Bridge Bank.pdf
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX138
BFM000206162
N/A
Video with file name signal-2020-03-25-
094152.mp4
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX139
N/A
03/09/2021
Chain Bridge Bancorp, Incorporated 2019
Annual Report
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 25 of 57 PageID#
720

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX140
N/A
02/02/2021
Excerpt from John Brough deposition
transcript
JPMC objects to this exhibit because it is
incomplete under Fed. R. Evid. 106. JPMC
objects to this exhibit on the ground that the
foundation necessary for its admission has not
been laid under Fed. R. Evid. 602.
DTX141
N/A
02/27/2015
Excerpt from Bank Secrecy Act/Anti-
Money Laundering Examination Manual
Appendix F
JPMC objects to this exhibit because it is
incomplete under Fed. R. Evid. 106. JPMC
objects to this exhibit on the ground that the
foundation necessary for its admission has not
been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it contains a
document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX142
N/A
03/26/2020
FBI Press Release: FBI Warns Health Care
Professionals of Increased Potential for
Fraudulent Sales of COVID-19 Related
Medical Equipment
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 26 of 57 PageID#
721

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX143
N/A
11/19/2011
Fedwire Funds Service Format Reference
Guide
JPMC objects to this exhibit because it is
incomplete under Fed. R. Evid. 106. JPMC
objects to this exhibit on the ground that the
foundation necessary for its admission has not
been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it contains a
document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX144
CBB00002781
03/26/2020
Fedwire Funds Processor Message

DTX145
N/A
2014
The ABCs of the UCC by Thomas C.
Baxter Jr. et al.
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX146
JPMC-00000533-
534
12/28/2020
Ltr. from Alan E. Schoenfeld
(WilmerHale) to Spencer Walker
(California) re: Reservation of Rights
Regarding March 26, 2020 Wire Transfer
to Blue Flame Medical LLC
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX147
JPMC-00000535-
599
03/20/2021
Email from Alan E. Schoenfeld to Spencer
Walker re: JPMorgan Chase Bank, N.A. /
Notice of Claim, with attachments
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 27 of 57 PageID#
722

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

DTX151
SDS000078-143
03/20/2020-
12/14/2020
Text messages between Stephanie Daily
Smith and Matthew Littman
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX152
SDS000144-153
03/20/2020
Texts between Stephanie Daily Smith and
Betty Yee
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX153
BFM000110641
03/21/2020
Email from John Thomas to Stephanie
Smith re: medical supplies sales sheet
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 28 of 57 PageID#
723

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX154
BFM000111228-
231
03/25/2020
Email from John Thomas to Stephanie
Smith re: Fwd: Bank Wire Instructions for
Blue Flame Medical LLC
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX155
SDS00072-074
04/04/2020
Emails between Lee Rosenberg and
Stephanie Smith
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX156
N/A
03/15/2021
Ltr. from Amanda Touchton (attorney for
Matthew Littman) to Matt Madden
(attorney for Defendants) re: Subpoena to
Mathew Littman in Blue Flame Medical,
LLC v. Chain Bridge Bank, et al.
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX157
SDS0001-077
03/20/2020-
04/27/2020
Stephanie Smith emails
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX158
BFM000206553-
559
06/05/2020
Ltr. from Douglas F. Gansler (Cadwalader)
to Lauri A. McGuire (Maryland
Department of General Services) Re: Blue
Flame Medical, LLC - Purchase Order
#H00P0601445
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX159
BFM_CA_DGS6
555- 6565
04/01/2020-
05/23/2020
California Department of General Services
Emails between Michael Wong, Angela
Shell, et al.
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 29 of 57 PageID#
724

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
a document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX160
N/A
12/2019
Federal Reserve Banks Operating Circular
No. 6
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX161
BFM000204231
11/2/2020
60 Minutes Video
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX162
N/A
12/06/2020
CBS News Article: Inside the chaotic PPE
market where shortages of critical supplies
persist
JPMC objects to this exhibit because its
probative value is outweighed by unfair
prejudice and/or confusion of the issues under
Fed. R. Evid. 403. JPMC objects to this exhibit
on the ground that the foundation necessary for
its admission has not been laid under Fed. R.
Evid. 602. JPMC objects to this exhibit
because it constitutes or contains hearsay under
Fed. R. Evid. 801-802. JPMC objects to this
exhibit because it contains a document that has
not been properly authenticated under Fed. R.
Evid. 901. JPMC objects to this exhibit on the
grounds that it is duplicative and/or cumulative
of other exhibits.
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 30 of 57 PageID#
725

ATTACHMENT A
Chain Bridge Trial Exhibits – Expects to Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT
DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX163
N/A
05/11/2020
Audio/Video of California State Assembly
Hearing for the Committee on
Accountability and Administrative Review
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX164
CBB00002608
N/A
SilverLake Xperience Screenshot of Blue
Flame Medical LLC Transaction History
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 31 of 57 PageID#
726

ATTACHMENT A
Chain Bridge Trial Exhibits—May Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX165
BFM000002416-
430
N/A
Blue Flame Medical Presentation
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX166
CBB00002569-
571
03/23/2020
State of Delaware Limited Liability
Company Certificate of Formation
for Blue Flame Medical LLC
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX167
CBB00001198-
199
02/10/2020
State of Delaware Limited Liability
Company Certificate of Formation
for Blue Flame Strategies LLC
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX168
BFM000115483-
490
03/16/2020
Email from Maria Cole to Michael
Gula, cc’ing Mariano Castagnello,
Mike Richardson, and Brad Ward,
“Re: New Account”, with
attachments
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX169
CBB00001952-
62
03/13/2020
Email from Michael Gula to Melissa
Strano, cc’ing John Thomas, “Fwd:
new business”, with attachments
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX170
CBB00004391-
392
03/16/2020
Account Agreement between Chain
Bridge Bank, N.A. and Blue Flame
Strategies LLC
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX171
CBB00001574-
79
03/17/2020
Email from Michael Gula to Maria
Cole, cc’ing John Thomas, “NEW
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 32 of 57 PageID#
727

ATTACHMENT A
Chain Bridge Trial Exhibits—May Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT DATE
DESCRIPTION
JPMC’s OBJECTIONS
business account needed”, with
attachment
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX172
CBB00004380-
381
03/18/2020
Account Agreement between Chain
Bridge Bank, N.A. and Redline
Strategies LLC
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX173
BFM000137279-
280
05/09/2020
Email from Michael Gula to Brielle
Appelbaum, “Fwd: My memory of
the call with Chain Bridge Bank”
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901. JPMC
objects to the admissibility of this exhibit under
Fed. R. Evid. 1002.
DTX174
CBB00004463-
467
N/A
Brough Typed Notes

DTX175
CBB00002124-
125
03/25/2020
Email from Allan Watson to Jim
Spano et al., “email chain restored
w/all who need to know…..”

DTX176
CBB00000728-
729
03/26/2020
Email from David Evinger to
Jennifer Lincoln, John Brough, and
Farrukh Memon, cc’ing Wires, “RE:
Incoming Large Wire”

DTX177
CBB00004235-
273
03/2020
Bank Secrecy Act, Anti Money
Laundering Control, and Office of

Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 33 of 57 PageID#
728

ATTACHMENT A
Chain Bridge Trial Exhibits—May Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT DATE
DESCRIPTION
JPMC’s OBJECTIONS
Foreign Assets Control Policy, Chain
Bridge Bank, N.A.
DTX178
CBB00004274-
276
09/2016
Suspicious Activities Procedures,
Chain Bridge Bank, N.A.

DTX179
CBB00004302-
306
N/A
Wire Transfer Procedures, Chain
Bridge Bank, N.A.

DTX180
CBB00004307-
09
01/2018
Funds Availability (Regulation CC)
Policy, Chain Bridge Bank, N.A.,

DTX181
CBB00004277-
278
09/12/2019
“BSA Policy Review: Questionable
and Suspicious Activity Reporting
(BSA Policy Pages 32 - 35),” BSA
Training - BSA Policy Review,
Chain Bridge Bank, N.A.

DTX182
CBB00002609-
610
N/A
Funds Availability Disclosure, Chain
Bridge Bank N.A.,

DTX183
BFM000116345-
346
03/25/2020
First Amendment and Addendum to
Referral Fee Agreement between
Healthcom Pacific Inc. and Blue
Flame Strategies LLC
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX184
BFM000021076-
94
04/01/2020
Email from Michael Gula to Julio
Cabral re: Medical Supplies - Blue
Flame Medical, with attachments
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 34 of 57 PageID#
729

ATTACHMENT A
Chain Bridge Trial Exhibits—May Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX185
BFM000170149-
174
03/31/2020
Email from Ethan Bearman to Marc
Serrio (Blue Flame) re: FW: Wire
Info, with Product Reseller
Agreement attachments
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX186
BFM000076873-
874
04/29/2020
Letter from Great Health to Blue
Flame Re: Cancellation of Order
Confirmation No. 1001-1004, 1006;
Blue Flame Medical as Reseller
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX187
CAL-OES-
00000020-026
03/23/2020
Emails from Abby Browning to Mike
Gula et al re: Updated invitation:
COVID-19 Supplies @ Mon Mar 23,
2020 5:30pm - 6:30pm (MDT)
(abby.browning@caloes.ca.gov)
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX188
BFM000066087-
088
03/22/2020
Email from Kate Arnold (Velox
Medical) to Brian Merrick (State of
Massachusetts) re: Update on
Supply-Urgent
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX189
BFM000008038-
039
03/19/2020
Email from Henry Huang to Michael
Jensen et al. re: Velox Daily
Shipping Request—March 18
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX190
BFM000011979-
982
03/24/2020
Texts between Mike Gula and Henry
Huang
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 35 of 57 PageID#
730

ATTACHMENT A
Chain Bridge Trial Exhibits—May Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX191
BFM000012279-
285
03/23/2020
Email from Suuchi Ramesh to Ethan
Bearman et al. RE: RE: Email 2
pricing from Suuchi Inc
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX192
BFM000077942-
956
03/21/2020
Texts between Suuchi Ramesh and
Ethan Bearman
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX193
BFM000116424-
425
03/25/2020
Purchase Order from Blue Flame to
Suuchi
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX194
BFM000013830 03/26/2020
Email from Suuchi Ramesh to Mike
Gula et al. re: PO Status
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX195
BFM000066389-
390
03/25/2020
Email from John Thomas to Mike
Gula et al. re: Invoice Inventory
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX196
BFM000116525-
527
03/26/2020
Email from Suuchi Ramesh to Ethan
Bearman re: Request on N95 Masks
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 36 of 57 PageID#
731

ATTACHMENT A
Chain Bridge Trial Exhibits—May Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX197
BFM000138783-
799
04/15/2020
Federal Grand Jury Subpoena to Blue
Flame Medical, US Attorney’s
Office, Central District of California
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX198
BFM000157939-
943
06/08/2020
Email from Tung Khuu to Michael
Skoglund et al re: Blue Flame
Medical, LLC PPE Subpoenas and
Investigations Additional subpoenas
from Maryland and U.S. DOJ - E.D.
Virginia, with attachment
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX199
CBB00002646-
648
05/18/2020
Ltr. from Frank Pallone, Jr., Diana
DeGette, U.S. House of
Representatives Committee on
Energy and Commerce to Mike Gula
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX200
CBB00004323-
362
03/26/2020
Selected Chain Bridge Bank Call
Logs

DTX201
CBB00002765-
778
N/A
Terms and Conditions of Your
Account
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 37 of 57 PageID#
732

ATTACHMENT A
Chain Bridge Trial Exhibits—May Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX202
CBB00001743-
747
03/17/2020-
03/25/2020
Emails between Maria Cole and
Mike Gula re: wire

DTX203
N/A
04/13/2020
FBI Warns of Advance Fee and BEC
Schemes Related to Procurement of
PPE and Other Supplies During
COVID-19 Pandemic
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX204
N/A
03/16/2020
The Financial Crimes Enforcement
Network (FinCEN) Encourages
Financial Institutions to
Communicate Concerns Related to
the Coronavirus Disease 2019
(COVID-10) and to Remain Alert to
Related Illicit Financial Activity
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX205
BFM000212491-
501
03/21/2020-
03/26/2020
Texts between Matt Littman,
Stephanie Daily Smith, and John
Thomas
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX206
BFM000212479 03/24/2020
Texts between Stephanie Smith, John
Thomas, and Betty Yee
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 38 of 57 PageID#
733

ATTACHMENT A
Chain Bridge Trial Exhibits—May Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX207
BFM000212468-
478
03/20/2020-
03/24/2020
Texts between John Thomas and
Stephanie Roberson (California
Nurses Association)
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX208
BFM000212939-
964
03/26/2020-
04/29/2020
Texts between John Thomas and
Marc Serrio
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX209
BFM000212912-
938
03/13/2020-
04/29/2020
Texts between John Thomas and
Henry Huang
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX210
BFM000212703-
733
03/16/2020-
04/26/2020
Texts between Mike Gula, John
Thomas, and Henry Huang
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX211
BFM000212965-
3013
03/20/2020-
04/29/2020
Texts between Matt Littman and
John Thomas
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX212
BFM000126009-
10
04/06/2020
Email from Marc Serrio to Henry
Huang re: proof of funds for Henry,
with attachment
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 39 of 57 PageID#
734

ATTACHMENT A
Chain Bridge Trial Exhibits—May Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX213
N/A
09/17/2020
Laurel Rosenhall, Exclusive:
California wires mask dealer half a
billion dollars, then claws it back, Cal
Matters
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901. JPMC
objects to this exhibit on the grounds that it is
duplicative and/or cumulative of other exhibits.
DTX214
N/A
05/02/2020
Tom Hamburger and Juliet Eilperin,
Maryland cancels $12.5 million PPE
contract with firm started by GOP
operatives, The WashingtonPost
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901. JPMC
objects to this exhibit on the grounds that it is
duplicative and/or cumulative of other exhibits.
DTX215
N/A
05/06/2020
Tom Hamburger and Juliet Eilperin,
Justice Department investigates Blue
Flame Medical after claims that it
failed to provide masks to Maryland
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901. JPMC
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 40 of 57 PageID#
735

ATTACHMENT A
Chain Bridge Trial Exhibits—May Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT DATE
DESCRIPTION
JPMC’s OBJECTIONS
objects to this exhibit on the grounds that it is
duplicative and/or cumulative of other exhibits.
DTX216
N/A
05/06/2020
Kenneth P. Vogel, Firm Set Up by
G.O.P. Operatives Under Scrutiny
Over Virus Contracts, The New York
Times
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901. JPMC
objects to this exhibit on the grounds that it is
duplicative and/or cumulative of other exhibits.
DTX217
N/A
05/02/2020
The Baltimore Sun, Maryland seeks
investigation of politically connected
company that hasn’t delivered masks,
ventilators
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901. JPMC
objects to this exhibit on the grounds that it is
duplicative and/or cumulative of other exhibits.
DTX218
N/A
05/02/2020
Brody Mullins and Susan Pulliam,
Maryland Cancels Big Coronavirus
Mask Order, The Wall Street Journal
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 41 of 57 PageID#
736

ATTACHMENT A
Chain Bridge Trial Exhibits—May Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT DATE
DESCRIPTION
JPMC’s OBJECTIONS
a document that has not been properly
authenticated under Fed. R. Evid. 901. JPMC
objects to this exhibit on the grounds that it is
duplicative and/or cumulative of other exhibits.
DTX219
CBB00000655-
57
03/26/2020
Email from Heather Schoeppe to
Maria Cole, John Brough, David
Evinger, Mike Richardson re Blue
Flame Medical LLC – Wire Transfer

DTX220
CBB000002529-
36
03/26/2020
Chain Bridge Bank GL History Print
Optical Report OutQ
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX221
CBB00001770-
72
03/25/2020
Email from Maria Cole to Mike
Richardson re wire

DTX222
CBB00002725-
29
03/26/2020
Email from Peter Fitzgerald to John
Brough re $450 Million wire came in

DTX223
JPMC-00000123 03/26/2020
Email from Rakesh Korpal to Patricia
Wiltz re Conversation initiated by
rakesh.korpal@jpmchase.com

Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 42 of 57 PageID#
737

ATTACHMENT A
Chain Bridge Trial Exhibits—May Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX224
JPMC-
00000194-95
03/26/2020
Email from June Cantrell to Lisa
Lucchese re California State
Treasurer’s Office (STO) - Wire

DTX225
JPMC-
00000231-32
03/26/2020
Email from June Cantrell to Daniel
Wilkening re California State
Treasurer’s Office (STO) - Wire

DTX226
JPMC-
00000239-42
03/27/2020
Email from Nikki Ticzon to Rakesh
Korpal, Jenifer Robinson, Timothy
Coffey, Akhil Kedia re [re line
empty] with attachments
JPMC objects to this exhibit because it is not
relevant to any issue to be decided in this case
under Fed. R. Evid. 401-402. JPMC objects to
this exhibit on the ground that the foundation
necessary for its admission has not been laid
under Fed. R. Evid. 602. JPMC objects to this
exhibit because it constitutes or contains
hearsay under Fed. R. Evid. 801-802. JPMC
objects to this exhibit because it contains a
document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX227
JPMC-00000243 03/27/2020
Email from Rakesh Korpal to Rakesh
Korpal, Timothy Coffey re
Conversation with Korpal, Rakesh
(CIB OPS, USA)

DTX228
JPMC-00000244 04/15/2020
Email from Rakesh Korpal to
Timothy Coffey re Conversation
initiated by
rakesh.korpal@jpmchase.com
JPMC objects to this exhibit because it is not
relevant to any issue to be decided in this case
under Fed. R. Evid. 401-402. JPMC objects to
this exhibit on the ground that the foundation
necessary for its admission has not been laid
under Fed. R. Evid. 602. JPMC objects to this
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 43 of 57 PageID#
738

ATTACHMENT A
Chain Bridge Trial Exhibits—May Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT DATE
DESCRIPTION
JPMC’s OBJECTIONS
exhibit because it constitutes or contains
hearsay under Fed. R. Evid. 801-802. JPMC
objects to this exhibit because it contains a
document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX229
JPMC-
00000461-63
N/A
March and April Handwritten notes JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX230
SCO0221-45
03/26/2020
Email from Andrew Sturmfels to
Karen Greene Ross, Rick Chivaro,
Natalie Gonzales, Fee Chang,
Monica Cuellar, Andre Rivera, Kim
Daniel, Allan Watson with cc: Jim
Spano, Jutta Wiechec, Angela Shell,
Jason Hollingsworth, Karen Finn,
Bill Simonson, Lilian lee, Coleen
Morrow, Bertha Mejia, Jennifer
Chavez, Shirley Dong, Roland Mar,
Elizabeth Gonzalez, Michael Wong
re email chain restored w/all who
need to know....

Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 44 of 57 PageID#
739

ATTACHMENT A
Chain Bridge Trial Exhibits—May Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX231
CBB00000853-
56
03/25/2020
Email from Heather Schoeppe to
Mike Richardson re Blue Flame
Medical incoming wire 450 million

DTX232
CBB00002795
03/25/2020
Call between Mike Gula and Heather
Schoeppe

DTX233
CBB00002797
03/25/2020
Call between Heather Schoeppe and
Joanna Williamson

DTX234
CBB00002798
03/25/2020
Call between Heather Schoeppe,
John Brough, and David Evinger

DTX235
CBB00001097-
101
03/25/2020
Email from Maria Cole to Mike
Richardson with cc: Heather
Schoeppe re Blue Flame Medical
incoming wire 450 million

DTX236
CBB00000761-
63
03/25/2020
Email from Heather Schoeppe to
John Brough with cc: Mike
Richardson, Joanna Williamson,
David Evinger re Blue Flame
Medical incoming wire 450 million

DTX237
CBB00002673-
77
03/26/2020
Email from Heather Schoeppe to
John Brough, Tsega Yohannes, Betsy
Sharon, Nancy Kelly with cc: David
Evinger, Tais Ribeiro, Mike
Richardson, Joanna Williamson re
Contact Info

Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 45 of 57 PageID#
740

ATTACHMENT A
Chain Bridge Trial Exhibits—May Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX238
CBB00002649
3/26/2020
Wire Transfers Display

DTX239
CBB00001008-
29
3/26/2020
Email from Mike Richardson to
Maria Cole with cc: Heather
Schoeppe re Blue Flame Medical
incoming wire 450 million with
attachment

DTX240
CBB00000748
03/26/2020
Email from John Brough to Jennifer
Lincoln, David Evinger, Joanna
Williamson, Farrukh Memon,
Heather Schoeppe, Mike Richardson
with cc: Wires re Incoming Large
Wire

DTX241
CBB00000971-
80
3/26/2020
Email from Maria Cole to Mike
Richardson, Claudia Mojica with
cc: Heather Schoeppe, Wires re
Blue Flame Medical incoming
wire 450 million

DTX242
CBB00000919-
29
03/26/2020
Email from Maria Cole to Mike
Richardson, Thais Ribeiro, Jennifer
Lincoln, Claudia Mojica with cc:
Heather Schoeppe, Wires re Blue
Flame Medical incoming wire 450
million

DTX243
CBB00000718-
27
03/26/2020
Email from Heather Schoeppe to
David Evinger, Mike Richardson,
John Brough, Joanna Williamson

Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 46 of 57 PageID#
741

ATTACHMENT A
Chain Bridge Trial Exhibits—May Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT DATE
DESCRIPTION
JPMC’s OBJECTIONS
with cc: Maria Cole re Blue Flame
Medical incoming wire 450 million
DTX244
CBB00000815-
17
03/26/2020
Email from Heather Schoeppe to
Thais Ribeiro re Please close
BlueFlame Accounts

DTX245
CBB00000527
03/27/2020
Email from John Brough to Heather
Schoeppe, Mariano Castagnello,
Angeli Nanali, Mubeen Baig, Najwa
Alwazir, M. Strano, Maria Cole,
Mike Richardson, Brad Ward,
Sametta Bailey, Pat Collins, Barry
Huitema, Marcia Bradford with cc:
David Evinger, Betsy Sharon,Tsega
Yohannes, Thais Ribeiro re No new
accounts for these clients

DTX246
CBB00002650
03/26/2020
Wire Transfers Display

DTX247
CBB00002789
03/26/2020
Call between Claudia Mojica-
Guadron, John Brough, David
Evinger, and Thais Ribeiro

DTX248
CBB00000640-
42
03/26/2020
Email from Claudia Mojica to John
Brough, David Evinger, Thais
Ribeiro re Message from JPMorgan
Chase - Large Incoming Wire with
attachment

Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 47 of 57 PageID#
742

ATTACHMENT A
Chain Bridge Trial Exhibits—May Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX249
CBB00000795-
96
03/26/2020
Email from David Evinger to Thais
Ribeiro, John Brough, Claudia
Mojica with cc: Tim Ahmad re
Message from JPMorgan Chase -
Large Incoming Wire

DTX250
CBB000002653-
54
03/26/2020
Wire Transfers Display

DTX251
CBB00000791-
94
03/26/2020
Email from David Evinger to John
Brough, Claudia Mojica, Tim Ahmad
with cc: Thais Ribeiro re Message
from JPMorgan Chase - Large
Incoming Wire

DTX252
CBB00003573-
74
03/25/2020
Email from Maria Cole to Mike Gula
re wire

DTX253
CBB00004437
03/26/2020
Cell Phone Record for Maria Cole

DTX254
CBB00001725-
26
03/26/2020
Email from Maria Cole to John
Thomas with cc: Mike Gula, Mike
Richardson re Wire Request Form
with attachment
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX255
DGS0201-02
03/26/2020
Email from Fee Chang to Natalie
Gonzales with cc: Andrew Sturmfels

Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 48 of 57 PageID#
743

ATTACHMENT A
Chain Bridge Trial Exhibits—May Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT DATE
DESCRIPTION
JPMC’s OBJECTIONS
re Urgent - request call from
CEO/President of Chain Bridge Bank
DTX256
CBB00000779-
81
03/25/2020
Email from John Brough to David
Evinger re Blue Flame Medical
incoming wire 450 million

DTX257
CBB00004453-
62
N/A
Notes of David Evinger

DTX258
CBB00000807
03/26/2020
Email from David Evinger to
Jennifer Lincoln, John Brough,
Joanna Williamson, Farrukh Memon
with cc Wires re Incoming Large
Wire

DTX259
N/A
01/06/2021
Plaintiff’s Notice of Rule 30(b)(6)
Videotaped Deposition of JPMorgan
Chase Bank, N.A. (Rakesh Korpal)

DTX260
JPMC-00000013 03/26/2020
Email from Ana Prieto to Mackson
Pereira re Conversation initiated by
ana.c.prieto@jpmorgan.com
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 49 of 57 PageID#
744

ATTACHMENT A
Chain Bridge Trial Exhibits—May Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX261
JPMC-
00000027-30
03/26/2020
Email from Ana Prieto to Natalie
Gonzales with cc: Cash Desk, Art
Neville, Tamara Brown, Angelique
Uribe re 03/26/20 Large Outgoing
Wire [202003260005534] with
attachments

DTX262
JPMC-
00000036-40
03/26/2020
Email from Brian Page to Art
Neville, Alexander Leonard with cc:
June Cantrell, Ana Prieto re 03/26/20
STO Large Outgoing Wire with
attachments
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX263
JPMC-00000046 03/26/2020
Email from June Cantrell to Rakesh
Korpal re Conversation initiated by
June.m.cantrell@chase.com

DTX264
JPMC-
00000049-53
03/26/2020
Email from June Cantrell to Rakesh
Korpal re FW 03/26/20 Large
Outgoing Wire with attachments
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX265
JPMC-00000068 03/26/2020
Email from Timothy Coffey to
Rakesh Korpal re Conversation

Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 50 of 57 PageID#
745

ATTACHMENT A
Chain Bridge Trial Exhibits—May Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT DATE
DESCRIPTION
JPMC’s OBJECTIONS
initiated by
timothy.p.coffey@jpmchase.com
DTX266
JPMC-00000069 03/26/2020
Skype conversation between June
Cantrell and Rakesh Korpal

DTX267
JPMC-00000119 03/26/2020
Email from Rakesh Korpal to Shinu
Varghese re Conversation initiated by
rakesh.korpal@jpmchase.com
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX268
JPMC-00000121 03/26/2020
Email from Rakesh Korpal to
Michael Smith re Conversation
initiated by
rakesh.korpal@jpmchase.com

DTX269
JPMC-00000247 04/15/2020
Email from Timothy Coffey to Brian
Stephenson re $456MM/Chain
Bridge Bank/JPM200326-004818/
Funds recovered on 3/26
JPMC objects to this exhibit because it is not
relevant to any issue to be decided in this case
under Fed. R. Evid. 401-402. JPMC objects to
this exhibit on the ground that the foundation
necessary for its admission has not been laid
under Fed. R. Evid. 602. JPMC objects to this
exhibit because it constitutes or contains
hearsay under Fed. R. Evid. 801-802. JPMC
objects to this exhibit because it contains a
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 51 of 57 PageID#
746

ATTACHMENT A
Chain Bridge Trial Exhibits—May Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT DATE
DESCRIPTION
JPMC’s OBJECTIONS
document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX270
JPMC-00000270 05/04/2020
Email from Rakesh Korpal to Brian
Stephenson re Conversation initiated
by rakesh.korpal@jpmchase.com
JPMC objects to this exhibit because it is not
relevant to any issue to be decided in this case
under Fed. R. Evid. 401-402. JPMC objects to
this exhibit on the ground that the foundation
necessary for its admission has not been laid
under Fed. R. Evid. 602. JPMC objects to this
exhibit because it constitutes or contains
hearsay under Fed. R. Evid. 801-802. JPMC
objects to this exhibit because it contains a
document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX271
JPMC-00000465 03/26/2020
Handwritten notes
JPMC objects to this exhibit because it is
incomplete under Fed. R. Evid. 106. JPMC
objects to this exhibit on the ground that the
foundation necessary for its admission has not
been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
DTX272
JPMC-
00000469-70
03/26/2020
JPMC Transaction Reference
Number: 2693100086JO/Client
Name: California State Treasurer
Alert Summary

DTX273
DGS0960
12/16/2020
Email from Lilian Lee to Fee Chang
[no re line]
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 52 of 57 PageID#
747

ATTACHMENT A
Chain Bridge Trial Exhibits—May Offer

DTX275
DGS0209-10
03/26/2020
Email from Andrew Sturmfels to
Andre Rivera re email chain restored
w/all who need to know....

DTX276
BFM000009562-
565
03/20/2020
Email from Ethan Bearman to Mike
Gula re: Fwd: New voicemail
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX277
JPMC-
00000394-395
06/16/2020
Email from Art Neville to Rakesh
Korpal and Rosalyn Nguyen re:
Confidential: State of California
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
a document that has not been properly
authenticated under Fed. R. Evid. 901. JPMC
objects to this exhibit because it contains
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 53 of 57 PageID#
748

ATTACHMENT A
Chain Bridge Trial Exhibits—May Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT DATE
DESCRIPTION
JPMC’s OBJECTIONS
communications or information protected from
disclosure by the work product doctrine.
DTX278
JPMC-00000070 03/26/2020
Messages from June Cantrell to
Rakesh Korpal re: Conversation
initiated by
rakesh.korpal@jpmchase.com

DTX279
BFM000117809-
835
03/31/2020
Email from Ethan Bearman to Marc
Serrio re: FW: Wire info
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX280
BFM000077716-
17
N/A
Ltr. from Danny Mays (Maryland) to
Mike Gula re: Purchase Order
#H00P0601445
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX281
BFM000111223-
227
03/25/2020
Email from John Thomas to Abby
Browning re: Facemask sample?
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX282
BFM000074866 03/25/2020
Text messages between Betty Yee
and John Thomas
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 54 of 57 PageID#
749

ATTACHMENT A
Chain Bridge Trial Exhibits—May Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT DATE
DESCRIPTION
JPMC’s OBJECTIONS
DTX283
BFM000065351-
53
04/30/2020
Email from Marc Serrio to John
Thomas and Mike Gula re: Cash
Position Snapshot
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX284
BFM000048393-
396
04/16/2020
Email from Marc Serrio to Henry
Huang, Mike Gula, Ethan Bearman,
and Joy Xu re: Updated PO 1006
(Chicago) and Funds Sent to Wingar
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX285
BFM000046589-
593
04/15/2020
Email from Ethan Bearman to Mike
Gula re: Fwd: URGENT PO 1-4
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX286
BFM000018938-
940
04/01/2020
Email from Ethan Bearman to Mike
Gula re: Wiring Instructions
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
DTX287
CBB00004294-
301
03/2014
Chain Bridge Bank, N.A. Wire
Transfer Policy

DTX288
N/A
05/06/2020
Sophia Bollag et al., ‘Urgency and
panic’: Inside Gov. Gavin Newsom’s
rush to buy coronavirus gear, The
Sacramento Bee
JPMC objects to this exhibit on the ground that
the foundation necessary for its admission has
not been laid under Fed. R. Evid. 602. JPMC
objects to this exhibit because it constitutes or
contains hearsay under Fed. R. Evid. 801-802.
JPMC objects to this exhibit because it contains
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 55 of 57 PageID#
750

ATTACHMENT A
Chain Bridge Trial Exhibits—May Offer

EXHIBIT
NUMBER
BATES
NUMBER
EXHIBIT DATE
DESCRIPTION
JPMC’s OBJECTIONS
a document that has not been properly
authenticated under Fed. R. Evid. 901.
DTX289
BFM000001582 03/26/2020
Great Health Companion Order
Confirmation
JPMC objects to this exhibit as being unrelated
to Chain Bridge’s claims against JPMC. JPMC
reserves its right to object on all grounds if this
exhibit is used against JPMC.
Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 56 of 57 PageID#
751

CERTIFICATE OF SERVICE

I certify that on this 26th day of April, 2021, I electronically filed the foregoing using the
Court’s CM/ECF system, which will then send a notification of such filing to all counsel of
record.
/s/ Meredith K. Loretta

Meredith K. Loretta
1875 Pennsylvania Avenue N.W.
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Case 1:20-cv-00658-LMB-IDD Document 103 Filed 04/26/21 Page 57 of 57 PageID#
752

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Order (Dkt. 33), Third-Party Defendant JPMorgan Chase Bank, N.A. (“JPMC”) respectfully — Blue Flame Medical LLC v. Chain Bridge Bank, N.A., et al.

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