JPMorgan Chase Bank, N.A.’s Memorandum in Support of Motion to File an Unredacted Memorandum in Opposition — Blue Flame Medical LLC v. Chain Bridge Bank, N.A. (E.D. Va. No. 1:20-cv-00658)

Summary

JPMorgan Chase Bank, N.A.’s memorandum in support of its motion to file an unredacted memorandum in opposition to Chain Bridge Bank, N.A.’s motion to establish the amount of indemnified fees and expenses under provisional seal, filed 11/18/21 as Document 200 in Case 1:20-cv-00658-LMB-IDD. The memorandum states that the opposition contains material that Chain Bridge Bank has designated Confidential Discovery Material under the Protective Order, and that JPMC takes no position on those designations. It notes that Chain Bridge moved to seal substantially the same information in exhibits to its motion and that the Court granted that motion. JPMC says it is providing public notice of the request so that interested parties and non-parties can object.

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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 (LMB/IDD)

CHAIN BRIDGE BANK, N.A.,

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

Third-Party Defendant.

JPMORGAN CHASE BANK, N.A.’S MEMORANDUM IN SUPPORT OF MOTION TO
FILE AN UNREDACTED MEMORANDUM IN OPPOSITION TO CHAIN BRIDGE
BANK, N.A.’S MOTION TO ESTABLISH THE AMOUNT OF INDEMNIFIED FEES
AND EXPENSES TO BE AWARDED FROM JPMORGAN CHASE BANK, N.A.
UNDER PROVISIONAL SEAL
Third-Party Defendant JPMorgan Chase Bank, N.A. (“JPMC”) submits this
Memorandum in Support of JPMC’s Motion to File An Unredacted Memorandum in Opposition
to Chain Bridge’s Motion to Establish the Amount of Indemnified Fees and Expenses to Be
Awarded From JPMC Under Provisional Seal pursuant to Federal Rule of Civil Procedure 26,
Local Civil Rule 5(C), this Court’s September 24, 2020 Order (Dkt. 37) (“Rule 16(b) Scheduling
Order”), and the Amended Stipulated Confidentiality Agreement and Protective Order (Dkt. 68)
Case 1:20-cv-00658-LMB-IDD     Document 200     Filed 11/18/21     Page 1 of 4 PageID#
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(“Protective Order”).  JPMC moves to file under provisional seal an unredacted version of
JPMC’s memorandum in opposition to Chain Bridge’s motion.
In support of this position, JPMC states the following.  Paragraph 7 of the Protective
Order obligates JPMC to file “any document or thing containing or embodying Confidential …
Discovery Material … under seal[.]”  Dkt. 68 ¶ 7.  JPMC’s memorandum in opposition contains
material that Chain Bridge Bank, N.A. has designated “Confidential Discovery Material” under
the terms of the Protective Order.  JPMC takes no position on those designations.  JPMC notes
that Chain Bridge moved to seal substantially the same information as it was contained within
exhibits to its Motion to Establish the Amount of Indemnified Fees and Expenses to Be Awarded
from JPMC.  See Dkt. 187.  The Court granted that motion.  Dkt. 197.
Pursuant to Paragraph 10(a) of the Rule 16(b) Scheduling Order, “Where a party moves
to file material under seal because the opposing party has designated that material as
confidential, the opposing party must file a response to the motion and a proposed order that
meet the requirements of Local Civil Rule 5.”  Dkt. 37 ¶ 10(a).
JPMC is providing public notice of this request to provisionally seal the Confidential
Documents such that interested parties, as well as non-parties, will have an opportunity to object.
Entry of that Notice and this Memorandum onto the Court’s public docket will notify any
interested individuals of the provisional sealing request.
For the foregoing reasons, JPMC respectfully requests that the Court grants its Motion to
File An Unredacted Memorandum in Opposition to Chain Bridge’s Motion to Establish the
Amount of Indemnified Fees and Expenses to Be Awarded From JPMC Under Provisional Seal.

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Dated:  November 18, 2021
Respectfully submitted,
WILMER CUTLER PICKERING HALE
AND DORR LLP
/s/ Meredith K. Loretta

Meredith K. Loretta (92369)
Albinas J. Prizgintas (pro hac vice)
Whitney Russell (pro hac vice)
1875 Pennsylvania Avenue N.W.
Washington, DC  20006
Tel.: (202) 663-6981
Fax: (202) 663-6363
meredith.loretta@wilmerhale.com

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
Fax: (212) 230-8888
alan.schoenfeld@wilmerhale.com

Felicia Ellsworth (pro hac vice)
60 State Street
Boston, MA  02109
Tel.: (617) 526-6000
Fax: (617) 526-5000
felicia.ellsworth@wilmerhale.com

Margarita M. Botero (pro hac vice)
1225 17th Street, Suite 2600
Denver, CO  80202
Tel.: (720) 274-3135
Fax: (720) 274-3133
margarita.botero@wilmerhale.com

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CERTIFICATE OF SERVICE

I certify that on this 18th day of November, 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.
Washington, DC  20006
Tel.: (202) 663-6981
meredith.loretta@wilmerhale.com

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